P22. 2 GHG Emissions from Electrical Generation Support regional and subregional efforts to reduce greenhouse gas emissions associated with electrical generation through energy conservation strategies and alternative/ renewable energy programs.
P22. 3 GHG Emissions from Water Conveyance Support regional and subregional efforts to reduce greenhouse gas emissions associated with water conveyance through water conservation strategies and alternative supply programs.
P22. 4 Solid Waste- Related GHG Emissions Support regional and subregional efforts to reduce emissions associated with solid waste through increased recycling programs and reduced waste strategies.
P22. 6 GHG Emissions from Waste Support projects, programs, policies and regulations to reduce greenhouse gas emissions from waste through improved management of waste handling and reductions in waste generation.
P22. 8 Sustainable Communities Strategies Support projects, programs, policies and regulations to coordinate future community- based planning eff orts of the Focus Areas for consistency with the SCAG Sustainable Communities Strategy and Orange County Sustainable Communities Strategy.
P22. 9 Development Support projects which voluntarily desire to implement site and/ or building design features exceeding minimum requirements to reduce project greenhouse gas emissions.
City of Fullerton Climate Action Plan
The City of Fullerton CAP provides a framework to reduce GHG emissions to a level consistent with the State reduction targets. The CAP establishes a baseline emissions inventory, future emission projections, and strategies, actions, and measures to meet reduction targets. The CAP includes the following strategies:
Transportation and Mobility Strategy. Promote a balanced transportation system that promotes the use of public transportation and bicycles, reduces congestion, and helps encourage residents to engage in healthy and active lifestyles.
Energy Use and Conservation Strategy. Reduce the carbon footprint of municipal operations to serve as a leader for the community and support the construction of buildings that are energy efficient and incorporate clean, renewable energy sources.
Water Use and Efficiency Strategy. Conserve and protect water resources and promote efficiency through public education.
Solid Waste Reduction and Recycling Strategy. Manage solid waste generation and diversion in order to achieve a zero-waste future.
Thresholds of Significance
South Coast Air Quality Management District
The SCAQMD formed a GHG CEQA Significance Threshold Working Group to provide guidance to local lead agencies on determining significance for GHG emissions in their CEQA documents. This working group was formed to assist SCAQMD’ s efforts to develop a GHG significance threshold and is composed of a AOO
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wide variety of stakeholders including the State Office of Planning and Research, CARB, the Attorney General’ s Office, a variety of city and county planning departments in the SCAB, various utilities such as sanitation and power companies throughout the SCAB, industry groups, and environmental and professional organizations. The Working Group has proposed a tiered approach to evaluating GHG emissions for development projects where SCAQMD is not the lead agency, wherein projects are evaluated sequentially through a series of “tiers” to determine whether the project is likely to result in a potentially significant impact due to GHG emissions.
With the tiered approach, a project is compared against the requirements of each tier sequentially and would not result in a significant impact if it complies with any tier. Tier 1 excludes projects that are specifically exempt from SB 97 from resulting in a significant impact. Tier 2 excludes projects that are consistent with a GHG reduction plan that has a certified final CEQA document and complies with AB 32 GHG reduction goals. Tier 3 excludes projects with annual emissions lower than a screening threshold.
The SCAQMD has adopted a threshold of 10,000 MTCO2e per year for industrial projects and a 3,000 MTCO2e threshold was proposed for non-industrial projects but has not been adopted. During Working Group Meeting #7 it was explained that this threshold was derived using a 90 percent capture rate of a large sampling of industrial facilities. During Meeting # 8, the Working Group defined industrial uses as production, manufacturing, and fabrication activities or storage and distribution ( e.g., warehouse, transfer facility, etc.). The Working Group indicated that the 10,000 MTCO2e per year threshold applies to both emissions from construction and operational phases plus indirect emissions ( electricity, water use, etc.). The SCAQMD concluded that projects with emissions less than the screening threshold would not result in a significant cumulative impact.
Tier 4 consists of three options. Under the Tier 4 first option, SCAQMD initially outlined that a project would be excluded if design features and/ or mitigation measures resulted in emissions 30 percent lower than business as usual emissions. However, the Working Group did not provide a recommendation for this approach. The Working Group folded the Tier 4 second option into the third option. Under the Tier 4 third option, a project would be excluded if it was below an efficiency- based threshold of 4.8 MTCO2e per service population per year. Tier 5 would exclude projects that implement off-site mitigation ( GHG reduction projects) or purchase offsets to reduce GHG emission impacts to less than the proposed screening level.
When the tiered approach is applied to a proposed project and the project is found not to comply with Tier 1 or Tier 2, a project’ s emissions are compared against a screening threshold, as described above, for Tier 3. The screening threshold formally adopted by SCAQMD is an “ interim” screening threshold for stationary source industrial projects where the SCAQMD is the lead agency under CEQA. The threshold was termed “ interim” because the SCAQMD anticipated that CARB would adopt a statewide significance threshold that would inform and provide guidance to SCAQMD in its adoption of a final threshold.
However, no statewide threshold was ever adopted, and the interim threshold remains in effect.
For projects for which SCAQMD is not the lead agency, no screening thresholds have been formally adopted. However, the SCAQMD Working Group recommended a threshold of 10,000 MTCO2e per year for industrial projects and 3,000 MTCO2e per year for residential and commercial projects. SCAQMD determined that these thresholds would “ capture” 90 percent of GHG emissions from these sectors, capture” meaning that 90 percent of total emissions from all new projects would be subject to some type AOO
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of CEQA analysis ( i.e., found potentially significant). 49 For purposes of this analysis, the threshold of significance is conservatively 3,000 MTCO2e per year.
City of Fullerton Climate Action Plan
The CAP does not include quantitative project- level CEQA thresholds or percentage reduction targets for individual projects. However, the CAP establishes that projects that demonstrate consistency with the emission projections, emission reduction targets, or strategies contained in the CAP would have a less than significant impact on climate change.
Methodology
Project construction would generate emissions from off-road equipment usage and on-road vehicle travel associated with haul, delivery, and construction worker trips. Annual construction emissions are estimated by assuming construction occurs at the earliest feasible date (i.e., a conservative estimate of construction activities) and applying off-road, fugitive dust, and on-road emissions factors in CalEEMod.
As recommended by the SCAQMD, the Project construction emissions were amortized over the lifetime of the Project and added to the Project operational emissions.
Project operations would generate emissions from area sources ( consumer products, architectural coating, and landscaping equipment), electrical generation, mobile sources (motor vehicles from Projectgenerated vehicle trips), water supply and wastewater treatment, solid waste generation, water usage, fugitive refrigerants, an emergency fire pump, and off-road forklifts. The mobile source emissions were estimated in CalEEMod based on the Project vehicle trip generation table included in Appendix L and prepared by Kimley- Horn as informed by the City’ s TAPP Analysis. The Project operational emissions associated with area sources, electricity, water and wastewater, and solid waste were quantified in CalEEMod based on land use activity data. The emergency fire pump emissions were calculated using default emissions rates from the U.S. EPA. The off-road forklift emissions were calculated using default emissions rates from CARB. As addressed in Section 4.6: Energy, the solar panel is assumed to be a 34.1 kW system and would produce 62.23 MWh per year. The use of solar panels would reduce the Project’ s consumption of grid electricity and would thus reduce operational electricity GHG emissions. The emissions reduction attributable to the solar panels was calculated based on the annual electricity provided by the solar panels and default electricity intensity factor from the CalEEMod User Guide. The total Project emissions were analyzed against the conservative SCAQMD 3,000 MTCO2e per year threshold.
Impact Analysis
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Less Than Significant Impact: Construction GHG Emissions. Project construction would result in direct GHG emissions from construction equipment and the transport of materials and construction workers to and from the project site. Construction- generated GHG emissions would be temporary and would cease with completion of construction. Project construction would consist of demolition, site preparation, grading, infrastructure improvements, building 49 South Coast Air Quality Management District. (2008). Staff Report: Interim CEQA GHG Significance Threshold for Stationary Sources, Rules and Plans and Attachment E: Draft Guidance Document – Interim CEQA Greenhouse Gas ( GHG) Significance Threshold, page 3-2.
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construction, paving, and architectural coating applications. 50 Project construction is anticipated to occur over an approximately 13-month period. Construction- generated GHG emissions associated with the Project were calculated using CalEEMod, which is designed to model emissions for land use development projects based on typical construction requirements. See Appendix A for more information regarding the construction assumptions used in this analysis.
Table 20: Project Construction Greenhouse Gas Emissions presents the total GHG emissions generated during Project construction. In accordance with the SCAQMD’ s guidance, GHG emissions from construction were amortized ( i.e., averaged annually) over the lifetime of the Project. 51 As shown in the table, Project construction would result in 572 MTCO2e over the course of construction and approximately 19 MTCO2e per year when amortized.
Table 20: Project Construction Greenhouse Gas Emissions Year MTCO2e
2028 236
2029 336
Total Construction1 572
Amortized over 30 Years 19
1 Total may not add up exactly due to rounding in the modeling calculations.
MTCO2e = metric tons of carbon dioxide equivalent
Source: CalEEMod version 2022.1. Refer to Appendix A for the model outputs.
Less Than Significant Impact: Operational GHG Emissions. Operational or long- term GHG emissions would occur over the life of the Project. Operational GHG emissions would result from direct sources, such as project- generated vehicular traffic, and emergency fire pump, off-road forklifts, and area source usage ( consumer products, architectural coatings, and landscape maintenance equipment). Operational GHG emissions would also result from indirect sources, such as electricity generation, water supply and wastewater treatment, solid waste generation, and fugitive refrigerants from air conditioning or refrigerators. Operational- generated emissions i.e., area, energy, water, wastewater, solid waste, and fugitive refrigerants) associated with the Project were calculated using CalEEMod, which is designed to model emissions based on land use activity data and the Project vehicle trip generation. The Project would generate approximately 212 total daily vehicle trips (146 passenger vehicles and 66 truck vehicles); see Table 1 in Appendix L. The GHG emissions from an emergency diesel fire pump and three diesel forklifts were calculated separately from CalEEMod using default emission rates; refer to Appendix A. The solar panels emissions reduction was calculated based on the annual electricity provided by the solar panels
62.23 MWh per year) and default electricity intensity factor from the CalEEMod User Guide. The default electricity intensity factor is based on the Project’ s electricity provider ( SCE) and the first operational year ( 2028). The Project operational GHG emissions are summarized in Table 21:
Project Operational Greenhouse Gas Emissions. It should be noted that Table 21 conservatively does not take credit for GHG emissions occurring under existing conditions. For example, the Project would result in a net reduction of 422 total daily vehicle trips when compared to existing 50 Although not proposed, this analysis conservatively assumes full-width grind and overlay improvements along Cypress Way. 51 The project lifetime is based on the standard 30-year assumption of the South Coast Air Quality Management District (South Coast Air Quality Management District. [ 2009]. Minutes for the GHG CEQA Significance Threshold Stakeholder Working Group #13.
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conditions; refer to Table 1 in Appendix L. Therefore, GHG emissions presented in Table 21 are conservative and would be substantially lower when accounting for existing conditions.
Table 21: Project Operational Greenhouse Gas Emissions
Source MTCO2e per year
Construction 19
Area 2
Electricity 175
Mobile 1,223
Water 75
Waste 32
Refrigeration < 1
Fire Pump 1
Off-Road Forklifts 76
Solar Panels - 10
Total 1,604
SCAQMD Threshold 3,000
Threshold Exceeded? No
1 Total may not add up exactly due to rounding in the modeling calculations.
MTCO2e = metric tons of carbon dioxide equivalent, SCAQMD = South Coast Air Quality Management District Source: CalEEMod version 2022.1. Refer to Appendix A for the model outputs.
As shown in Table 21, the total operational GHG emissions associated with the proposed Project would not exceed the most conservative SCAQMD threshold. As such, impacts in regard to GHG emissions associated with Project implementation would be less than significant. b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
Less Than Significant Impact. This analysis determines the Project’ s consistency with SCAG’ s RTP/ SCS, CARB 2022 Scoping Plan, and CAP.
SCAG RTP/ SCS. Under SB 375, SCAG’ s 2024- 2050 RTP/ SCS establishes GHG emissions goals to reduce GHG emissions in the region by eight percent from 2005 levels by 2020 and 19 percent by 2035. 52 The RTP/ SCS is a long-range vision plan that balances future mobility and housing needs with economic, environmental, and public health goals. The RTP/ SCS plans account for operations and maintenance costs to ensure reliability, longevity, and cost effectiveness. The RTP/ SCS are also supported by a combination of transportation and land use strategies that help the region achieve State GHG emissions reduction goals and FCAA requirements, increased housing production, improved equity and resilience, the preservation of natural lands, improvement of public health, increased transportation safety, support for the region’ s vital goods movement industries and more efficient use of resources. GHG emissions resulting from development- related mobile sources are the most potent source of emissions, and therefore Project comparison to the RTP/ SCS is an appropriate indicator of whether the Project would inhibit the post- 2020 GHG reduction goals 52 California Air Resources Board. (N.D.). SB 375 Regional Targets. Retrieved from: https:// ww2.arb.ca.gov/our-work/ programs/ sustainablecommunities- program/ sb-375-regional- targets. Accessed September 9, 2025.
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promulgated by the State. The Project’ s consistency with the 2024-2050 RTP/ SCS goals in Table 22: Regional Transportation Plan/ Sustainable Communities Strategy Consistency.
Table 22: Regional Transportation Plan/ Sustainable Communities Strategy Consistency SCAG Goals Compliance
2024 REGIONAL TRANSPORTATION PLAN/ SUSTAINABLE COMMUNITIES STRATEGY CONSISTENCY1 Mobility: Build and maintain an integrated multimodal transportation network.
Support investments that are wellmaintained and operated, coordinated, resilient and result in improved safety,
improved air quality and minimized
greenhouse gas emissions.
N/ A: This is not a project-specific policy and is therefore not applicable.
Ensure that reliable, accessible,
affordable, and appealing travel options
are readily available, while striving to
enhance equity in the offerings in highneed communities.
N/ A: This is not a project-specific policy and is therefore not applicable.
Support planning for people of all ages,
abilities, and backgrounds
N/ A: This is not a project-specific policy and is therefore not applicable.
Communities: Develop, connect, and sustain communities that are livable and thriving.
Create human- centered communities in
urban, suburban, and rural settings to
increase mobility options and reduce
travel distances.
Consistent: The project site is located within 0.5 mile of SR91 and SR-57 and in an urban area near existing employment opportunities and community services. The Project would also result in a net reduction of 422 daily vehicle trips when compared to existing conditions. The project site location and the reduction in daily trips would reduce trip lengths, VMT, and associated GHG emissions.
Produce and preserve diverse housing
types in an effort to improve affordability,
accessibility, and opportunities for all
households.
N/ A: The Project does not propose residential uses.
Therefore, this is not a project-specific policy and is not applicable.
Environment: Create a healthy region for the people of today and tomorrow Develop communities that are resilient
and can mitigate, adapt to, and respond
to chronic and acute stresses and
disruptions, such as climate change.
Consistent: The Project would develop a central warehouse on an infill site. The Project’ s reduction in net daily trips and the project site location in an urban area would reduce VMT and the associated GHG emissions. The Project would
comply with all applicable energy efficiency and
sustainability measures. Specifically, the Project would include solar panels, which would reduce the Project’ s dependence on the electrical grid and associated energy source emissions. The Project would additionally include drought- tolerant landscaping and an irrigation system that would adjust run times based on local weather conditions.
The Project is located approximately 16 miles inland and would therefore not be subject to risks associated with sea level rise. The proposed warehouse would include central air condition to offer relief from increased exterior surface temperatures. The Project promotes GHG-reduction
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Table 22: Regional Transportation Plan/ Sustainable Communities Strategy Consistency SCAG Goals Compliance
strategies and is well suited to maintaining resiliency against the effects of climate change and associated health impacts.
Integrate the region’ s development
pattern and transportation network to
improve air quality, reduce greenhouse
gas emissions and enable more
sustainable use of energy and water.
Consistent: The Project is not a transportation improvement Project. However, Project implementation would reduce the total daily trips and VMT to the project site, when compared to existing conditions. Additionally, the project site location in an urban area would reduce truck trip lengths and VMT.
As such, Project implementation would reduce mobile
associated GHG emissions. Additionally, the reduction of energy use, improvement of air quality, and promotion of more environmentally sustainable development are
encouraged through compliance with the California Building Energy Efficiency Standards and the Green Building
Standards Code.
Conserve the region’ s resources. Consistent: As described in Section 4.2: Agriculture and Forestry Resources, the project site is not located on or near land that is designated for agricultural purposes. Therefore, Project implementation would not result in a loss of the region’ s resources.
Economy: Support a sustainable, efficient, and productive regional economic environment that provides opportunities for all people inthe region.
Improve access to jobs and educational
resources.
Consistent: The Project proposes a warehouse development within an urban area with residential, retail, and institutional land uses. The Project would provide approximately 113 jobs in an urban area, which would improve access to jobs
opportunities.
Advance a resilient and efficient goods
movement system that supports the
economic vitality of the region,
attainment of clean air and quality of life
for our communities.
Consistent: The Project proposes a warehouse in an urban area near SR-91 and SR-57. Therefore, the Project would support efficient goods movement and would reduce VMT.
Additionally, the Project would provide approximately 113 jobs to the local area. As summarized above, the Project would result in less than significant air quality and health risk impacts.
1 Based on employee generation factor of one employee per 979 sf of warehouse use provided, the Project is anticipated to employ approximately 113 employees. Source: Natelson Company, Inc. (2001). Employment Density Study Summary Report, Table 6A.
N/A = not applicable; SR = State Route; VMT = vehicle miles traveled; LST = localized significance threshold; GHG = greenhouse gas Sources: Southern California Association of Governments. ( 2024). Connect SoCal ( 2024 – 2050 Regional Transportation Plan/ Sustainable Communities Strategy).
As shown in Table 22, the Project would be consistent with the applicable goals of the 2024-2050 RTP/ SCS. Therefore, the Project would not interfere with SCAG’ s ability to achieve the region’ s post-2020 mobile source GHG reduction targets and a less than significant impact would occur.
CARB 2022 Scoping Plan. The 2022 Scoping Plan sets a path to achieve targets for carbon neutrality and reduce anthropogenic GHG emissions by 85 percent below 1990 levels by 2045 in accordance with AB 1279. The transportation, electricity, and industrial sectors are the largest GHG contributors in the State. The 2022 Scoping Plan provides guidance to achieve the AB 1279 targets primarily through zero- emission transportation ( e.g., electrifying cars, buses, trains, and trucks).
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Additional GHG reductions are achieved through decarbonizing the electricity and industrial sectors.
Statewide strategies to reduce GHG emissions in the latest 2022 Scoping Plan include implementing SB 100, which would achieve 100 percent clean electricity by 2045; achieving 100 percent ZE vehicles in 2035 through Advanced Clean Cars II, 53 and implementing the Advanced Clean Fleets regulation to deploy ZE buses and trucks. 54 Additional transportation policies include the Potential Phased Advanced Clean Equipment Regulation, Clean Off-Road Fleet Recognition Program, In-use Off-Road Diesel-Fueled Fleets Regulation, and Amendments to the In-use Off-Road Diesel- Fueled Fleets Regulation. The 2022 Scoping Plan would continue to implement SB 375.
Project GHGs would be further reduced through the Cap-and-Trade Program carbon pricing and SB 905. SB 905 requires CARB to create the Carbon Capture, Removal, Utilization, and Storage Program to evaluate, demonstrate, and regulate carbon dioxide removal projects and technology.
As indicated in Table 21, approximately 87 percent of the proposed Project’ s GHG emissions are from energy (i.e., electricity generation) and mobile sources, which would be further reduced by the 2022 Scoping Plan measures described above. The Project would include solar panels, which would reduce the Project’ s electricity consumption and associated energy source emissions. The Project would result in a net reduction of 422 total daily vehicle trips when compared to existing conditions. As such, Project implementation would decrease VMT and associated mobile source emissions. Additionally, energy and mobile source emissions would further decline in the future due to statewide measures discussed above, as well as cleaner technology and fleet turnover.
Therefore, the reduction of GHG emissions would be consistent with the 2022 Scoping Plan’ s goal to reduce GHG emissions.
Following compliance with all applicable regulations, the proposed Project would not conflict with the State’ s progress towards carbon neutrality under the 2022 Scoping Plan. While these measures are not directly applicable to the Project, any commercial activity associated with goods movement would be required to comply with these measures as adopted. The Project would not obstruct or interfere with efforts to increase ZE vehicles or State efforts to improve system efficiency, nor conflict with the State’ s progress towards carbon neutrality under the 2022 Scoping Plan. It is also noted that the Project would not convert any Natural and Working Lands and/ or decrease the urban forest carbon stock in the State, which are areas of emphasis in the 2022 Scoping Plan. As such, the Project would not interfere with implementation of the 2022 Scoping Plan and a less than significant impact would occur.
City of Fullerton Climate Action Plan. The CAP includes strategies directed at reducing citywide GHG emissions through energy use and conservation, water use and efficiency, transportation and mobility, and solid waste reduction and recycling. The CAP establishes that projects that demonstrate consistency with the emission projections, emission reduction targets, or strategies contained in the CAP would have a less than significant impact on climate change. As stated in 53 On May 22, 2025, the United States Senate voted to revoke the waiver granted by the Biden administration for the Advanced Clean Cars II program. On June 12, 2025, the Trump Administration formally nullified the Advanced Clean Cars II program. 54 On January 13, 2025, CARB withdrew their requests for Clean Air Act waivers from the U.S. EPA needed to support four recently adopted vehicle emissions regulations: ( 1) the Advanced Clean Fleets Regulations; ( 2) the In-Use Locomotive Regulations; ( 3) part of the Commercial Harbor Craft and Ocean-Going Vessels At-Berth Regulations; and (4) part of the Transport Refrigeration Unit Engine Standards Regulations.
Therefore, implementation of these regulations is currently unknown.
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Section 4.3: Air Quality, the project site is consistent with The Fullerton Plan land use designation.
Therefore, project- related emissions have been accounted for in the City’ s projected emissions forecast. As stated above, the Project would comply with the CARB 2022 Scoping Plan strategies aimed at reducing GHG emissions. Therefore, the Project would be consistent with the emission reduction targets. Additionally, Project consistency with the CAP strategies are discussed below:
Energy Use and Conservation. The proposed Project would be an infill development and would be designed in compliance with the latest Title 24 Energy Code and CALGreen Code.
Therefore, the Project would improve energy efficiency when compared to existing conditions.
Water Use and Efficiency. The Project would comply with the City’ s Water Efficiency Landscape Ordinance. The Project would include drought-tolerant landscaping and low flow irrigation systems with a smart controller that adjusts the water flow based on weather conditions. Furthermore, the Project would comply with the latest CALGreen Code water conservation requirements.
Transportation and Mobility. The project site’ s location within an urban area would reduce trip lengths and VMT. Additionally, the Project would result in a net reduction of 422 total daily trips when compared to existing conditions. Further, the Project would provide longterm bicycle parking and 4 EVCS, thus promoting alternative modes of transportation.
Solid Waste Reduction and Recycling. Project construction would comply with the CALGreen Code, which requires 65 percent of waste to be diverted. Additionally, the Project would comply with AB 341, which requires implementation of a recycling program to divert solid waste from landfills.
As discussed herein, the Project would be consistent with the City’ s emission forecasts, emissions reduction targets, and CAP strategies. Impacts in regard to Project consistency with the CAP are less than significant. Therefore, the Project would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing GHG emissions. A less than significant impact would occur, and no mitigation is required.
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4.9 HAZARDS AND HAZARDOUS MATERIALS
ENVIRONMENTAL IMPACTS
Potentially
Significant
Issues
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
9. HAZARDS AND HAZARDOUS MATERIALS. Would the project:
a) Create a significant hazard to the public or the
environment through the routine transport, use, or
disposal of hazardous materials?
X
b) 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?
X
c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within onequarter mile of an existing or proposed school? X
d) 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 aresult, would
it create a significant hazard to the public or the
environment?
X
e) For a project located within an airport land use plan or, where such aplan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?
X
f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency
evacuation plan?
X
g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?
X
The basis for the following information and analysis is the Phase I Environmental Site Assessment ( Phase I ESA) ( Orswell & Kasman, October 2023), which is provided as Appendix F: Phase I Environmental Site Assessment.
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a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
Less than Significant Impact. The proposed Project would include the demolition of the existing business park and associated improvements. As stated in the Phase I Environmental Site Assessment ( ESA), during the site investigation, a visual inspection was conducted for presumed asbestos- containing materials (PACMs), lead-based paint, and mold. It was concluded based on the age of the building and visual inspection that PACMs were in good condition, lead-based paint would not be a health hazard, and no mold concerns were identified. In addition, based on the Orange County CA EPA radon concentration Zone 3, the Project would not impacted by radon gas.
Project construction would involve the transport, storage, use and/ or disposal of limited quantities of hazardous materials, such as fuels, solvents, degreasers, and paints. The use of these materials during construction would be short-term and would occur in accordance with standard construction practices, as well as with applicable federal, State, and local regulations. Potentially hazardous materials would be contained, stored, and used during construction in accordance with manufacturers’ instructions and handled in compliance with applicable standards and regulations.
Examples of such activities include fueling and servicing construction equipment and applying paints and other coatings. Project construction would be temporary, and on-site activities would be governed by existing regulations of several agencies. Construction activities would be subject to compliance with relevant regulatory requirements and restrictions concerning the transport, use, or disposal to prevent a significant hazard to the public or environment. The regulatory requirements include SCAQMD Rule 1403 ( fugitive dust). In addition, should a spill or other hazardous materials incident occur, construction staff would stop work and contact a qualified contractor that is well-versed in handling such a situation. All construction activities would be performed in compliance with the California Division of Occupational Safety and Health (Cal/ OSHA) regulations.
Project operations would not involve the use or storage of hazardous substances other than limited quantities of hazardous materials such as solvents, fertilizers, pesticides, and other materials used for regular maintenance of buildings and landscaping. The use of these materials already occurs within the site associated with the existing use, and the quantities of these materials would not typically be at an amount that would pose a significant hazard to the public or the environment.
The routine transport, use, and disposal of these materials must adhere to federal, State, and local regulations for transport, handling, storage, and disposal of hazardous substances; such as the Hazardous Materials Transportation Act and Hazardous Materials Release Response Plans and Inventory Act, which address safe handling procedures and emergency response procedures in the event of an accidental release. Therefore, following compliance with applicable federal, State, and local regulations, Project operations would not result in a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials. Impacts would be less than significant, and no mitigation would be required.
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b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
Less Than Significant Impact. The project site was developed in 1983 as a five-building multi-tenant business park. The site is currently comprised of approximately 85,700 square- feet of office, industrial, and commercial uses between five buildings, a surface parking lot, and landscaping. Due to the project site’ s existing use, there is a potential that prior tenants and land uses could have resulted in the accidental release of hazardous materials into the environment. A Phase I ESA was prepared to identify recognized environmental conditions (RECs) that may exist at the project site, including historical recognized environmental conditions ( HRECs), controlled recognized environmental conditions ( CRECs), and vapor migration. The Phase I ESA reported no RECs, HRECs, or CREDs and no off-site locations with potential threat of vapor migration to the project site. As noted above, there would be no potential presence of asbestos- containing materials, lead- based paints, mold, or radon.
Outlined in the Phase I ESA a review of the CAL-EPA Department of Toxic Substances Control (DTSC) and Regional Water Quality Control Board ( RWQCB) databases did identify multiple open DTSC/ RWQCB cases surrounding the site, however most are downgradient and recent plume maps are away from the project site. There are two DTSC cases georeferenced cross- gradient as Winonics, Inc. and the Placentia Avene School Site. These sites are listed to need evaluation; however, the Phase I ESA states that due to the locational distance away from the project site, it would not likely have a significant impact on the site. There are no hazardous clean- up cases on the project site. Therefore, Project construction would not create a significant hazard to the public or to the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment.
The Project would not generate or facilitate the generation of hazardous materials. The proposed Project would involve typical hazardous materials/ chemicals associated with warehouse uses such as fuels, paints, mechanical fluids, cleaners, solvents, and fertilizers and pesticides for landscaping.
However, the types and quantities of materials used and stored on site would not be of a significant quantity to create a reasonably foreseeable upset or accident. Additionally, any routine use, storage, and transport of hazardous materials during Project operations must adhere to federal, State, and local regulations for transport, handling, storage, and disposal of hazardous substances.
Hazardous materials/ chemicals such as fuels, cleaners, paints, solvents and fertilizers in low quantities do not pose a significant threat related to the release of hazardous materials into the environment.
Title 24 requires solar arrangements on industrial buildings to have battery storage systems to provide backup power in case of emergencies or grid outages. The battery storage system would be regulated by Title 24, Part 9 California Fire Code (CFC). The CFC incorporates standards from the International Fire Code (IFC) and the National Fire Protection Association ( NFPA) ( NFPA 855), to mitigate fire, explosion, and toxic gas risks. Battery storage systems are required to comply with SCAQMD permitting and regulatory requirements, that focus on fire safety and set emission limits of toxic air contaminants. SCAQMD Rule 1420.1 requires negative pressure enclosures, emission control devices, and ambient air monitoring for lead, for which the project would need to comply.
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response plans for battery storage systems that are designed to complement the California Public Utilities Commission, and the SCAQMD' s own Clean Energy Policy aims to promote battery systems that meet emission standards and climate goals. Therefore, with implementation of SCAQMD Rule 1420.1, Senate Bill 38, and implementing measures consistent with the best practices recommended by the SCAQMD, any future battery storage systems that would be installed by the project, would not be anticipated to add significant operational emissions that would contribute to hazardous impacts or adverse health effects. Therefore, Project operations would not result in the accidental release of hazardous materials. Operational impacts would be less than significant, and no mitigation is required.
c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? No Impact. The nearest school to the project site is Commonwealth Elementary School located approximately 1.0 mile north of the project site. Therefore, there are no schools within onequarter mile of the project site. The Project is not anticipated to generate hazardous emissions or involve the handling of hazardous materials, substances, or waste in significant quantities that would have an impact to surrounding schools. The types of hazardous materials that would be routinely handled would be limited to fuels, paints, mechanical fluids, cleaners, solvents, and fertilizers and pesticides for site landscaping. The Project would be required to adhere to all applicable federal, State and regional regulations regarding handling, transport and disposal of hazardous materials. Therefore, the Project would not emit hazardous emissions or handle hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school. No impact would occur, and no mitigation is required. d) 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?
No Impact. Government Code Section 65962.5 refers to the Hazardous Waste and Substances Site List, commonly known as the Cortese List, maintained by the DTSC. The Cortese List identifies hazardous waste and substance sites including public drinking water wells with detectable levels of contamination; sites with known USTs having a reportable release; and solid waste disposal facilities from which there is a known migration. The Cortese List also includes hazardous substance sites selected for remedial action; historic Cortese sites; and sites with known toxic material identified through the abandoned site assessment program. Review of EnviroStor55 and GeoTracker 56 databases indicate the project site is not on a list of hazardous materials sites compiled pursuant to Government Code Section 65962. 5. No impact would occur and no mitigation is required.
e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area? No Impact. Fullerton Municipal Airport is located in the western portion of the City, within the Airport Industrial Focus Area. The project site is not located within the Airport Industrial Focus Area 55 Department of Toxic Substance Control. (2025). Envirostor Database. Retrieved from https:// www.envirostor.dtsc.ca.gov/ public/. 56 State Water Resources Control Board. (2025). GeoTracker. Retrieved from https:// geotracker. waterboards. ca.gov/.
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nor is it located within any Runway Protection Zone or Accident Potential Zones. The project site is located approximately 5 miles to the east of the Fullerton Municipal Airport. Accordingly, the proposed Project would not result in a safety hazard for people working in the area associated with the airport or project site and impacts would be less than significant. f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
Less Than Significant Impact. The Fullerton Safety Element Supplemental identifies potential evacuation routes that could be used during a hazard event. 57 These roadways are intended to meet evacuation needs. The City’ s Emergency Operations Plan provides guidance for the City’ s planned response to extraordinary emergency situations associated with natural disasters, terrorism, technological incidents, and nuclear defense operations. The Emergency Operations Plan anticipates that all major streets within the City would serve as evacuation routes. City highways and arterial streets that connect to SR-91 and SR-57 would serve as potential evacuation routes, in the event of an extraordinary emergency situation.
Orangethorpe Avenue, which the project site is located adjacent to, is identified as an emergency evacuation route. Local access to the project site would still be provided via two driveways along Orangethorpe Avenue. Project operations are not anticipated to result in significant queuing along adjacent roadways that could potentially impede emergency vehicles or impair any emergency evacuation plan. The Project does not propose modification to roadways adjacent to the project site.
Project- related construction activities could temporarily impact street access and traffic flow due to off-site improvements on Orangethorpe Avenue and potential extension of construction activities into the rights- of-way for utility connections, resulting in temporary lane closures. Prior to the issuance of a building permit, the applicant is required to submit appropriate plans for plan review to ensure compliance with zoning, building, and fire codes. The Project would be required to comply with standard conditions SC HAZ-1 and prepare a Traffic Control Plan for implementation during the construction phase, as deemed necessary by the City Traffic Engineer, as well as SC HAZ2, in which the City Community and Economic Development Department would consult with the Fullerton Police Department to disclose temporary closures and alternative travel routes, in order to ensure adequate access for emergency vehicles when construction of a development results in temporary lane or roadway closures. Therefore, implementation of these standard conditions would ensure the Project would not impair the implementation of or physically interfere with an emergency response plan or emergency evacuation plan. Project impacts would be less than significant and no mitigation is required.
g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?
No Impact. The California Department of Forestry and Fire Protection ( CAL FIRE) has mapped fire threat potential throughout California. CAL FIRE threats are based on the availability of fuel and the likelihood of an area burning (based on topography, fire history, and climate). According to CAL 57 City of Fullerton. (2024). Safety Element Supplement, Exhibit 1: Potential Evacuation Routes in Fullerton. Retrieved from:
https:// www.cityoffullerton. com/ home/ showpublisheddocument/ 8834/ 638586480019470000. Accessed July 9, 2025.
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FIRE’ s Fire Hazard Severity Zones Map for the City, the project site is not located in or near a State Responsibility Area (SRA) nor Very High Fire Hazard Severity Zone (VHFHSZ). 58 As illustrated in the Fullerton 2021-2029 Safety Element Exhibit 5: Fire Hazard Severity Zones in Fullerton the project site is located in a Local Responsibility Area (LRA). 59 As shown in CAL FIRE’ s FHSZ Viewer, the closest VHFHZ to the project site is located approximately 4 miles northwest of the site. The project site is located within an urbanized area. The project site and surrounding area are not within or located adjacent to any wildlands or areas identified as being at risk of wildland fires. Therefore, the proposed Project would not expose people or structures to a significant risk of loss, injury, or death involving wildland fires, and no impact would occur.
Standard Conditions and Requirements
SC HAZ- 1: Prior to construction, future developers shall prepare a Traffic Control Plan for implementation during the construction phase, as deemed necessary by the City Traffic Engineer. The Plan may include the following provisions, among others:
At least one unobstructed lane shall be maintained in both directions on surrounding roadways.
At any time only a single lane is available, the developer shall provide a temporary traffic signal, signal carriers (i.e., flag persons), or other appropriate traffic controls to allow travel in both directions.
If construction activities require the complete closure of a roadway segment, the developer shall provide appropriate signage indicating detours/ alternative routes.
SC HAZ- 2: The City Community and Economic Development Department shall consult with the Fullerton Police Department to disclose temporary closures and alternative travel routes, in order to ensure adequate access for emergency vehicles when construction of a development results in temporary lane or roadway closures. 58 CAL FIRE. ( 2024). Fire Hazard Severity Zones Viewer. Retrieved from: https:// egis.fire.ca.gov/ FHSZ/. Accessed on July 9, 2025. 59 City of Fullerton. (2024). Safety Element Supplement, Exhibit 5 Fire Hazard Severity Zones in Fullerton. Retrieved from:
https:// www.cityoffullerton. com/ home/ showpublisheddocument/ 8834/ 638586480019470000. Accessed July 9, 2025.
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4.10 HYDROLOGY AND WATER QUALITY
ENVIRONMENTAL IMPACTS Potentially
Significant
Issues
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
10. HYDROLOGY AND WATER QUALITY. Would the project:
a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality?
X
b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the
project may impede sustainable groundwater
management of the basin?
X
c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
i) Result in substantial erosion or siltation on- or offsite? X ii) Substantially increase the rate or amount of surface runoff in a manner which would result in flooding onor offsite? X
iii) 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?
X
iv) Impede or redirect flood flows? X
d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
X
e) Conflict with or obstruct implementation of a water
quality control plan or sustainable groundwater
management plan?
X
This section is based on the Preliminary Water Quality Management Plan (PWQMP) ( Pacific Consulting Group, Inc., 2025) which is included in its entirety as Appendix G: Preliminary Water Quality Management Plan and the Hydrology and Hydraulic Report (Pacific Consulting Group, Inc., 2025) which is included in its entirety as Appendix H: Hydrology and Hydraulic Report.
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a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality?
Less than Significant Impact. Project impacts related to water quality could occur over three different periods:
During the earthwork and construction phase, where the potential for erosion, siltation, and sedimentation would be the greatest;
Following construction, before the establishment of ground cover, when the erosion potential may remain relatively high; and
After project completion, when impacts related to sedimentation would decrease markedly but those associated with urban runoff would increase.
Urban runoff, both dry and wet weather, discharges into storm drains, and in most cases, flows directly to creeks, rivers, lakes, and the ocean. Polluted runoff can have harmful effects on drinking water, recreational water, and wildlife. Urban runoff pollution includes a wide array of environmental, and stormwater characteristics dependent on site conditions ( e.g., land use, impervious cover, and pollution prevention practices), rain events ( duration, amount of rainfall, intensity, and time between events), soil type and particle sizes, the amount of vehicular traffic, and atmospheric deposition. Major pollutants typically found in runoff from urban areas include sediments, nutrients, oxygen- demanding substances, heavy metals, petroleum hydrocarbons, pathogens, and bacteria. Most urban stormwater discharges are non-point sources.
Construction. Short-term construction activities associated with the proposed Project could impact water quality. Sources of potential construction- related storm water pollution include handling, storage, and disposal of construction materials containing pollutants; maintenance and operation of construction equipment; and site preparation activities, such as excavation, grading and trenching. These sources, if not controlled, can generate soil erosion and on- and off-site transport via storm run-off or mechanical equipment. Poorly maintained vehicles and heavy equipment leaking fuel, oil, antifreeze, or other vehicle-related fluids on the project site are also common sources of storm water pollution and soil contamination. Implementation of the proposed Project has the potential to produce typical pollutants such as nutrients, heavy metals, pesticides and herbicides, toxic chemicals related to construction and cleaning, waste materials including wash water, paints, wood, paper, concrete, food containers, and sanitary wastes, fuel, and lubricants. Generally, standard safety precautions for handling and storing construction materials can adequately reduce the potential pollution of storm water by these materials. These types of standard procedures can be extended to non-hazardous storm water pollutants such as sawdust, concrete washout, and other wastes.
Grading activities would displace soils and temporarily increase the potential for soils to be subject to wind and water erosion. Two general strategies are recommended to prevent soil materials from entering local storm drains. First, erosion control procedures should be implemented for those areas that must be exposed, and secondly, the project site should be secured to control offsite transport of pollutants. In order to reduce the amount of on-site exposed soil, grading would be limited to the extent feasible, and any graded areas would be protected against erosion once they are brought to final grade. Additionally, the proposed Project would be required to comply AOO
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with the Construction General National Pollutant Discharge Elimination System ( NPDES) Permit and the FMC.
Construction- related erosion effects would be addressed through compliance with the NPDES program’ s Construction General Permit. Construction activity subject to this General Permit includes any construction or demolition activity, including, but not limited to, clearing, grading, grubbing, or excavation, or any other activity that results in a land disturbance of equal to or greater than one acre. The Project would disturb approximately 4.8 acres and therefore would be subject to the General Permit. To obtain coverage under the General Permit, dischargers are required to file with the State Water Resources Control Board ( SWRCB) the Permit Registration Documents ( PRDs), which include a Notice of Intent ( NOI) and other compliance- related documents. The General Permit requires development and implementation of a Stormwater Pollution Prevention Plan (SWPPP) and monitoring plan, which must include erosion- control and sediment- control BMPs that would meet or exceed measures required by the General Permit to control potential construction- related pollutants. Erosion- control BMPs are designed to prevent erosion, whereas sediment controls are designed to trap sediment once it has been mobilized.
Project construction activities would also be required to comply with water quality measures included in the City of Fullerton’ s Water Quality Ordinance ( FMC Chapter 12.18, Water Quality Ordinance). The City’ s Water Quality Ordinance requires compliance with the Orange County Drainage Area Management Plan (DAMP) and any conditions and requirements established by the City in order to meet Federal and State water quality requirements related to storm water runoff.
These regulations would require the Project contractor to include BMPs to ensure that the discharge of pollutants from the site would be effectively prohibited and would not cause or contribute to an exceedance of water quality standards or alter water quality during construction.
In accordance with FMC Section 12.18.030, Control of Urban Runoff, prior to issuance of grading permits, the planning agency would be required to review the Project plans and impose terms, conditions and requirements on the Project in accordance with the DAMP and any conditions and requirements established by the City that are reasonably related to the reduction or elimination of pollutants in stormwater runoff from the project site. Therefore, through adherence to the County of Orange DAMP, the NPDES Stormwater Program and FMC regulations, specified under SC HYD-1 and SC HYD-2, construction- related activities would not violate any water quality standards or otherwise substantially degrade surface or groundwater quality and impacts would be less than significant.
Operations. The project site is located within the jurisdiction of the Santa Ana Regional Water Quality Control Board ( RWQCB) and would be subject to compliance with the Phase I Municipal Separate Storm Sewer System ( MS4) permit. Under the MS4 permit issued by the Santa Ana RWQCB ( Waste Discharge Requirements for the County of Orange, Orange County Flood Control District and Incorporated Cities of Orange County within the Santa Ana Region Areawide Urban Storm Water Runoff, Order No. R8-2009-0030), co-permittees, including the City of Fullerton, must prepare a WQMP and implement BMPs, where feasible, to capture and treat stormwater prior to discharge to their MS4 facilities. Prior to building permit issuance, the Applicant would be required to submit a Final WQMP to the City for review and compliance with the County’ s NPDES stormwater permit. The Final WQMP would be required to specific the BMPs to be incorporated AOO
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into the final Project design to address pollutants of concern associated with runoff from the project site.
The project site is currently developed with a multi-tenant business park and associated improvements, including surface parking and ornamental landscaping. Under existing conditions, the site generally flows from south to north throughout the property. The existing drainage is conveyed via sheet flow through ribbon gutters before it is discharged to Cypress Way through two curb outlets. There is no record of any public stormwater infrastructure adjacent to the project site. Stormwater is assumed to be carried downstream of the project site in the curb and gutter in Cypress Way and conveyed northerly on State College Boulevard where a catch basin is located approximately 1,400 feet away northwest of the project site.
The Preliminary WQMP identifies pollutants of concern associated with the proposed Project, including suspended- solid/ sediment, nutrients, pesticides, oil and grease, toxic organic compounds, and trash and debris. Additionally, the Preliminary WQMP documents the various BMPs that would be implemented as part of the Project, which include biotreatment, treatment control, non-structural source control, and structural source control BMPs to address water quality conditions associated with the proposed Project. Proposed hydrologic source controls include onlot infiltration and impervious area reduction; infiltration BMPs include drywells; treatment control BMPs include a filter insert for each catch basin/ trench drain; proposed non-structural BMPs include education, activity restrictions, common area landscape management, BMP maintenance, local industrial permit compliance, spill contingency plan, hazardous materials disclosure, common area litter control, employee training, housekeeping of loading docks, common area catch basin inspection, and street sweeping private streets; and structural source control BMPs include storm drain stenciling and signage, design and construction of trash and waste storage areas, efficient irrigation systems and landscape design, dock areas, and wash water control; refer to Appendix G for a detailed list of proposed BMPs.
The project site is currently 14.1 percent ( 29,185 square feet) pervious area and 85.9 percent 179,031 square feet) impervious area. In the proposed condition, the project site would be 9.2 percent ( 19,166 square feet) pervious area and 90.8 percent ( 189,486 square feet) impervious area. Therefore, the Project would increase pervious area in the proposed condition.
As concluded in the Preliminary WQMP, infiltration has been deemed feasible through sampling and testing from the Geotechnical Investigation. Therefore, the Project includes infiltration BMPs via drywells. The drywells would be sized according to the North Orange County Technical Guidance Document to infiltrate the 85th percentile, 24-hour storm event. Any overflow due to large storm events in excess of the design storm ( 85th percentile) would be conveyed to Cypress way through means of curb outlets to replicate the existing condition.
Under the proposed condition, runoff generated from the site would fall into two main drainage areas. Roof runoff would be collected through roof drains and directly connected to conveyance piping below grade. Surface drainage would be collected through drains with filters before being conveyed to the drywell system. The drywell system is composed of a manhole shaft that would accumulate sediment and any debris which would be removed during the standard maintenance of the facilities.
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Implementation of standard conditions and the proposed on-site stormwater system and Final WQMP, including water quality operational BMPs, would reduce pollutants of concern associated with the stormwater runoff from the project site in compliance with the County’ s MS4 Permit and ensure the proposed Project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality. Impacts would be less than significant.
b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin? Less than Significant Impact. The City of Fullerton provides water service to the City, including the project site. According to the Fullerton 2020 Urban Water Management Plan ( 2020 UWMP), the project site is located within Pressure Zone 4 in the southeast of the City. 60 The City is a retail water supplier that receives its water supplies from a combination of imported potable water from Metropolitan Water District of Southern California (MWD) and local groundwater from the Orange County Groundwater Basin ( OC Basin), which is managed by the Orange County Water District OCWD). The City’ s main source of water supply is groundwater from the OC Basin. Imported water supplements the City’ s water supply portfolio.
The City’ s Water Utility operates 15 reservoirs with a capacity of 67.5 million gallons, 12 booster pumping stations, 8 active groundwater wells, and manages a 424-mile water mains system with approximately 31,936 service connections. The Fullerton 2020 UWMP forecasts the City’ s total retail water demand to be 27,850-acre feet (AF) by 2045.
The Fullerton 2020 UWMP indicates water supplies would meet the service area’ s water demands for normal, single dry, and multiple dry year conditions through 2045. UWMP water demand forecasts are based in part on adopted General Plans. The Fullerton Plan identifies the development capacity associated with implementation of The Fullerton Plan land use designations.
The Fullerton Plan Community Development Plan ( General Plan Community Development and Design Exhibit 2) designates the project site as Industrial ( I) within the Southeast Industrial Focus Area.
The Project’ s average daily water demand would be approximately 3,196 gallons per day (GPD), an increase of 344 GPD from existing conditions. As discussed under Threshold 4.19b, while the Project would result in a minor increase from existing conditions, the Water Demand Assessment concluded based on fire flow testing that the increase would not significantly impact existing infrastructure and would be able to be serviced by the City (Appendix J). Further, as discussed in Section 4.14:, Population and Housing, the Project would be consistent with the existing land use designation and would not result in significant new unanticipated employment opportunities.
Therefore, the proposed Project would be within the population projections anticipated by the City and the 2020 UWMP. Therefore, the Project would not conflict with UWMP demand projections and would not substantially decrease groundwater supplies. Project impacts would be less than significant and no mitigation is required.
60 Arcadis. (June 2021). 2020 UWMP for City of Fullerton. Available at:
https:// www.cityoffullerton. com/ home/ showpublisheddocument/ 5052/ 637598829614070000, Accessed July 15, 2021.
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As noted above, Project implementation would decrease the site’s effective imperviousness from approximately 86 percent to 91 percent, resulting in a potential increase of runoff in the postdevelopment condition. However, the increased runoff would be offset by the proposed drywells which would infiltrate at 0.62 cubic feet per section ( cfs), which is greater than the increase of runoff generated. This would effectively decrease the amount of runoff generated under the proposed condition and increase infiltrating stormwater. Therefore, the Project would not interfere with groundwater recharge nor would groundwater recharge would be impeded.
Therefore, the Project would neither substantially deplete groundwater supplies nor interfere substantially with groundwater recharge, such that the project may impede sustainable groundwater management of the basin, and a less than significant impact would occur. c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
i) Result in substantial erosion or siltation on- or off-site? ii) Substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite?
iii) 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?
iv) Impede or redirect flood flows?
Less than Significant Impact. As noted in Threshold 4.10a, under existing conditions, runoff on the project site is conveyed via sheet flow through ribbon gutters before it is discharged to Cypress Way through two curb outlets. Stormwater is assumed to be carried downstream of the project site in the curb and gutter in Cypress Way and conveyed north along State College Boulevard where a catch basin is located approximately 1,400 feet away northwest of the project site.
Under proposed conditions, the Project would not result in a significant change to the site’ s drainage pattern and flows would continue to discharge northwest toward Cypress Way. As previously addressed, under proposed conditions, the project site is composed of two main drainage areas. Drainage Area A on the west side of the property and Drainage Area B on the east and north end of the property.
Drainage Area A is 2.83 acres and approximately 57 percent of the building roof drainage as well as 56,616 square feet of paved and hardscaped runoff. The area would contain parking areas and drive aisles along with landscaping and hardscaped walkways. Drainage Area A consists of a sump condition for the loading docks. As described above, the runoff would be conveyed via sheet flow to its respective collection device ( roof drains, area drains, catch basins) before it would be conveyed via pipe flow to the drywell. Downstream of the drywell, a sump pump would be used to discharge excess runoff volumes. The pump would discharge to a catch basin to transition from pressure flow to gravity flow before finally discharging through the curb outlet in Cypress Way.
Drainage Area B is 1.96 acres and approximately 43 percent of the building runoff and 28,539 square feet of paving and hardscape. The area would contain parking areas and drive aisles along with landscaping and hardscaped walkways. This area would collect runoff via the curb and gutter AOO
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located at the east side of the property and the ribbon gutter to the north. This gutter would intermittently intercept flow and convey runoff through conveyance piping. The conveyance piping would convey the tributary runoff to the drywell located at the northeast corner of the property.
Larger storm events would overflow from the drywell to an overflow pipe before eventually being conveyed to Cypress Way through means of a curb outlet. Larger storm events that would have to utilize the overflow would discharge via gravity.
Overall site hydrology is comprised of sheet flowing runoff by gravity through to surface drainage features such as area drains and catch basins. These surface drainage features connect to on-site conveyance piping that would take runoff to two drywells located in the northwest corner of the property, one for each drainage area and sized to be compliant with the Orange County Water Quality Management Plan.
The drywell system is composed of a manhole shaft that would accumulate sediment and any debris which would be removed during the standard maintenance of the facilities. Any overflow due to large storm events in excess of the design storm (85th percentile) would be conveyed to Cypress Way through means of curb outlets to replicate the existing condition. As noted above, Project implementation would decrease the site’ s effective imperviousness from approximately 86 percent to 91 percent, resulting in potentially an increase of runoff of the post-development condition. However, the increased runoff would be offset by the proposed drywells which would infiltrate at 0.62 cfs, which is greater than the increase of runoff generated. Further, the drywells are designed to retain and store a total of 1,402 CF of water. This additional storage would decrease and offset peak flows during large storm events that may discharge to Cypress Way.
Therefore, effectively decreasing the amount of runoff generated under the proposed condition.
Overall, the Project would not impede or redirect flood flows, increase rate or amount of runoff such that flooding would occur on or off the site, nor would it exceed the capacity of existing or planned drainage systems.
d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation? Less than Significant Impact. According to the Federal Emergency Management Agency ( FEMA) Flood Insurance Rate Map (FIRM) No. 06059C0132J, the project site is located within “ Zone X,” which is considered to be an area of minimal flood hazard and is not considered a special flood hazard area. Accordingly, impacts related to release of pollutants due to project inundation in a flood hazard zone would be less than significant.
Tsunamis are sea waves that are generated in response to large-magnitude earthquakes, which can result in coastal flooding. Seiches are the oscillation of large bodies of standing water, such as lakes, that can occur in response to ground shaking. The project site is approximately 14.5 miles east of the Pacific Ocean and there are no large bodies of standing water near the project site. As a result, tsunamis and seiches do not pose hazards due to the project site’ s inland location and lack of nearby bodies of standing water. As the project site is not located within a tsunami or seiche zone, the Project would not risk of release of pollutants due to Project inundation; impacts would be less than significant.
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e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
Less than Significant Impact. Refer to Responses 4.10(a) regarding water quality. As noted in Threshold 4.10b, the City’s local groundwater water supply is produced from the Orange County Groundwater Basin (OC Basin). The OC Basin underlies the northerly half of Orange County beneath broad lowlands. The OC Basin, managed by OCWD, covers an area of approximately 350 square miles, bordered by the Coyote and Chino Hills to the north, the Santa Ana Mountains to the northeast, and the Pacific Ocean to the southwest.
In accordance with the California Urban Water Management Planning Act, the City of Fullerton must prepare and adopt a UWMP every five years. The City’ s most recent 2020 UWMP, which was published in 2021, describes the City’s management operations in achieving the maximum practicable conservation and efficient use of local water resources.
The 2020 UWMP estimated a total water demand of 27,850 AF by 2045. Additionally, the City’ s population is expected to increase from 141,648 persons in 2020 to 189,687 persons by 2045. In case of a water supply shortage, the City has prepared a Water Shortage Contingency Plan to ensure adequate service. The Water Shortage Contingency Plan serves as the operating manual detailing processes and procedures to be deployed during shortage conditions, enabling the City and water retail agencies to identify and efficiently implement pre-determined steps to mitigate a water shortage.
Further, as discussed in Section 4.14: Population and Housing, the Project would be consistent with the existing land use designation and would not result in significant new unanticipated employment opportunities. Therefore, the proposed Project would be within the population projections anticipated by the City and the 2020 UWMP. Further, as noted above and concluded in the Water Demand Assessment, the Project’ s average daily water demand would be approximately 3,196 GPD, an increase of 344 GPD from existing conditions. As discussed, it was concluded based on fire flow testing that the increase would not significantly impact existing infrastructure and the proposed Project would be able to be serviced by the City. Therefore, the Project’ s anticipated water demand is accounted for in the UWMP, and there would be sufficient water supplies available to serve the Project development during normal, dry and multiple dry years. Impacts to water supply would be less than significant. Therefore, the Project would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan and impacts would be less than significant.
Standard Conditions and Requirements
SC HYD- 1 Prior to issuance of any Grading or Building Permit, and as part of the future development’ s compliance with the NPDES requirements, a Notice of Intent shall be prepared and submitted to the Santa Ana RWQCB providing notification and intent to comply with the State of California General Construction Permit. Also, a Stormwater Pollution Prevention Plan ( SWPPP) shall be reviewed and approved by the Director of Engineering for water quality construction activities on-site. A copy of the SWPPP shall be available and implemented at the construction site at all times. The SWPPP shall outline the source control and/ or treatment control BMPs to avoid or mitigate runoff pollutants at the construction site to the “maximum extent practicable.” All recommendations in the AOO
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Plan shall be implemented during area preparation, grading, and construction. The project applicant shall comply with each of the recommendations detailed in the Study, and other such measure( s) as the City deems necessary to mitigate potential stormwater runoff impacts.
SC HYD- 2 Prior to issuance of any Grading Permit, future development projects shall prepare, to the satisfaction of the Director of Engineering, a Water Quality Management Plan or Stormwater Mitigation Plan, which includes Best Management Practices ( BMPs), in accordance with the Orange County Drainage Area Master Plan ( DAMP). All recommendations in the Plan shall be implemented during post construction/ operation phase. The project applicant shall comply with each of the recommendations detailed in the Study, and other such measure( s) as the City deems necessary to mitigate potential water quality impacts.
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4.11 LAND USE AND PLANNING
ENVIRONMENTAL IMPACTS
Potentially
Significant
Issues
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
11. LAND USE AND PLANNING. Would the project:
a) Physically divide an established community? X
b) Cause asignificant 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?
X
a) Physically divide an established community?
No Impact. The Applicant is proposing the demolition of the existing approximately 85,700-squarefoot Cedarwoods Business Park and the construction and operation of a new 110,232-square-foot warehouse/ distribution facility with a surface parking lot and gated truck court. The proposed building would have 100,232 square feet of warehouse space and 10,000 square feet of ancillary office space that is split evenly between the ground level and mezzanine. The surrounding areas are zoned M-P and M-G, and designated as Industrial ( I). Orangethorpe Avenue is located south of the project site. The property located south of Orangethorpe Avenue is located within the City of Anaheim and zoned Industrial by the City of Anaheim. The Project would not involve any roadways or significant infrastructure systems that would physically divide an established community or surrounding areas. Development of the Project would be consistent with surrounding land uses.
Therefore, the Project would not divide an established community, and no impact would occur. b) 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? Less than Significant Impact.
The Fullerton Plan’ s Community Development Plan ( Community Development and Design Exhibit 2) depicts the City’ s land use designations and identifies that the project site is designated Industrial. The Industrial ( I) land use designation is intended to protect and enhance the City’ s major employment areas by providing opportunities for manufacturing, product assembly, research and development, warehousing, and supporting uses and amenities. 61 Therefore, the proposed Project would be consistent with the project site’s Industrial (I) land use designation.
The project site is located within the Southeast Industrial Focus Area. The Focus Area is composed mainly of large parcels with one- and two-story buildings and is characterized by businesses that operate during traditional working hours, with minimal nighttime activity. 61 City of Fullerton. (2012). The Fullerton Plan. https:// www.cityoffullerton.com/government/ departments/ community-and-economicdevelopment/ planning- zoning/ general- plan/ the-fullerton- plan-current-version. Accessed September 10, 2025.
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The Southeast Industrial Focus Area’ s Planning Objectives identified in The Fullerton Plan include:
Retain industrial and employment- generating uses while providing amenities and services that will support the work force, such as recreation, retail, and limited housing opportunities.
Provide for large parcels and flexible spaces to accommodate a variety of industries over the long term while supporting incubator spaces for new and emerging technologies.
Encourage new businesses and compatible new uses, while discouraging those that are in conflict. Specifically seek to expand and attract industrial users that would benefit from freeway access, technology clusters, and industrial infrastructure.
Improve appearance and function through design, including landscaping, pedestrian and transit facilities, and alleyway improvements.
The proposed warehouse use is consistent with the objectives identified in the Southeast Industrial Focus Area. Additionally, consistent with the Southeast Industrial Focus Area, the Project proposes a FAR of 0.53, which is within the 1.0 maximum identified in The Fullerton Plan.
An analysis of the proposed Project’ s consistency with relevant policies of The Fullerton Plan adopted for the purpose of avoiding or mitigating an environmental effect is provided in Table 23: General Plan Policy Consistency. The Project is consistent with The Fullerton Plan.
Table 23: General Plan Policy Consistency
Goal Consistency Analysis
Chapter 1: Community Development and Design
P1.11: Support programs, policies and regulations
to consider the immediate and surrounding
contexts of projects to promote positive design
relationships and use compatibility with adjacent
built environments and land uses, including the
public realm
Consistent. As discussed in Section 4.1: Aesthetics, the site would be subject to FMC 15.40.040, Site Development
Standards, which addresses building exterior design,
screening of rooftop equipment, landscape requirements, building height limits, setback requirements, and fences and walls, amongst others. FMC Chapter 15.47, Site Plan Review, requires that the approval of the reviewed site plan occurs only after the proposed Project is confirmed to follow
development standards and nearby uses. The proposed
Project would be in alignment with this policy.
P1.12: Support projects, programs, policies and
regulations to encourage energy and resource
efficient practices in site and building design for
private and public projects.
Consistent. As discussed in Section 4.6: Energy, the proposed Project would include a variety of energy saving and
renewable energy features, including high-efficiency lighting, solar PV system, provide electric vehicle charging stations, install low flow water fixtures, water-efficient irrigation, and drought tolerant landscaping. Therefore, the Project would be consistent with this policy.
P2.8: Support projects, programs, policies and
regulations to respect the local context, including
consideration of cultural and historic resources,
existing scale and character and development
patterns of the surrounding neighborhood or
district.
Consistent. As previously discussed, the site is identified by the city as Industrial, and the site is zoned as Manufacturing Park (M-P). Nearby sites also fall into these two clearly defined categories. Section 4.5: Cultural Resources states that based on a review of the Register of Historic Places, National Historic Landmarks, and the Built Environment
Resources Directory, a review of resource databases and repositories did not result in the identification of any present AOO
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Table 23: General Plan Policy Consistency
Goal Consistency Analysis
cultural resources in the project site. Therefore, the Project would be consistent with this policy.
Chapter 4: Mobility
P5.16: Support projects, programs, policies and
regulations to encourage the development of
private and/ or public infrastructure facilitating the
use of alternative fuel vehicles
Consistent. As addressed in Section 2.3: Project
Characteristics, the project proposes 4 electric vehicle charging stations ( EVCS) and 13 electric vehicle capable stalls.
Therefore, the proposed project is in alignment with this policy.
Chapter 6: Growth Management
P7.5: Support projects, programs, policies and
regulations to ensure that development is
appropriate in scale to current and planned
infrastructure capabilities.
Consistent. As addressed in Section 2.3: Project
Characteristics, the Project proposes the demolition of the existing approximately 85,700-square-foot Cedarwoods
Business Park and the construction and operation of a new 110,232 square-foot warehouse/ distribution facility. The proposed Project is consistent with The Fullerton Plan land use designation and zoning. Further, the Project would
generate significant population growth. Therefore, the
proposed Project would not require the construction of new or expanded water supply or treatment facilities. The project site currently receives the services necessary and maintains the infrastructure necessary to serve the proposed Project.
Therefore, the Project is consistent with this policy.
Chapter 7: Noise
P8.6: Support projects, programs, policies and
regulations to permit uses where the noise level of
the surroundings— after taking into account noise
insulation features and other control techniques of
the use—is not detrimental to the use.
Consistent. The Project proposes an industrial use and would not be considered a sensitive receptor. As discussed in Section 4.13: Noise, the FMC does not establish noise limits for industrial properties. The noise level of surrounding uses would not affect the proposed Project use. Therefore, the Project would be consistent with this policy.
P8.7: Support projects, programs, policies and
regulations to permit uses and/ or activities where
the noise generated by the use and/ or activity is
not detrimental or otherwise a nuisance to the
surroundings.
Consistent. Refer to consistency analysis for P8.6.
Chapter 10: Public Safety
P17.16: Support programs that foster coordination
between the City and local school districts, colleges
and universities to assess and mitigate project
impacts pertaining to on and off -campus
development.
Consistent. As addressed in Section 4.15: Public Services, the Project would not create a direct demand for public school services as the project proposes non-residential uses that would not generate any school-aged children requiring public education. Further, the Project would not draw a substantial number of new residents to the school districts and therefore would not indirectly generate school- aged students requiring public education. Therefore, the Project would be consistent with this policy.
Chapter 16: Water
P19.7: Support projects, programs, policies and
regulations to encourage water efficient practices
Consistent. The Project would include water efficient design features including low flow water fixtures, water-efficient AOO
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Table 23: General Plan Policy Consistency
Goal Consistency Analysis
in site and building design for private and public
projects.
irrigation, and drought tolerant landscaping. Therefore, the Project would be consistent with this policy.
P20. 6: Construction Impacts. Support projects,
programs, policies and regulations to reduce
impacts to watersheds and urban runoff caused by
private and public construction projects.
Consistent. As discussed in Section 4.10: Hydrology and Water Quality, The General Permit requires development
and implementation of a Stormwater Pollution Prevention Plan (SWPPP) and monitoring plan, which must include
erosion- control and sediment- control BMPs that would meet or exceed measures required by the General Permit to
control potential construction- related pollutants. Erosioncontrol BMPs are designed to prevent erosion, whereas sediment controls are designed to trap sediment once it has been mobilized. Project construction activities would also be required to comply with water quality measures included in the City of Fullerton’ s Water Quality Ordinance ( FMC Chapter
12.18, Water Quality Ordinance). The City’ s Water Quality Ordinance requires compliance with the Orange County
Drainage Area Management Plan (DAMP) and any conditions and requirements established by the City in order to meet Federal and State water quality requirements related to storm water runoff. These regulations would require the Project contractor to include BMPs to ensure that the
discharge of pollutants from the site would be effectively prohibited and would not cause or contribute to an
exceedance of water quality standards or alter water quality during construction. With these measures in place, the
Project would be consistent with this policy.
P20.7: Support projects, programs, policies and
regulations to reduce impacts to watersheds and
urban runoff caused by the design or operation of a
site or use.
Consistent. As discussed in Section 4.10: Hydrology and Water Quality, the proposed Project would be required to submit a Final WQMP to the City for review and compliance with the County’ s NPDES stormwater permit. The Final
WQMP would be required to implement BMPs into the final Project design to address pollutants of concern associated with runoff from the project site. The Project incorporates various BMPs as part of the Project, which include
biotreatment, treatment control, non-structural source
control, and structural source control BMPs to address water quality conditions associated with the proposed Project.
Therefore, the Project would be consistent with this policy.
Chapter 17: Air Quality and Climate Change
P21.6: Construction Impacts. Support projects,
programs, policies and regulations to reduce
impacts to air quality caused by private and public
construction projects.
Consistent. As discussed in Section 4.3: Air Quality, Projectrelated construction activities would include demolition, grading, building construction, and paving, architectural coating, and landscaping. Project construction activities would generate short-term emissions of criteria air
pollutants. However, this short term and minor construction would not exceed the SCAQMD’ s daily emission thresholds at the regional level. In addition, the proposed Project would be subject to compliance with SCAQMD Rules 402, 403, and
1113, which would further reduce specific constructionAOO Jurore”
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Table 23: General Plan Policy Consistency
Goal Consistency Analysis
related emissions. Therefore, the Project would be consistent with this policy.
Chapter 18: Integrated Waste Management
P23.7: Support projects, programs, policies and
regulations to consider project level solid waste
management needs at the site and building design
stages.
Consistent. As discussed in Section 4.19: Utilities and Service Systems, in accordance with State law and FMC Section
14.06.010, the Project would be required to divert at least 65 percent of the nonhazardous construction and demolition debris from the project site by recycling, reuse, and/ or salvage. In addition, the City meets its per capita disposal rate target through diversion programs. The City would continue to implement its diversion programs and require compliance with all federal, State and local statutes and regulations for solid waste, including those identified under the most current CALGreen standards and in compliance with AB 939 and SB 1383. Therefore, the Project would be consistent with this policy.
Zoning. The City of Fullerton Zoning Map identifies the zoning classification on the northern portion of the site as Manufacturing Park with a 100,000-square-foot minimum lot size (MP-100) and Commercial Manufacturing ( CM) over the remaining southern portion of the site.
Additionally, the entirety of the site has an Emergency Shelter Overlay (ES). The proposed Project would rezone the southern portion of the site to MP-100-ES to allow for the warehouse development. The FMC Chapter 15.40, Industrial Zone Classifications, clarifies that M-P zones are established to allow compatible industrial uses in proximity to each other while protecting the public health, safety and welfare through development standards and the site plan review process. It also states that the M-P zone is intended for a wide range of light industrial activities, often based on a multiple- tenant type development. FMC Section 15.40.040, Site Development Standards, provides development standards that apply to the M-P zone.
The Project would also be subject to FMC Section 15.40.040, Site Development Standards, which addresses building height limits, setback requirements, and minimum lot area, amongst others, as well as FMC Section 15.40.050, Parking Standards, which specifies parking requirements.
Consistent with the proposed MP-100-ES zoning district, the proposed warehouse would have a maximum roof line of approximately 44 feet in height, 91 passenger vehicle parking stalls - including electric vehicle charging and capable stalls, an approximately 21 foot setback from Orangethorpe Avenue, and a total of 19,109 square feet of landscaping, focused near parking lot areas, the warehouse, site perimeter, and driveway entries. As part of the City’ s Site Plan Review process required under FMC Chapter 15.47, Site Plan Review, the Project site plan would be reviewed and only approved after finding the proposed development, including the uses and the physical design of the development is consistent with the intent and general purposes of the chapter, and would not adversely affect surrounding development in the area. Therefore, the Project would not cause a significant environmental impact due to a conflict with The Fullerton Plan or FMC, or any other land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.
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4.12 MINERAL RESOURCES
ENVIRONMENTAL IMPACTS
Potentially
Significant
Issues
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
12. MINERAL RESOURCES. Would the project:
a) Result in the loss of availability of a known mineral resource that would be of value to the region and the
residents of the State?
X
b) Result in the loss of availability of a locally- important mineral resource recovery site delineated on a local
general plan, specific plan, or other land use plan?
X
a) Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the State?
No Impact. The Surface Mining and Reclamation Act of 1975 ( SMARA) requires the classification of land into mineral resource zones ( MRZs) according to the known or inferred mineral potential of the area. The Fullerton Plan states that the City does not contain any areas designated as MRZs. 62 The Project proposes the demolition of the existing Cedarwoods Business Park and the construction and operation of a warehouse/ distribution facility, which would not establish any use associated with mineral resource extraction. Therefore, the Project would not result in the loss of known mineral resources that would be of value to the region and the residents of the State, and no impact would occur.
b) Result in the loss of availability of a locally- important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan? No Impact. The project site is not identified as a locally important mineral resource recovery site in any local general plan, specific plan, or other land use plan. The proposed Project would not result in the loss of availability of a locally important mineral resource recovery site. The proposed project site is currently urbanized, and no resource recovery sites exist. Therefore, the proposed Project would not result in a loss of availability of known mineral resources, and no impact would occur.
62 City of Fullerton. (1997). General Plan. Retrieved from:
https:// www.cityoffullerton. com/ home/ showpublisheddocument/ 1214/ 637436205717830000. Accessed July 9, 2025.
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4.13 NOISE
ENVIRONMENTAL IMPACTS
Potentially
Significant
Issues
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
13. NOISE. Would the project result in:
a) Generation of a substantial temporary or permanent
increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?
X
b) Generation of excessive groundborne vibration or
groundborne noise levels?
X
c) 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 two miles of apublic airport or public use airport, would the project expose people
residing or working in the project area to excessive noise levels?
X
The noise modeling is included in Appendix I: Noise and Vibration Data, and the results are summarized below.
Background
The analysis describes sound in terms of amplitude ( loudness) and frequency ( pitch). The standard unit of sound amplitude measurement is the decibel ( dB). The decibel scale is a logarithmic scale that describes the physical intensity of the pressure vibrations that make up any sound. The pitch of the sound is in relation to the frequency of the pressure vibration. Since the human ear is not equally sensitive to a given sound level at all frequencies, the A-weighted decibel scale (dBA) relates noise to human sensitivity. The A-weighted decibel scale provides this compensation by discriminating against frequencies in a manner approximating the sensitivity of the human ear.
Noise, on the other hand, is unwanted sound. A typical noise environment consists of a base of steady ambient noise that is the sum of many distant and indistinguishable noise sources. Superimposed on this background noise is the sound from individual local sources. These can vary from an occasional aircraft or train passing by to virtually continuous noise from traffic on a major highway.
Several rating scales analyze the adverse effects of community noise on people. Since environmental noise fluctuates over time, these scales consider that the effect of noise on people is largely dependent on the total acoustical energy content of the noise as well as the time of day when the noise occurs. For example, the equivalent continuous sound level ( Leq) is the acoustic energy content of noise for a stated period; therefore, the Leq of a time- varying noise and that of a steady noise are the same if they deliver the same acoustic energy to the ear during exposure. The Day- Night Sound level (Ldn ) is a 24-hour average Leq with a 10 dBA “ weighting” added to noise during the hours of 10:00 PM to 7:00 AM to account for noise AOO
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sensitivity in the nighttime. The Community Noise Equivalent Level (CNEL) is a 24-hour average Leq with a 10 dBA weighting added to noise during the hours of 10:00 PM to 7:00 AM and an additional 5-dBA weighting during the hours of 7:00 PM to 10:00 PM to account for noise sensitivity in the evening and nighttime.
Existing Setting
The project site is located within an urban environment, surrounded by commercial and industrial uses.
The Project vicinity is impacted by various noise sources. Mobile noise sources, especially cars and trucks traveling along Orangethorpe Avenue and South State College Boulevard, are the most common and significant sources of noise in the Project vicinity. The primary sources of stationary noise near the project site are associated with the commercial and industrial uses and include parking lot activity, mechanical equipment ( e.g., heating, ventilation, and air conditioning [ HVAC] units), idling vehicles, truck deliveries, pedestrians, car radios and music playing, and landscaping equipment. The noise associated with these sources may represent a single- event noise occurrence or short-term noise.
Noise Measurements
To quantify existing ambient noise levels in the Project vicinity, Kimley- Horn conducted three short-term 10-minute) measurements on July 15, 2025; see Appendix I: Noise Data for additional details regarding how the ambient noise measurements were taken. The noise measurement sites were selected to be representative of the existing ambient noise levels at the noise-sensitive uses in the vicinity of the project site. The 10-minute daytime measurements were taken between 8:41 AM and 9:28 AM Measurements of Leq are considered representative of the noise levels throughout the day. The average noise levels measured at each location are identified in Table 24: Existing Noise Measurement Locations and Measurements and shown on Figure 11: Noise Monitoring Locations Map.
Table 24: Existing Noise Measurement Locations and Measurements Site Location Measurement Period Duration
Daytime Average
dBA Leq)
ST- 1
Adjacent to 823 Lark Avenue, along South
Placentia Avenue 8:41 AM - 8:51 AM 10 minutes 73.1
ST- 2 Adjacent to Interface Rehab 8:56 AM - 9:06 AM 10 minutes 71.5 ST- 3 Adjacent to Doggi Dogi Pet Spa 9:18 AM - 9:28 AM 10 minutes 61.3 ST = short-term noise measurement
Source: Noise measurements taken by Kimley-Horn and Associates, Inc., July 15, 2025. See Appendix I for the noise measurement results.
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Not to scale.
Source:
Cedarwoods Fullerton Project
Figure 11: Noise Measurement Locations Map
Source: 2025Source: Nearmaps, Nearmaps, 2025
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Cedarwoods Fullerton Project
Initial Study/ Mitigated Negative Declaration
Sensitive Receptors
Noise exposure standards and guidelines for various types of land uses reflect the varying noise sensitivities associated with each of these uses. FMC Section 15.90.030, Noise Standards, defines a sensitive receptor as any private or public school, hospital, or residential care facility for the elderly, and religious institution. 63
No sensitive receptors in the City of Fullerton have been identified within 1,000 feet of the project site.
The City of Placentia General Plan defines a sensitive receptor as residential uses, schools, libraries, hospitals, churches, and parks. 64 The nearest sensitive receptors to the project site within the City of Placentia are residential uses located approximately 765 feet to the southeast and Interface Rehab located approximately 975 feet to the east. 65
Regulations
State of California Noise Standards
The State of California does not have standards for environmental noise, but the Governor’ s Office of Land Use and Climate Innovation ( Governor’ s Office) has established general plan guidelines for evaluating the compatibility of various land uses as a function of community noise exposure. 66 The purpose of these guidelines is to maintain acceptable noise levels in a community setting for different land use types. The guidelines rank noise land use compatibility in terms of “normally acceptable,” “ conditionally acceptable,” normally unacceptable,” and “ clearly unacceptable” noise levels for various land use types.
In addition, California Government Code Section 65302(f) mandates that the legislative body of each county and city adopt a noise element as part of its comprehensive general plan. The local noise element must recognize the land use compatibility guidelines established by the Governor’ s Office.
California Code of Regulations, Title 24
The CCR, Title 24: Part 1, Building Standards Administrative Code, and Part 2, California Building Code, codify the State’ s noise insulation standards. These noise standards apply to new construction in California for the purpose of interior noise compatibility from exterior noise sources.
The regulations specify that acoustical studies must be prepared when noise-sensitive structures, such as residential buildings, schools, or hospitals, are located near major transportation noise sources, and where such noise sources create an exterior noise level of 65 dBA CNEL or higher. Acoustical studies that accompany building plans must demonstrate that the design of the structure would limit interior noise in habitable rooms to acceptable noise levels. For new residential buildings, schools, and hospitals, the acceptable interior noise limit for new construction is 45 dBA CNEL. 63 The nearest sensitive receptors are located in the City of Placentia. The distance was measured from the project site property line to the nearest sensitive receptor property line on Google Earth Imagery (2025). 64 City of Placentia. ( 2019). City of Placentia General Plan, Noise Element. https:// www.placentia. org/ DocumentCenter/ View/ 8392/ 8- Noise?bidId=. Accessed September 10, 2025.
65 The nearest sensitive receptors are located in the City of Placentia. The distance was measured from the project site property line to the nearest sensitive receptor property line on Google Earth Imagery ( 2025). 66 State of California Governor’s Office of Planning and Research. (2017). General Plan Guidelines, Appendix D: Noise Element Guidelines, page 374. Retrieved from: https:// opr.ca.gov/ docs/ OPR_COMPLETE_ 7.31.17.pdf. Accessed September 20, 2025.
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City of Fullerton
The Fullerton Plan
Adopted May 1, 2012, Chapter 7: Noise of The Fullerton Plan (Fullerton Noise Element) provides guidance for the control of noise and establishes goals and policies to protect residents, workers, and visitors from potentially adverse noise impacts. The primary purpose of The Fullerton Plan Noise Element is to preserve an acceptable noise environment for all types of land uses. The Noise Element defers regulation of temporary, point- source noises such as construction activities to the City’ s Municipal Code. The following goals and policies from Noise Element are applicable to the Project.
GOAL 8: Protection from the adverse effects of noise.
P8.3 Consideration of Noise in Land Use Decisions Support projects, programs, policies and regulations which ensure noise-compatible land use planning recognizing the relative importance of noise sources in order of community impact, the local attitudes towards these sources, and the suburban or urban characteristics of the environment, while identifying noise sensitive uses.
P8.4 Noise Reduction Measures Support projects, programs, policies and regulations to control and abate noise generated by stationary sources.
P8.5 Focus Area Planning Support projects, programs, policies and regulations to evaluate ways to ensure noise compatible land use planning as part of community- based planning of Focus Areas.
P8.6 Noise Receptors Support projects, programs, policies and regulations to permit uses where the noise level of the surroundings— after taking into account noise insulation features and other control techniques of the use—is not detrimental to the use.
P8.7 Noise Generators Support projects, programs, policies and regulations to permit uses and/ or activities where the noise generated by the use and/ or activity is not detrimental or otherwise a nuisance to the surroundings.
The Fullerton Noise Element identifies land use guidelines to reduce future noise and land use incompatibilities. The noise and land use compatibility criteria is provided in Table 25: Land Use Compatibility for Community Noise Environments.
Table 25: Land Use Compatibility for Community Noise Environments Land Use Category
Community Noise Exposure ( CNEL)
Normally
Acceptable
Conditionally
Acceptable
Normally
Unacceptable
Clearly
Unacceptable
Residential- Low Density, Single- Family,
Duplex, Mobile Homes 50 - 60 55 - 70 70 - 75 75 - 85
Residential – Multiple Family 50 - 65 60 - 70 70 - 75 70 - 85 Transient Lodging – Motel, Hotels 50 - 65 60 - 70 70 - 80 80 - 85 Schools, Libraries, Churches, Hospitals,
Nursing Homes 50 - 70 60 - 70 70 - 80 80 - 85
Auditoriums, Concert Halls,
Amphitheaters NA 50 - 70 NA 65 - 85
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Table 25: Land Use Compatibility for Community Noise Environments Land Use Category
Community Noise Exposure ( CNEL)
Normally
Acceptable
Conditionally
Acceptable
Normally
Unacceptable
Clearly
Unacceptable
Sports Arenas, Outdoor Spectator
Sports NA 50 -75 NA 70 - 85
Playgrounds, Neighborhood Parks 50 - 70 NA 67.5 – 77.5 72.5 - 85 Golf Courses, Riding Stables, Water
Recreation, Cemeteries 50 - 70 NA 70 - 80 80 - 85
Office Buildings, Business Commercial
and Professional 50 - 70 67.5 – 77.5 75 - 85 NA
Industrial, Manufacturing, Utilities,
Agriculture 50 - 75 70 - 80 75 - 85 NA
CNEL = community noise equivalent level; NA = not applicable Normally Acceptable: Specified land use is satisfactory, based upon the assumption that any buildings involved are of normal conventional construction, without any special noise insulation requirements.
Conditionally Acceptable: New construction or development should be undertaken only after a detailed analysis of the noise reduction requirements is made and needed noise insulation features have been included in the design. Conventional construction, but with closed windows and fresh air supply systems or air conditioning, will normally suffice.
Normally Unacceptable: New construction or development should be discouraged. If new construction or development does proceed, a detailed analysis of the noise reduction requirements must be made and needed noise insulation features must be included in the design.
Clearly Unacceptable: New construction or development should generally not be undertaken.
Source: Office of Planning and Research, California. (2017). General Plan Guidelines; City of Fullerton. (2012). City of Fullerton General Plan, E:
Tables and Exhibits; and City of Placentia. ( 2019). City of Placentia General Plan, Chapter 8: Noise Element.
City of Fullerton Municipal Code
The following sections of the FMC are applicable to the proposed Project.
Section 15.40.080 Industrial Environmental Controls. Vibration from any machine, operation, or process that can cause noticeable displacement as measured at the property line of the parcel on which the use is located is prohibited.
Section 15.90.030 Noise Standards.
A. The following interior and exterior noise standard presented in Table 26: City of Fullerton Noise Standards apply to the Residential Noise Zone. The City does not specify noise level limits for commercial or industrial zones.
Table 26: City of Fullerton Noise Standards
Noise Area
Allowable Noise Level (dBA Leq)
7:00 AM to 10:00 PM 10:00 PM to 7:00 AM
Interior 55 45
Exterior 55 50
Source: City of Fullerton. ( N.D.) Fullerton Municipal Code Section 15.90.030: Noise Standards.
B. A sensitive use is defined as any private or public school, hospital, or residential care facility for the elderly, and religious institution. It is prohibited to create any noise that causes the noise level at any sensitive use, while the sensitive use is in operation to exceed the noise limits specified for the Residential Noise Zone, notwithstanding the sensitive use may be located outside the Residential Noise Zone.
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C. Noise that is classified as being continuous, reoccurring, predictable, or whose operation of noisegenerating capability can be stopped or started at a specified time, or exceeds the following is prohibited:
The noise standard for a cumulative period of more than 30 minutes in any hour; The noise standard plus five dBA for a cumulative period of more than 15 minutes but less than 30 minutes in any hour;
The noise standard plus 10 dBA for a cumulative period of more than five minutes but less than 15 minutes in any hour;
The noise standard plus 15 dBA for a cumulative period of more than one minute but less than five minutes in any hour; and
The noise standard plus 20 dBA for a cumulative period of less than one minute in an hour.
D. If the ambient noise level exceeds any of the five noise limit categories listed in Subsection C, the cumulative period applicable to the category shall be increased to reflect the ambient noise level.
Section 15.90.040 Actives Exempt from Standards. Noise from vehicular traffic on public streets is exempt from the noise level standards specified in this chapter.
Section 15.90.050 Activities with Special Provisions. The noise sources associated with construction, repair, remodeling, or grading of property is exempt from the noise levels standards specific by this chapter between the hours of 7:00 AM to 8:00 PM on any day except Sunday or a City-recognized holiday.
Air conditioning, refrigeration, and pool equipment must be certified within the noise limits of the Code.
City of Placentia
Although the project site is located in the City of Fullerton, the nearest sensitive receptors are located in the City of Placentia. As such, the City of Placentia noise goals, policies, and standards are included below.
City of Placentia General Plan
Chapter 8: Noise Element of the City of Placentia General Plan (Placentia Noise Element) identifies goals and policies to protect workers, residents, and visitors from potentially adverse noise impacts.
GOAL N - 1 Reduce noise impacts from transportation noise sources.
Policy N - 2.1 Land use planning decisions should be guided by the “ normally acceptable” and conditionally acceptable” community noise exposures, as established by the Office of Planning and Research and shown on Table 5 (refer to Table 25, above).
Policy N - 2.2 Require noise-reduction techniques and mitigation measures in site planning, architectural design, and construction where new projects do not meet the land use compatibility standards in Table 5 (refer to Table 25, above).
Policy N - 2.3 Discourage and, if necessary, prohibit the exposure of noise sensitive land uses to noisy environments. Incorporate noise reduction features during site planning to mitigate anticipated noise impacts on affected noise-sensitive land uses.
Policy N - 2.5 Require proposed development and building projects to demonstrate compliance with the Noise Element and Noise Ordinance prior to project approval. Inform building permit applicants of the relevant sections of the Noise Element and Ordinance.
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GOAL N - 3 Minimize noise spillover from commercial uses into nearby residential neighborhoods.
Policy N - 3.1 Require adherence to City and State exterior noise requirements, specifying exterior and interior noise levels.
Policy N - 3.2 Use increased setbacks where necessary to ensure noise from new development does not impact adjoining residentially used or zoned property.
Policy N - 3.3 Require that automobile and truck access to commercial properties located adjacent to residential parcels be located at the maximum practical distance from the residential parcel.
Policy N - 3.4 Truck deliveries within the City to commercial and industrial properties abutting residential uses shall fully comply with the City’ s Noise Ordinance.
Policy N - 3.5 Limit delivery hours for commercial and industrial uses with loading areas or docks fronting, siding, bordering, or gaining access on driveways adjacent to noise- sensitive uses.
Policy N - 3.6 Require adherence to City and State building codes that specify indoor noise levels.
Policy N - 3.7 Incorporate noise considerations into the site plan review process, particularly with regard to parking and loading areas, ingress/ egress points and refuse collections areas.
GOAL N - 5 Develop measures to control objectionable noise impacts.
Policy N - 5.3 Where possible, resolve existing and potential conflicts between various noise sources and other human activities.
Policy N - 5.4 Require sound attenuation devices on construction equipment.
Policy N - 5.5 Encourage additional sound attenuation measures to reduce noise impacts to sensitive uses.
Policy N - 5.6 Continue to enforce and ensure agency coordination of noise abatement and control measures, particularly within residential neighborhoods and around noise sensitive land uses.
Policy N - 5.7 Require construction activity to comply with City Noise Ordinance. Ensure adequate noise control measures at all construction sites through good sound attenuation practices.
The Placentia Noise Element identifies land use guidelines to reduce future noise and land use incompatibilities. The noise and land use compatibility criteria is provided in Table 25, above.
City of Placentia Municipal Code
The following sections of the City of Placentia Municipal Code are applicable to the proposed Project.
Section 23.76.050 Exterior Noise Standards
A. The noise standard presented in Table 27: City of Placentia Noise Standards apply to property within the designated noise zone.
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Table 27: City of Placentia Noise Standards
Noise Zone Noise Level dB(A) Time Period
1 – All Residential Property
55 7:00 AM – 10:00 PM
50 10:00 PM – 7:00 AM
2 – All Commercial Property 65 Anytime
3 – All Industrial Property 70 Anytime
Source: City of Placentia. (N.D.) City of Placentia Municipal Code, Section 23.76.050: Exterior Noise Standards.
B. The noise levels shown in Table 27 shall be reduced by 5 dB(A) if the offensive noise consists entirely of impact noise, simple tone noise, speech, music, or any combination thereof.
Noise that exceeds the following measured at any residential, commercia, or industrial property is prohibited:
The noise standard for a cumulative period of more than 30 minutes in any hour; The noise standard plus five dBA for a cumulative period of more than 15 minutes but less than 30 minutes in any hour;
The noise standard plus 10 dBA for a cumulative period of more than five minutes but less than 15 minutes in any hour;
The noise standard plus 15 dBA for a cumulative period of more than one minute but less than five minutes in any hour; and
The noise standard plus 20 dBA for a cumulative period of less than one minute in an hour.
C. If the ambient noise level exceeds the first four categories, then the cumulative period for the said category shall be increased to reflect the ambient noise level. If the ambient noise level exceeds the fifth category, then the maximum allowable noise level under said category shall be increased to reflect the maximum ambient noise level.
D. If the noise source and the affected property are within different noise zones, then the noise standard applicable to the affected property shall apply.
Section 23.81.170 Grading, Construction, and Maintenance of Real Property All grading and initial construction of any real property is permitted only between the hours of 7:00 AM and 7:00 PM Monday through Friday, and 9:00 AM and 6:00 PM on Saturday. All grading and initial construction of any real property is prohibited at any time on Sunday and federal holidays, unless approved by the chief building official or city engineer upon receipt of evidence that an emergency exists which would constitute a hazard to persons or property.
Thresholds of Significance
Construction
The City of Fullerton and City of Placentia have not established a quantitative construction noise standard.
For purposes of this analysis, the FTA’ s threshold of 80 dBA (8-hour Leq) for residential uses and 85 dBA 8-hour Leq) for commercial uses is used to evaluate construction noise impacts. 67 Because a doubling of 67 Federal Transit Administration. ( 2018). Transit Noise and Vibration Impact Assessment Manual, Table 7-3, Page 179.
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traffic is considered to cause a perceptible noise increase of 3-dBA above existing noise conditions, the significance for the off-site traffic noise is assessed based on a doubling of existing traffic conditions. 68 Operations
The nearest sensitive receptors are located in the City of Placentia and the nearest non-sensitive receptors are located in the City of Fullerton. However, the City has not established stationary noise standards for non-sensitive receptors. Therefore, Project- generated stationary noise levels at sensitive receptors would be subject to the City of Placentia Municipal Code Section 23.76.050, Exterior Noise Standards; refer to Table 27. Because a change in noise levels of at least 5-dBA is required before any noticeable change in community response would be expected, an increase of 5-dBA is typically considered a substantial increase for operations. 69 Therefore, the composite operational noise significance is assessed based on the City of Placentia exterior noise standards and a noise level increase threshold of 5-dBA above existing noise conditions. Because a doubling of traffic is considered to cause a perceptible noise increase of 3- dBA above existing noise conditions, the significance for the off-site traffic noise is assessed based on a doubling of existing traffic conditions. 70
Vibration
The City of Fullerton and City of Placentia have not established a vibration damage standard. For purposes of this analysis, the building vibration threshold from the FTA Transit Noise and Vibration Assessment Manual and the human annoyance vibration threshold from the California Department of Transportation Caltrans) Transportation and Construction Vibration Manual are used as the significance thresholds. The FTA guidance state that reinforced- concrete, steel, or timber buildings can withstand vibration levels up to 0.5 inch-per-second peak particle velocity ( PPV) and not experience vibration damage. The Caltrans guidance identifies the vibration threshold for human annoyance when vibrations are considered annoying by people subjected to continuous vibrations as 0.2 inch-per-second PPV.
Methodology
Construction
Construction noise levels were based on typical noise levels generated by construction equipment published by the FTA and FHWA. Construction noise is assessed in dBA Leq. This unit is appropriate because Leq can be used to describe the noise level from the operation of each piece of equipment separately, and the levels can be combined to represent the noise level from all equipment operating concurrently during a given period.
Construction noise was modeled using the FHWA Roadway Construction Noise Model (RCNM). Reference noise levels are used to estimate operational noise levels at nearby sensitive receptors based on a standard noise attenuation rate of 6 dB per doubling of distance ( line-of-sight method of sound attenuation for point sources of noise). Noise level estimates do not account for the presence of intervening structures or topography, which may reduce noise levels at receptor locations. Therefore, the noise levels presented herein represent a conservative, reasonable worst- case estimate of actual temporary construction noise.
68 California Department of Transportation. ( 2017). Technical Noise Supplement to the Traffic Noise Analysis Protocol 69 Compiled from California Department of Transportation. ( 2017). Technical Noise Supplement to the Traffic Noise Analysis Protocol and Federal Highway Administration. ( 2017). Noise Fundamentals. 70 California Department of Transportation. ( 2017). Technical Noise Supplement to the Traffic Noise Analysis Protocol AOO
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Operations
The analysis of the Project noise environment is based on noise prediction modeling and empirical observations. Reference noise level data are used to estimate the Project operational noise impacts from stationary sources. Noise levels were collected from published sources from similar types of activities and used to estimate noise levels expected with the Project’ s stationary sources. The reference noise levels are used to represent a worst-case noise environment as noise level from stationary sources can vary throughout the day.
Vibration
Ground- borne vibration levels associated with construction activities for the Project were evaluated utilizing typical ground- borne vibration levels associated with construction equipment, obtained from FTA published data for construction equipment. Potential ground- borne vibration impacts related to building/ structure damage and interference with existing sensitive operations were evaluated, considering the distance from construction activities to nearby land uses and typically applied criteria for structural damage.
Construction vibration levels were calculated using the following formula:
PPVequip = PPVref x (25/ D)1.5
where: PPVequip = the peak particle velocity in inch-per-second of the equipment adjusted for the distance PPVref = the reference vibration level in inch-per-second from Table 7-4 of the Federal Transit Administration, Transit Noise and Vibration Impact Assessment Manual, 2018.
D = the distance from the equipment to the receiver
Impact Analysis
a) Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?
Less Than Significant Impact: On-Site Construction Noise. Construction noise typically occurs intermittently and varies depending on the nature or phase of construction ( e.g., land clearing, grading, excavation, paving). Noise generated by construction equipment, including earth movers, material handlers, and portable generators, can reach high levels. During construction, exterior noise levels could affect the commercial and industrial receptors near the construction site.
Project construction would occur over a 13-month period. Project construction activities would include demolition, site preparation, grading, infrastructure improvements, building construction, paving, and architectural coating applications. 71
Such activities may require graders, and tractors/ loaders/ backhoes during site preparation; graders, dozers, and tractors/ loaders/ backhoes during grading; cranes, forklifts, and tractors/ loaders/ backhoes during building construction; pavers, rollers, mixers, and tractors/ loaders/ backhoes during paving; and air compressors during architectural coating applications. Typical 71 Although not proposed, the modeled Project construction equipment conservatively accounts for the full-width grind and overlay improvements along Cypress Way.
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operating cycles for these types of construction equipment may involve 1 or 2 minutes of full power operation followed by 3 to 4 minutes at lower power settings. Other primary sources of acoustical disturbance would be random incidents, which would last less than one minute (such as dropping large pieces of equipment or the hydraulic movement of machinery lifts).
The site preparation and grading phases of Project construction tend to be the shortest in duration and create the highest construction noise levels due to the operation of heavy equipment required to complete these activities. It should be noted that only a limited amount of equipment can operate near a given location at a particular time. Typical noise levels associated with individual construction equipment are listed in Table 28: Typical Construction Noise Levels. It should be noted that the noise level values shown in Table 28 are for the equipment when operating at full power 50 feet from the sensitive receptor, without taking into account any intervening structures or topography that may reduce noise levels.
Table 28: Typical Construction Noise Levels
Equipment Typical Noise Level (dBA) at 50 feet from Source Air Compressor 80
Backhoe 80
Compactor 82
Concrete Mixer 85
Concrete Pump 82
Concrete Vibrator 76
Crane, Mobile 83
Dozer 85
Generator 82
Grader 85
Impact Wrench 85
Jack Hammer 88
Loader 80
Paver 85
Pneumatic Tool 85
Pump 77
Roller 85
Saw 76
Scraper 85
Shovel 82
Truck 84
Source: Federal Transit Administration. (2018). Transit Noise and Vibration Impact Assessment Manual.
Daytime construction noise is not typically a concern for human health and is a common occurrence within the urban environment. The nearest non- sensitive receptors to the project site are commercial uses located adjacent to the west, within the City of Fullerton. Pursuant to the City’ s Municipal Code Section 15.90.050, construction noise is permitted between the hours of 7:00 AM and 8:00 PM any day, except for Sundays and City-recognized holidays. The nearest AO
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sensitive receptors to the project site are residential uses located approximately 765 feet to the southeast and Interface Rehab located approximately 975 feet to the east, within the City of Placentia. The City of Placentia Municipal Code Section 23.81.170 permits grading and construction between the hours of 7:00 AM and 7:00 PM Monday through Friday, and 9:00 AM and 6:00 PM on Saturday. However, the Project does not propose construction in the City of Placentia and would therefore not be subject to the allowable hours of construction. The City for Fullerton and City of Placentia have not established quantitative construction noise standards. As such, this analysis conservatively uses the FTA’ s threshold of 80 dBA ( 8-hour Leq) for residential uses and 85 dBA (8-hour Leq) for commercial uses. 72
The FHWA’ s RCNM was used to calculate noise levels at the nearest commercial receptor and sensitive receptors. Noise levels at other receptors surrounding the project site would be located further away and would experience lower construction noise levels than the modeled receptors.
Noise levels were based on the equipment used, distance to the nearest receptor, and acoustical use factor for equipment. When calculating construction noise, the anticipated construction equipment is assumed to operate at staggered distances throughout the construction area. This methodology accounts for equipment operating throughout the construction area and not at a fixed location for extended periods of time. 73 See Appendix I for more information regarding the construction assumptions used in this analysis.
The noise levels calculated in Table 29: Project Construction Noise Levels summarizes the exterior construction noise attributable to the Project without accounting for attenuation from existing physical barriers. As indicated on the table, maximum construction noise level would be 84.0 dBA Leq at the nearest receptor ( commercial), 65.8 dBA Leq at the nearest residential use, and 63.6 dBA Leq at Interface Rehab. As such, the Project would not exceed the FTA’ s construction noise thresholds for residential or commercial uses. Additionally, The Project would comply with City’ s allowable hours of construction, which are required in recognition that construction activities undertaken during daytime hours are a typical part of living in an urban environment and do not cause a significant impact. Therefore, impacts in regard to on-site construction noise would be less than significant.
72 Federal Transit Administration. (2018). Transit Noise and Vibration Impact Assessment Manual, Table 7-3, Page 179. 73 Ibid.
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Table 29: Project Construction Noise Levels
Construction Phase Receptor Direction
Project
Construction
Noise Level
dBA Leq) 1
Noise
Threshold
dBA Leq) 2 Exceeded?
Individual Construction Phase
Demolition3
Commercial West 80.5 85 No
Residential Southeast 61.3 80 No
Interface Rehab East 59.0 85 No
Site Preparation3
Commercial West 79.4 85 No
Residential Southeast 61.8 80 No
Interface Rehab East 59.6 85 No
Grading3
Commercial West 80.0 85 No
Residential Southeast 62.0 80 No
Interface Rehab East 59.7 85 No
Infrastructure
Improvements3
Commercial West 80.5 85 No
Residential Southeast 60.5 80 No
Interface Rehab East 58.1 85 No
Building
Construction3
Commercial West 81.4 85 No
Residential Southeast 63.8 80 No
Interface Rehab East 61.6 85 No
Paving3
Commercial West 80.3 85 No
Residential Southeast 61.1 80 No
Interface Rehab East 58.8 85 No
Architectural
Coating3
Commercial East 70.8 85 No
Residential West 49.2 80 No
Interface Rehab Southeast 46.8 85 No
Off-site
Improvements4
Commercial South5 83.3 85 No
Residential East 54.8 80 No
Interface Rehab Southeast 54.5 85 No
Overlapping Construction Phase
Infrastructure
Improvements +
Building Construction
Commercial West 84.0 85 No
Residential Southeast 65.5 80 No
Interface Rehab East 63.2 85 No
Building Construction
Paving
Commercial West 84.0 85 No
Residential Southeast 65.7 80 No
Interface Rehab East 63.4 85 No
1 The equipment is assumed to operate at staggered distances throughout the construction area. 2 Thresholds are from the FTA Transit Noise and Vibration Impact Assessment Manual (2018). 3 The construction area is considered to be the project site. 4 Although not proposed, the off-site improvements conservatively account for the full-width grind and overlay improvements along Cypress Way.
5 The nearest commercial receptors to the off-site Cypress Way grind and overlay improvements are located adjacent to the south of Cypress Way.
Source: Federal Highway Administration. ( 2006). Roadway Construction Noise Model. Refer to Appendix I for noise modeling results.
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Less Than Significant Impact: Off-Site Mobile Construction Noise. In addition to on-site construction noise, the Project would generate mobile- source noise from haul and delivery trucks and construction workers traveling to and from the project site during Project construction using Orangethorpe Avenue and South State College Boulevard. Project- generated trips would be temporary and cease with the end of construction.
Because of the logarithmic nature of noise levels, a doubling of the traffic volumes would result in a noise level increase of 3 dBA, which is considered to be readily noticeable. 74 According to annual average daily traffic (AADT) data provided by Replica HQ, Orangethorpe Avenue has an AADT of 12,869 and South State College Boulevard has an AADT of 20,553. 75 According to modeling assumptions in Section 4.3: Air Quality, the construction phases with the highest assumed number of trucks would be demolition, when it is assumed, there would be up to 102 daily trips accessing the project site. As Project construction would not double the existing traffic volumes on Orangethorpe Avenue or South State College Boulevard, the proposed Project would not generate enough traffic to result in a noticeable 3-dBA increase in ambient noise levels.
Large trucks would deliver building materials, remove waste materials, and depending on the final earthwork quantities, import or export soil to and from off-site locations. These large trucks would generate noise from the engine acceleration, braking, and loading and unloading. The State establishes noise limits for vehicles licensed to operate on public roads using a pass- by test procedure. Pass- by noise refers to the noise level produced by an individual vehicle as it travels past a fixed location. The pass-by procedure measures the total noise generated by a moving vehicle with a microphone. When the vehicle reaches the microphone, the vehicle is at full throttle acceleration at an engine speed calculated for its displacement. The State pass-by standard for heavy trucks is consistent with the federal limit of 80 dB. The State pass-by standard for light trucks and passenger cars ( less than 4.5 tons gross vehicle rating) is also 80 dB at 15 meters from the centerline. According to the FHWA, dump trucks typically generate noise levels of 76 dBA and flatbed trucks typically generate noise levels of 74 dBA, at a distance of 50 feet from the truck. 76 As such, noise from truck trips associated with the proposed project would not exceed FTA threshold levels of 90 dBA ( one-hour Leq) or 80 dBA ( eight-hour Leq). Impacts associated with Project- generated mobile traffic would be less than significant.
Less Than Significant Impact: On -Site Operational Noise. The major on-site noise sources associated with the Project include mechanical equipment ( e.g., HVAC equipment), loading dock activities ( i.e., slow moving trucks on the site, maneuvering and idling trucks, air brakes, back-up alarms, equipment noise), trash and recycling collection, back- up beepers, parking lot activity (i.e., car door slamming, car radios, engine start-up, and car pass- by), and an emergency fire pump.
Operational noise associated with the Project would be similar to existing conditions on-site and at the adjacent uses.
As noted above in the Thresholds of Significance section, the nearest sensitive receptors are located in the City of Placentia and the nearest non-sensitive receptors are located in the City of Fullerton. However, the City of Fullerton has not established stationary noise standards for non74 According to the California Department of Transportation, Technical Noise Supplement to Traffic Noise Analysis Protocol (September 2013), it takes a doubling of traffic to create a noticeable (i.e., 3-dBA) noise increase. 75 ReplicaHQ. (2024). Replica Annual Average Daily Traffic (AADT) Data. https:// www.replicahq.com/aadt. Accessed July 3, 2025. 76 Federal Highway Administration, Roadway Construction Noise Model, 2006.
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sensitive receptors. Therefore, Project- generated stationary noise was not analyzed at the nearest non- sensitive receptors, adjacent to the project site. The following analysis addresses Projectgenerated stationary noise at the nearest sensitive receptors in the City of Placentia.
Mechanical Equipment. Potential stationary noise sources related to long-term Project operations would include mechanical equipment ( e.g., HVAC equipment) located on the roof of the proposed building. It is conservatively assumed the mechanical equipment would be located on the building rooftop nearest the sensitive receptor and would not be screened by architectural features. Mechanical equipment typically generates noise levels of approximately 52 dBA at 50 feet. 77 The nearest sensitive receptors are residential uses located approximately 815 feet to the southeast and Interface Rehab located approximately 1,076 feet to the east of the mechanical equipment. The mechanical equipment noise levels at the nearest residential use would be 27.8 dBA Leq and would not exceed the City of Placentia residential daytime (55 dBA) or nighttime (50 dBA) noise standard. The mechanical equipment noise levels at Interface Rehab would be 25.3 dBA Leq and would not exceed the City of Placentia commercial noise standard ( 65 dBA). Impacts would be less than significant.
Truck and Loading Dock Activities. During loading and unloading activities, noise would be generated by the trucks’ diesel engines, exhaust systems, and brakes during low gear shifting’ braking activities; backing up toward the docks; dropping down the dock ramps; and maneuvering away from the docks. The loading docks would be located on the western side of the proposed warehouse building; refer to Figure 7. Typically, heavy truck and loading dock operations generate a noise level of 64.4 dBA at a distance of 50 feet. 78 The nearest sensitive receptors are Interface Rehab located approximately 1,030 feet to the east and residential uses located approximately 1,273 feet to the southeast of the loading dock area. The loading and unloading noise levels at Interface Rehab would be 38.1 dBA Leq and would not exceed the City of Placentia commercial noise standard ( 65 dBA). The loading and unloading noise levels at the nearest residential use would be 36.3 dBA Leq and would not exceed the City of Placentia residential daytime ( 55 dBA) or nighttime ( 50 dBA) noise standard. Impacts would be less than significant.
Back- up Alarms. Medium and heavy- duty trucks reversing into loading docks would produce noise from back- up alarms ( also known as back- up beepers). Back- up beepers produce a typical volume of 97 dBA at 3.28 feet from the source. 79According to Table 1: Trip Generation in Appendix L, the Project would generate three truck trips to the project site during peak hours. Therefore, this analysis conservatively assumes the three trucks would simultaneously utilize back- up alarms within the loading dock area. The nearest sensitive receptors are Interface Rehab located approximately 1,030 feet to the east and residential uses located approximately 1,273 feet to the southeast of the loading dock area. The back-up beeper noise levels at Interface Rehab would be 25.3 dBA Leq and would not exceed the City of Placentia commercial noise standard ( 65 dBA). The back- up beeper noise levels at the nearest 77 Elliott H. Berger, Rick Neitzel, and Cynthia A. Kladden. ( 2010). Noise Navigator Sound Level Database with Over 1700 Measurement Values. 78 Loading dock reference noise level measurements conducted by Kimley-Horn on December 18, 2018. 79 David Holzman. ( 2011). Vehicle Motion Alarms: Necessity, Noise Pollution, or Both? https:// www.ncbi.nlm.nih.gov/ pmc/ articles/ PMC3018517/. Accessed September 10, 2025.
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residential use would be 23.5 dBA Leq and would not exceed the City of Placentia residential daytime (55 dBA) or nighttime (50 dBA) noise standard. Impacts would be less than significant.
Parking. Traffic associated with parking lots is typically not of sufficient volume to exceed community noise standards, which are based on a time-averaged scale such as the Leq or CNEL scale. The instantaneous maximum sound levels generated by a car door slamming, engine starting up, and car pass-bys range from 53 to 61 dBA. 80 Conversations in parking areas may also be an annoyance to adjacent sensitive receptors. Sound levels of speech typically range from 33 dBA at 50 feet for normal speech to 50 dBA at 50 feet for very loud speech. 81 It should be noted that parking lot noises are instantaneous noise levels compared to noise standards in the hourly Leq or 24-hour CNEL metrics, which are averaged over the entire duration of a time period. As a result, actual noise levels over time resulting from parking lot activities would be far lower than the reference levels identified above.
For the purpose of providing a conservative, quantitative estimate of the noise levels that would be generated from the vehicles entering and exiting the parking lot, the methodology recommended by FTA for the general assessment of stationary transit noise sources is used.
Using the methodology, the Project’ s peak hourly noise level that would be generated by the on-site parking levels was estimated using the following FTA equation for a parking lot:
Leq(h) = SELref + 10 log (NA/ 1,000) – 35.6
Where:
Leq(h) = hourly Leq noise level at 50 feet
SELref = reference noise level for stationary noise source represented in sound exposure level (SEL) at 50 feet
NA = number of automobiles per hour
35.6 is a constant in the formula, calculated as 10 times the logarithm of the number of seconds in an hour.
Based on Table 1 in Appendix L, the Project would generate approximately 212 daily trips, with 40 peak hour trips. Using the FTA’ s reference noise level of 92 dBA SEL82 at 50 feet from the noise source, the Project’ s highest peak hour vehicle trips would generate noise levels of approximately 42.4 dBA Leq at 50 feet from the parking lot. The nearest sensitive receptors are Interface Rehab located approximately 1,050 feet to the east and residential uses located approximately 1,058 feet to the southwest from the parking area. The parking noise levels at Interface Rehab would be 15.9 dBA Leq and would not exceed the City of Placentia commercial noise standard ( 65 dBA). The parking noise levels at the nearest residential use would be 16.0 dBA Leq and would not exceed the City of Placentia residential daytime (55 dBA) or nighttime 50 dBA) noise standard.
80 Kariel, H. G. (1991). Noise in Rural Recreational Environments, Canadian Acoustics 19(5), 3-10. 81 Elliott H. Berger, Rick Neitzel, and Cynthia A. Kladden. (2015). Noise Navigator Sound Level Database with Over 1700 Measurement Values. 82 Federal Transit Administration. ( 2018). Transit Noise and Vibration Impact Assessment Manual.
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Emergency Fire Pump. The Project would include an emergency fire pump located in an external pump house building located along the western project boundary. The emergency fire pump equipment would be entirely enclosed within the building and would not result in any measurable noise levels within the Project vicinity. Impacts would be less than significant.
Composite Noise Levels. An evaluation of the Project’ s composite noise levels, including all on-site Project- related noise sources plus the existing ambient noise level, was conducted to identify the potential maximum Project- related noise level increase that may occur at the nearest sensitive receptors. On-site noise-generating sources associated with the Project would include mechanical equipment, loading dock activities, truck back-up alarms, and parking activities. It is conservatively assumed that operational noise sources at the project site would occur in a constant, simultaneous manner. However, noise sources would occur intermittently throughout the day ( except for the HVAC which may operate in a steady- state manner). This analysis considers an exceedance of the noise standard at a sensitive receptor and a 5-dBA increase in noise levels over the existing ambient noise environment as the significance criterion. Table 30: Composite Noise Levels presents the composite noise level from the on-site Project- related noise sources.
Table 30: Composite Noise Levels
Noise Source
Noise
Level at
Sensitive
Receptor
dBA)
Daytime/
Nighttime
Noise
Standard
dBA) 1
Ambient +
Project
Noise Level
dBA) 2
Incremental
Increase
dBA)
Incremental
Increase
Threshold3 Significant? 4
Residential Uses
Mechanical
Equipment 27.8 55/ 50 - - - No
Truck Loading 36.3 55/ 50 - - - No
Back-up Beeper 23.5 55/ 50 - - - No
Parking 15.9 55/ 50 - - - No
Combined5 37.1 55/ 50 73.1 0.0 5.0 No
Interface Rehab
Mechanical
Equipment 25.3 65/ 65 - - - No
Truck Loading 38.1 65/ 65 - - - No
Back-up Beeper 25.3 65/ 65 - - - No
Parking 16.0 65/ 65 - - - No
Combined5 38.6 65/ 65 71.5 0.0 5.0 No
1 As the nearest sensitive receptors are located in the City of Placentia, the noise standards from the City of Placentia Municipal Code, Section 23.76.050: Exterior Noise Standards, are presented in this table. 2 Ambient noise measurements were taken by Kimley-Horn and Associates on July 15, 2025, and are shown in Table 1. ST-1 (73.1 dBA) is representative of the residential uses and ST-2 (71.5 dBA) is representative of Interface Rehab. 3 This analysis considers an exceedance of the noise standard at a sensitive receptor and a 5-dBA increase in noise levels over the existing ambient noise environment as the significance criterion. 4 An exceedance of the noise standard by the individual operational noise sources is considered to be significant. An exceedance of the noise standard and 5-dBA incremental noise increase by the combined operational noise sources is considered to be significant. 5 Noise levels for all operational sources were logarithmically added together and conservatively assumed to operate in a simultaneous, constant manner.
Refer to Appendix I for noise modeling results.
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As shown in Table 30, project-generated composite noise levels would not exceed either the City of Placentia noise standards or the 5-dBA ambient increase threshold at the nearest sensitive receptors. Impacts would be less than significant.
Less Than Significant Impact: Mobile Traffic Noise. Project implementation would result in an increase in traffic trips along roadways near the project site. In general, a 3-dBA increase in traffic noise is barely perceptible to people, while a 5-dBA increase is readily noticeable. Traffic volumes on area roadways would have to approximately double for the resulting traffic noise levels to generate a barely perceptible 3-dBA increase. 83 According to the AADT data provided by Replica HQ, Orangethorpe Avenue has an AADT of 12,869 and South State College Boulevard has an AADT of 20,553. 84 Based on Table 1 in Appendix L, Project implementation would result in a net decrease of 422 total daily trips, which would reduce the existing traffic noise levels along Orangethorpe Avenue and South State College Boulevard. However, this analysis conservatively assumes the Project would generate 212 new daily trips (refer to Table 1 in Appendix L) along roadways within vicinity of the project site. As Project operations would not double the existing traffic volumes on Orangethorpe Avenue or South State College Boulevard, the proposed Project would not generate enough traffic to result in a noticeable 3-dBA increase in ambient noise levels. Impacts associated with Project- generated mobile traffic would be less than significant.
As discussed above, the proposed Project would not generate substantial temporary or permanent increase in ambient noise levels in the vicinity of the Project and a less than significant impact would occur.
b) Generation of excessive groundborne vibration or groundborne noise levels? Less Than Significant with Mitigation Incorporated: Construction Vibration. Increases in groundborne vibration levels attributable to the Project would be primarily associated with shortterm construction- related activities. Project construction would have the potential to result in varying degrees of temporary groundborne vibration, depending on the specific construction equipment used and the operations involved. Ground vibration generated by construction equipment spreads through the ground and diminishes in magnitude as distance from the source increases. The results from vibration can range from no perceptible effects at the lowest vibration levels, to low rumbling sounds and perceptible vibration at moderate levels, to slight damage at the highest levels. Groundborne vibrations from construction activities rarely reach levels that damage structures.
The FTA has published standard vibration velocities for construction equipment operations. The types of construction vibration impacts include human annoyance and building damage. Building damage can be cosmetic or structural. Ordinary buildings that are not particularly fragile would not experience any cosmetic damage ( e.g., plaster cracks) at distances beyond 30 feet. This distance can vary substantially depending on the soil composition and the underground geological layer between the vibration source and the receiver. In addition, not all buildings respond similarly to vibration generated by construction equipment. For example, for a building that is constructed 83 According to the California Department of Transportation, Technical Noise Supplement to Traffic Noise Analysis Protocol (September 2013), it takes a doubling of traffic to create a noticeable ( i.e., 3-dBA) noise increase. 84 ReplicaHQ. ( 2024). Replica Annual Average Daily Traffic (AADT) Data. Retrieved from: https:// www.replicahq.com/ aadt. Accessed July 3, 2025.
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135 Page
to upoflevel vibration a that show guidelines FTA the plaster, no with concrete reinforced with damage. vibration construction any in result not would and safe considered is second per-inch- 5 0. of threshold the above significantly rises vibration construction whenoccurs annoyance Human damagearchitectural FTA the uses evaluation This time. ofperiods extended for perception human inch- 5 0.of buildings timber or steel, concrete, reinforced- at vibrations continuous for criterion with accordance in PPV second per-inch- 2 0.of criterion annoyance human and PPV second perguidance.Caltrans 85 during rollers vibratory and bulldozers, small trucks, loaded bulldozers, large use wouldProject The includes Levels Vibration Equipment Construction Typical 31: Table construction. Project typical for range distance a as well as feet), 25 distance (reference the at levels vibration equipment. construction
Levels Vibration Equipment Construction Typical 31: Table Equipment
second) per-inch- Velocity (Particle Peak 1
feet 765 feet 15 feet 8 Feet 5 Feet 25
001 0. 452 0. 160 1. 348 2. 21 0. Roller Vibratory
001 0. 191 0. 492 0. 995 0. 089 0. Bulldozer Large
000 0. 164 0. 420 0. 850 0. 076 0. Trucks Loaded
000 0. 006 0. 017 0. 034 0. 003 0. BulldozerSmall
1 D)25/ x (PPVref PPVequip = formula: following the using Calculated 5, 1. the of sec in/ in velocity particle peak the PPVequip = where:
Transit Federal the of 4 7-Table from sec in/ in level vibration reference the PPVref = distance; the for adjusted equipment the to equipment the from distance the D = 2018; Manual, Assessment Impact Vibration and NoiseTransit Administration, receiver.
Manual. AssessmentImpact Vibration and NoiseTransit 2018). Administration. ( TransitFederal Source:
boundary. area construction the to up occur to anticipated are activities construction site Onfeet 5 approximately located be would building) commercial e., i. structure (nearest the Therefore, from velocities vibration 31, Table in indicated As line. property site project the of west the to construction Project during used be wouldthat operations equipment construction heavytypical Therefore, activity. of source the from feet 5at PPV second per-inch- 348 2.to 034 0. from range 5 0.of criterion damage structural the exceed would vibration groundborne construction Project required be would 1NOI- MM) Measure (Mitigation building. nearest the at PPV second per-inchbuffer a require would 1NOI- MMlevel. significant than less a to impacts vibration reduce to ensure to buildings commercial existing the to adjacent operation equipment heavy from distance the exceed not would activities construction Project by generated vibration groundborne PPV. second per-inch- 5 0.of criterion damagestructural wouldProject the assumes conservatively analysis this Applicant, the by proposed not Although Cypress along activities overlay and grind widthfull-of consisting improvements site off-include activities Such approval. of condition a as City the by required be improvements such should Way structures nearest the from feet 15 as close as and WayCypress along curb the to upoccur would could rollers vibratory from vibration groundborne distance, this At buildings). commercial e., i. the exceed not would vibration groundborne Therefore, PPV. second per-inch- 452 0. reach
31. Table to refer PPV; second per-inch- 5 0.of criterion damagestructural 85 20. Table Manual, Guidance Vibration Construction and Transportation 2013). Transportation. (ofDepartment California Ow
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Cedarwoods Fullerton Project
Initial Study/ Mitigated Negative Declaration
The nearest sensitive receptor would be located 765 feet to the southeast of the project site property line. As identified in Table 31, vibration velocities from typical heavy construction equipment operations at 765 feet from the source of activity would be less than 0.001 inch-persecond PPV and would not exceed the human annoyance criterion of 0.2 inch-per- second PPV.
Impacts would be less than significant with implementation of MM NOI-1.
Less Than Significant Impact: Operational Vibration. With respect to vibration- generating activities, Project operations would primarily involve truck loading and unloading activities.
According to the FTA’s Transit Noise and Vibration Impact Assessment, trucks such as delivery trucks, refuse collection trucks, and occasional moving trucks rarely create vibration levels that exceed 70 VdB ( equivalent to 0.012 inch-per- second PPV) when they are on roadways. 86 Furthermore, these movements would generally be low-speed ( i.e., less than 15 miles per hour) and would occur over new, smooth surfaces.
For perspective, Caltrans has studied the effects of propagation of vehicle vibration on sensitive land uses and notes that “heavy trucks, and quite frequently buses, generate the highest earthborn vibrations of normal traffic.” Caltrans further notes that the highest traffic-generated vibrations are along freeways and state routes. Their study finds that “ vibrations measured on freeway shoulders ( five meters from the centerline of the nearest lane) have never exceeded 0.08 in/ sec, with the worst combinations of heavy trucks and poor roadway conditions ( while such trucks were moving at freeway speeds). This level coincides with the maximum recommended safe level for ruins and ancient monuments ( and historic buildings)”. 87 Since the truck movements associated with the Project would be at low speed ( not at freeway speeds) and would be over smooth surfaces ( not under poor roadway conditions), Project-related vibration associated with truck activity would not result in excessive groundborne vibrations. In addition, there are no sources of substantial groundborne vibration associated with the Project, such as rail or subways. The Project would not create or cause any vibration impacts due to operations. Impacts would be less than significant.
c) 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 two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? No Impact. The project site is located approximately 5.0 miles to the east of the Fullerton Municipal Airport. The project site is not located within an airport land use plan, nor is it located within two miles of a private or public airport, or within the vicinity of a private airstrip. Therefore, the Project would not expose people working at the project site to excessive airport- or airstrip- related noise levels, and no impact would occur.
86 California Department of Transportation. ( 2013). Transportation and Construction Vibration Guidance Manual, Table 20. 87 California Department of Transportation. ( 2013). Technical Noise Supplement to the Traffic Noise Analysis Protocol (“ TeNS”).
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Mitigation Measures
MM NOI-1 On-Site Construction Vibration Control. The following measure shall be incorporated on all grading and building plans and specifications subject to approval of the City’ s Building and Safety Division prior to issuance of a grading permit:
The developer shall ensure construction equipment will not approach the construction buffer zone adjacent to the commercial building ( i.e., 2443 East Orangethorpe Avenue) along portions of the Project’ s western project site boundary.
The buffer zone shall be tiered based on distances established in Table 31: Typical Construction Equipment Vibration Levels. Loaded trucks and large bulldozers shall not operate within 8 feet of the commercial building, and vibratory rollers shall not operate within 15 feet of the commercial building.
This mitigation measure only applies to on-site construction activities.
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4.14 POPULATION AND HOUSING
ENVIRONMENTAL IMPACTS
Potentially
Significant
Issues
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
14. POPULATION AND HOUSING. Would the project:
a) 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)?
X
b) Displace substantial numbers of existing people or
housing, necessitating the construction of replacement
housing elsewhere?
X
a) 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)?
Less Than Significant Impact. As described above, the project site is designated Industrial ( I) and located within the Southwest Industrial Focus Area. The project site is currently developed and surrounded by existing development. The site does not contain any housing. The Project proposes to remove the existing 85,700 square- feet of industrial and commercial uses and develop a new 110,232 square- foot warehouse/ distribution facility, which would be compatible with the Industrial (I) designation and Southwest Industrial Focus Area, as described in The Fullerton Plan.
Employment opportunities would be provided both during the construction of the Project and once the Project is operational. The number of temporary construction jobs that would be created is unknown. For the purpose of this analysis regarding long-term employment opportunities, the proposed Project would employ approximately 113 employees, based on an employment generation factor of one employee per 979 sf of warehouse use ( 110,232 sf/979 sf = 112.6, rounded up to 113). 88 It is assumed the new jobs could be filled by local residents who already reside in or near the City, as employment- generating uses currently occur on the site. The proposed Project is consistent with the existing Industrial ( I) land use designation and therefore would be within the population projections anticipated and planned for in The Fullerton Plan . Therefore, the Project would not induce substantial unplanned population growth in the area. Additionally, the Project does not include the extension of roads or other infrastructure to unserved areas, which could induce indirect growth. Therefore, the proposed Project would not result in direct or indirect substantial unplanned growth, and a less than significant impact would occur. 88 Natelson Company, Inc. 2001. Employment Density Study Summary Report Prepared for SCAG, Table 6A.
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b) Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
No Impact. The project site does not contain any existing housing, and no housing would be removed to accommodate the Project. Therefore, the proposed Project would not displace existing people or housing, and no impact would occur.
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4.15 PUBLIC SERVICES
ENVIRONMENTAL IMPACTS
Potentially
Significant
Issues
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
15. PUBLIC SERVICES. Would the project:
a) 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 any of the public
services:
i) Fire protection? X
ii) Police protection? X
iii) Schools? X
iv) Parks? X
v) Other public facilities? X
a) 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, theconstruction of whichcouldcause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
i) Fire protection?
Less than Significant Impact. The Fullerton Fire Department provides fire protection and emergency medical response services for the City, inclusive of the project site which is currently developed as a business park. Additionally, Fullerton is part of a mutual aid agreement with all Orange County Fire agencies to improve emergency response efforts. The nearest fire station is Fire Department Station #3, located at 700 South Acacia Avenue, approximately 1.0 mile northwest of the project site. The Fire Department operates a fleet of five Fire Engines, three Reserve Fire Engines, one Mobile EOC Command Trailor, one Reserve Fire Truck, one Utility Task Vehicle, one 2020 BME Type 3 Wildland Engine under OES 1313 ( Office of Emergency Services), and one battalion comprised of one Battalion Chief supervising 24 on-duty Firefighters89 As described above in Section 4.14: Population and Housing, the Project would not result in permanent population growth and would only incrementally increase the demand for fire protection and 89 City of Fullerton, Fire Station Locations & Apparatus, available at: https:// www.cityoffullerton.com/government/ departments/ fire/aboutus/ fire-station-locations- apparatus, accessed July 30, 2025.
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emergency medical services in the area. The proposed facility is estimated to have approximately 113 employees. The forecast employment growth and increased demand for services would not exceed projections and anticipated public service needs identified in The Fullerton Plan.
Additionally, the incremental increase in population as a result of the Project would not require the construction of new or the alteration of existing fire protection facilities to maintain an adequate level of service to the area. Therefore, no physical impacts associated with fire protection services and facilities would occur.
The Fire Prevention Division (Fire Prevention) of the Fire Department serves to protect the citizens of Fullerton from hazards of fire or other dangerous conditions in existing structures and premises, while also providing safety and assistance to firefighters before and during emergency events. Fire Prevention is responsible for promoting public awareness of fire and life safety and enforcing the California Fire Code (CFC), the California Code of Regulations ( CCR), and the California Health and Safety Code. The Fire Department would review and conditionally approve proposed project site plans to ensure fire prevention and suppression measures, fire hydrants and sprinkler systems, emergency access, and other similar requirements are met. The proposed Project would adhere to SC PS-1, which requires compliance with the Fullerton Fire Prevention Ordinance as per FMC Chapter 13, as well as the Fullerton Building Code as per FMC Chapter 14, the California Fire Code, and the CBC. 90
New developments would also be required to pay property taxes that would go toward the City’ s General Fund, which is the Fire Department’ s main source of funding. As previously addressed, compliance with the California Fire Code and Fullerton Building Code and payment of taxes would minimize the Project’ s operational impacts to fire protection services to the greatest extent practicable. Further, compliance with SC PS-1 which requires adherence to the Fullerton Fire Prevention Ordinance, the Fullerton Building Code, the California Fire Code, and the CBC, in regard to design of fire protection facilities, would lessen adverse physical impacts associated with the provision of new or physically altered fire facilities. Therefore, the Project would not cause significant environmental impacts resulting in the need for new or expanded Fire Department facilities, or impair service ratios, response times or other performance objectives for fire services. ii) Police protection?
Less than Significant Impact. The Fullerton Police Department provides police protection services to the City, including the project site. The Police Department headquarters is located at 237 W.
Commonwealth Avenue, approximately 3.2 miles northwest of the project site. The Police Department is responsible for providing public safety services within City boundaries. The Police Department has approximately 180 employees, 125 sworn police officers and 55 civilian employees. 91
Funding for the operation and maintenance of existing police services comes from the City’ s General Fund. Accordingly, applicants are required to pay property taxes that are imposed on new developments to fund police protection services. The project site would be adequately served by 90 City of Fullerton. ( 2024). Municipal Code. https:// codelibrary. amlegal. com/ codes/ fullerton/ latest/ fullerton_ca/ 0-0-0- 22940# JD_ Chapter13. 19. Accessed July 30, 2025.
91 City of Fullerton. (N.d.). Fullerton Police About Us . https:// www.cityoffullerton.com/ government/ departments/ police/ about-fpd, Accessed July 30, 2025.
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existing Police Department facilities, equipment, and personnel such that new facilities would not be required. Although some calls for service are anticipated, the increase in police services would not be significantly impacted due to the construction and operation of the industrial development.
Additionally, development of the site would increase property tax revenues to provide a source of funding to offset any increases in demand for police protection services generated by the Project.
Overall, the proposed Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered Police Department facilities which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for police services and a less than significant impact would occur. iii) Schools?
Less than Significant Impact. The City has two school districts: Fullerton School District and the Fullerton Joint Union High School District. However, the project site is not located within the boundaries of either district. 92 The project is located within the boundaries of the Placentia- Yorba Linda Unified School District. 93 The Placentia- Yorba Linda Unified School District provides educational services for students in kindergarten through 12th grade.
The nearest school to the project site is Commonwealth Elementary School located approximately
0.6 miles north of the project site within the Fullerton School District. Within the Placentia- Yorba Linda Unified School District, the nearest elementary middle school is Melrose Elementary, approximately 0.6 miles to the east, the nearest middle school is Valadez Middle School Academy, approximately 0.8 miles to the east, and the nearest high school is Valencia High School, approximately 1.3 miles to the northeast.
The Project would not create a direct demand for public school services, as the Project proposes non-residential uses that would not directly generate any school-aged children requiring public education. Further, as discussed in Section 4.14: Population and Housing, significant new employment opportunities would not be generated and would not result in an increase in potential new students. Although the Project would not create a direct demand for additional public- school services, the Project would be required to comply with Senate Bill 50 ( Greene Act), which authorizes school districts to impose fees against certain development projects to fund the construction or reconstruction of school facilities. As outlined in SC PS- 2, the Project Applicant would be required to submit evidence that school impact fees have been paid prior to the issuance of building permits.
Overall, Project implementation would not result in substantial adverse physical impacts associated with the provision of new or physically altered school facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives. Additionally, no school facilities exist on the project site and development of the Project would not conflict with existing school structures or require modification of school facilities. Compliance with applicable local and State regulations in addition to SC PS-2 would ensure that Project implementation would not result in substantial adverse physical impacts associated with the provision of new or physically altered school facilities, the 92 City of Fullerton. ( N.D.). Public Schools. https:// www.cityoffullerton. com/ residents/ schools/ public-schools. Accessed July 30, 2025. 93 Placentia-Yorba Linda Unified School District. (2025). Boundary Maps. https:// www.pylusd.org/ apps/ pages/ index.jsp?uREC_ ID=206487& type=d&pREC_ ID=453794. Accessed July 30, 2025.
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construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios for schools and a less than significant impact would occur. iv) Parks?
Less than Significant Impact. Refer to Section 4.16: Recreation. v) Other public facilities?
Less than Significant Impact. The Fullerton Public Library System serves the City with two main branches. The nearest library is the Fullerton Public Library ( Main Branch), located at 353 W.
Commonwealth Avenue, approximately 3.4 miles northwest of the project site. The Hunt Branch is located at 201 S Basque Ave, approximately 5.3 miles northeast of the project site. The Project would develop a warehouse facility that would not directly generate population and would not cause or contribute to a need to construct new or physically alter library facilities. Therefore, Project implementation would not result in a substantial adverse physical impact associated with the provision of new or physically altered library facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives, and a less than significant impact would occur.
Standard Conditions and Requirements
SC PS- 1 The Applicant shall comply with the Fullerton Fire Prevention Ordinance as per Fullerton Municipal Code ( FMC) Chapter 13, Fullerton Building Code as per FMC Chapter 14, the California Fire Code, and the CBC in regard to design of fire facilities.
SC PS-2 Prior to the issuance of building permits, the Applicant shall submit evidence to the City of Fullerton that legally required school impact fees have been paid per the mitigation established by the applicable school district.
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4.16 RECREATION
ENVIRONMENTAL IMPACTS
Potentially
Significant
Issues
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
16. RECREATION
a) 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?
X
b) Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the
environment?
X
a) 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? Or,
b) Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment? Less Than Significant Impact.
According to The Fullerton Plan EIR, there are 640.4 acres of public parks and recreational facilities in the City; refer to Exhibit 5.15-1, Public Parks and Recreational Facilities in The Fullerton Plan. 94 The nearest parks are Chapman Park located at 2515 San Carlos Drive approximately 1.4 miles north of the project site and Byerrum Park located at 501 North Raymond Avenue, approximately
2.2 miles northwest of the project site, both which are north of the project site. 95 The Fullerton Plan includes goals and policies related to parks and recreation. Specifically, The Fullerton Plan establishes a long-term goal to provide 4 acres of useable park area per 1,000 residents. Based on the City’s current population of 143,617 residents, the current parkland demand for the City is 575 acres. 96,97 As previously addressed, the Project would not create a direct demand for park facilities because it would not generate substantial population growth requiring the need for new or physically altered park facilities. The Project proposes to demolish an existing business park and construct a new warehouse facility. This Initial Study assumes that the facility could employ approximately 113 employees. It is anticipated that many of these positions would be filled by local residents or residents residing near the City and thus would not generate substantial population growth that would increase the use of these parks or any existing 94 City of Fullerton. (2012). The Fullerton Plan - Final Program EIR https:// www.cityoffullerton. com/ home/ showpublisheddocument/ 3696/ 637470826641900000. Accessed August 8, 2025. 95 City of Fullerton. (2008). Parks. https:// www.cityoffullerton.com/ government/ departments/ parks-recreation/ parks-trails-and-fields/ parksand-trails/ list-of-parks. Accessed July 30, 2025. 96 143,617 residents x 0.004 acres = 574.5 acres
97 U.S. Census Bureau. (2020). Fullerton City, California. https:// data.census.gov/profile/ Fullerton_city,_California?g=160XX00US0628000.
Accessed July 30, 2025.
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neighborhood or regional parks or other recreational facilities. Since the Project would not directly generate population growth and would not indirectly introduce parkgoers to the area, the Project would not cause or contribute to a need to construct new or physically alter park facilities.
Because no park facilities exist on the project site, the Project would not conflict with existing park structures or require modification of park facilities. Overall, Project implementation would not result in substantial adverse physical impacts associated with the provision of new or physically altered park facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives and a less than significant impact would occur.
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4.17 TRANSPORTATION
ENVIRONMENTAL IMPACTS
Potentially
Significant
Issues
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
17. TRANSPORTATION. Would the project:
a) Conflict with a program plan, ordinance or policy
addressing the circulation system, including transit,
roadway, bicycle, and pedestrian facilities?
X
b) Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision ( b)?
X
c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses ( e.g., farm equipment)?
X
d) Result in inadequate emergency access? X
This section is based in part on the Transportation Assessment Policies and Procedures ( TAPP) Worksheet TAPP Worksheet), prepared by the City of Fullerton, dated May 20, 2025 and included in its entirety as Appendix L: Transportation AssessmentPolicies andProcedures (TAPP) Worksheet and Trip Generation Table.
a) Conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities?
Less than Significant Impact. The proposed Project would not conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities.
Transit Service
Public transit service in the vicinity of the project site is provided by the Orange County Transportation Authority ( OCTA). Bus Route 30 provides service from Cerritos to Anaheim via Orangethorpe Avenue; a bus stop is located at the intersection of Orangethorpe Avenue and State College Boulevard, approximately 600 feet west of the project site. Another stop is located at the intersection of Orangethorpe Avenue and South Placentia Avenue, approximately 850 feet east of the site (OCTA, 2025). Bus Route 57 provides service from Brea to Newport Beach via State College Boulevard; a bus stop is located at the intersection of Orangethorpe Avenue and State College Boulevard, approximately 870 feet west of the project site.
Project construction would be temporary in nature and would not result in any road closures.
Public transit service would continue to operate during Project construction. Upon Project implementation, public transit bus service would continue to be provided by the OCTA.
Employment- generating uses currently occur within the site and have been anticipated by The Fullerton Plan. Significant new employment opportunities potentially resulting in a significant AOO
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increase in the use of transit would not be generated; refer to Section 4.14, Population and Housing. Therefore, the Project would not conflict with a program plan, ordinance, or policy addressing transit.
Roadway facilities
The proposed warehouse facility would continue to provide vehicular access from two driveways on East Orangethorpe Avenue and one driveway at the terminus of the Cypress Way cul-de-sac.
Passenger vehicles would have access to the project site from all three driveways. The existing driveway off of Cypress Way would be a 64-foot-wide truck ingress and egress point. The western driveway along Orangethorpe Avenue would be closed and a new driveway would be provided approximately 110 feet to the west. New curb and gutter and sidewalk improvements would also be constructed at the closed driveway. The new western driveway along Orangethorpe Avenue would be 40-foot-wide and allow for truck ingress. The existing eastern driveway along Orangethorpe Avenue would be 26-foot-wide and would exclusively allow for passenger and emergency vehicle ingress and egress. No changes to the existing roadway network would occur.
All driveway improvements would be constructed pursuant to the City’ s requirements. Therefore, the Project would not conflict with a plan, ordinance, or policy concerning roadway facilities.
Pedestrian and Bicycle Facilities
There is an existing sidewalk along Orangethorpe Avenue, adjacent to the project site. As discussed above, the Project would be accessible from two driveways on Orangethorpe Avenue. The existing eastern driveway would be maintained, and the western driveway would be closed and new curb and gutter would be constructed and sidewalk connection would be provided. The Project would also provide landscaping and trees along the Project frontage. Project construction could temporarily impact pedestrian facilities; however, this would be temporary and would not result in a significant impact.
The City of Fullerton Bicycle Master Plan ( Exhibits 3.1 and 5.1) identifies existing and proposed bicycle facilities within the City. According to the Bicycle Master Plan, Class II bike lanes are identified as proposed on Orangethorpe Avenue. A Class II bike lane is defined as a lane striped for one-way travel. Project implementation would not conflict with the bicycle lanes identified in The Fullerton Plan, as no road improvements are proposed. During Project operations, the Project includes the provision of bicycle parking in its plan. As such, Project construction and operation would not result in a significant impact to proposed bicycle facilities. b) Would the project conflict or be inconsistent with CEQA Guidelines section 15064. 3, subdivision b)?
Less than Significant Impact. State CEQA Guidelines Section 15064. 3 codifies the change from Level of Service to VMT as a metric for transportation impact analysis. Pursuant to SB 743, VMT analysis is the primary method for determining CEQA impacts. Jurisdictions were not required to adopt VMT as a significant impact determination until July 1, 2020. The City’ s TAPP requires a VMT Assessment for all projects in accordance with CEQA. The City’ s TAPP sets criteria for the evaluation of projects and the preparation of VMT Assessments. The City relies on the North Orange County Collaborative VMT Traffic Study Screening Tool, which assists in identifying projects that meet VMT screening criteria and therefore do not result in project-generated VMT impacts.
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A TAPP Worksheet was prepared by the City of Fullerton Traffic Engineer for the proposed Project; refer to Appendix L. VMT Screening indicates the proposed Project is anticipated to generate less than 836 VMT. As a result, the Project passed the Primary Screening analysis and a Secondary Screening analysis was conducted. The proposed Project also passed the Secondary Screening criteria. Although additional VMT analysis was not required, a VMT Analysis was conducted; refer to Table 32: VMT Analysis.
Table 32: VMT Analysis
Proposed Project
Estimated Daily Trips 225
Average Trip Length 8.9
Service Population 110
VMT per Service Population 18.1
Proposed Project VMT 2,003
Existing Use VMT Credit 13,047
Net Project VMT - 11,044
Target VMT per Service Population Threshold 29.6
Percentage above/ below VMT Target - 38.9%
Source: TAPP Worksheet, Appendix L.
As indicated in Table 32, the proposed Project would have aVMT/ Service Population of 18.1, which would be approximately 38.9 percent lower than the Target VMT/ Service Population Threshold of
29.6. Therefore, the proposed Project would not have a VMT impact and would not conflict or be inconsistent with CEQA Guidelines section 15064.3(b), a less than significant impact would occur and no mitigation is required.
c) Substantially increase hazards due toa geometricdesign feature (e.g., sharpcurvesor dangerous intersections) or incompatible uses ( e.g., farm equipment)? Less than Significant Impact. The Project proposes to remove the existing business park and develop a new warehouse use consistent with the project site’ s land use Industrial ( I) land use designation and Southwest Industrial Focus Area. Therefore, the Project would not introduce an incompatible use to the site. Internal drive aisles would accommodate standard fire lane turning radiuses and hammerhead turnaround maneuvers design for emergency vehicles and fire services.
The project site would continue to be accessed from two existing driveways along Orangethorpe Avenue and one driveway at the terminus of the Cypress Way cul-de-sac. The existing western driveway along Orangethorpe Avenue closed and a new driveway would be provided approximately 110 feet to the west. New curb and gutter and sidewalk improvements would also be constructed at the closed driveway. The proposed driveway and internal circulation improvements would be constructed pursuant to City of Fullerton Fire Department standards. The Project would not provide any off-site roadway improvements that could substantially increase hazards due to a design feature.
As part of the City’ s Site Plan Review process required under FMC Chapter 15.47, Site Plan Review, the site plan would be reviewed and only approved after finding the proposed development conforms with applicable requirements and standards set forth in the FMC. Therefore, the Project AOO
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would not substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses ( e.g., farm equipment). As such impacts are considered less than significant and no mitigation is required. d) Result in inadequate emergency access?
Less than Significant Impact. The proposed Project driveway entrances and interior drive aisles would accommodate standard fire lane turning radiuses and hammerhead turnaround maneuvers.
Internal drive aisles would be greater than 20 feet wide to accommodate fire apparatus requirements for fire truck access and turning radius. The Fullerton Fire Department would review the Project and specified access requirements concerning minimum roadway width, fire apparatus access roads, fire lanes, signage, access devices and gates, and access walkways, among other requirements, which would enhance emergency access to the project site. Project plans would be reviewed by Fullerton Fire Department for final approval prior to issuance of a building permit.
Compliance with the Fullerton Fire Department’ s requirements would ensure impacts to emergency access would be less than significant.
There is the potential that one or more traffic lanes located immediately adjacent to the project site may be temporarily closed or controlled by construction personnel during construction activities. However, this would be temporary and emergency access to the project site and surrounding area would be required to be maintained at all times. All construction staging would occur within the boundaries of the project site and would not interfere with circulation along nearby roadways. The Project would comply with standard condition SC HAZ- 1, which would require the prepare a Traffic Control Plan for implementation during the construction phase, as deemed necessary by the City Traffic Engineer, as well as SC HAZ-2, in which the City Community and Economic Development Department would consult with the Fullerton Police Department to disclose temporary closures and alternative travel routes, in order to ensure adequate access for emergency vehicles. Therefore, the Project would not result in inadequate emergency access to the City, and a less than significant impact would occur.
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4.18 TRIBAL CULTURAL RESOURCES
ENVIRONMENTAL IMPACTS
Potentially
Significant
Issues
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
18. TRIBAL CULTURAL RESOURCES. Would the project:
a) 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
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)?
X
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?
X
a) 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)? No Impact. The project site is currently developed with a five-building multi-tenant business park that was constructed in 1983. As discussed in Section 4.5: Cultural Resources, the project site does not contain any features meeting the historic resources criteria and does not meet the definition of a historic resource under CEQA. The Fullerton Plan EIR does not identify any historic resources structures located on the project site nor is the project site located within a historic district in the City. 98 Therefore, no known historical resources pursuant to CEQA Guidelines Section 15064.5 were identified on the project site, and the proposed Project would not cause a change in the 98 City of Fullerton. 2012. The Fullerton Plan Final Program EIR – Section 5.10 Cultural Resources. https:// www.cityoffullerton. com/ home/ showpublisheddocument/ 3686/ 637470826615030000. Accessed September 2025.
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significance of a historical resource. In addition, a request was submitted to the Native American Heritage Commission ( NAHC) to review the Sacred Lands File ( SLF) database for any sacred landscape or Tribal resources within or near the project site. A negative response was received on September 5, 2024, which indicated that no recorded SLFs were on file within or near the project site. No impact would occur and no mitigation is required. 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 thecriteria set forthin 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 Impact with Mitigation Incorporated. The Project is subject to compliance with AB 52, which requires consideration of impacts to “tribal cultural resources” ( TCRs), defined in Section 21074 of the Public Resources Code, as part of the CEQA process. AB 52 requires the City to notify any groups ( who have requested notification) who are traditionally or culturally affiliated with the geographic area of a project for which a negative declaration, an MND, or an EIR is required pursuant to CEQA. The Tribes are provided 30 days to request consultation after the lead agency notifies the tribe of a project. In compliance with Public Resources Code Section 21080. 3.1(b), the City provided formal notification to California Native American tribal representatives Based on the City’ s Tribal Contact List. Native American groups may know the area’ s cultural resources and may have concerns about a development’ s adverse effects on tribal cultural resources, as defined in Public Resources Code Section 21074. The City sent AB 52 notification letters to the tribal representatives listed below on July 25th 2025.
Gabrieleno Band of Mission Indians – Kizh Nation – Andrew Salas, Chairperson Gabrieleno Band of Mission Indians – Kizh Nation – Christina Swindall Martinez, Secretary Gabrielino/ Tongva San Gabriel Band of Mission Indians – Anthony Morales, Chairperson Gabrielino/ Tongva Nation – Sandonne Goad, Chairperson
Gabrielino Tongva Indians of California Tribal Council – Robert Dorame, Chairperson Gabrielino Tongva Indians of California Tribal Council – Christina Conely, Cultural Resource Administrator
Gabrielino- Tongva Tribe – Charles Alvarez, Chairperson Gabrielino- Tongva Tribe – Sam Dunlap, Cultural Resource Director Juaneño Band of Mission Indians Acjachemen Nation – Belardes – Joyce Perry, Cultural Resource Director
Juaneño Band of Mission Indians Acjachemen Nation 84A – Heidi Lucero, Chairperson, Tribal Historic Preservation Officer
Pala Band of Mission Indians – Alexis Wallick, Assistant, Tribal Historic Preservation Officer The City received responses from three tribes regarding the AB 52 letter: the Gabrielino Band of Mission Indians – Kizh Nation, Gabrielino Tongva Indians of California Tribal Council, and Pala Band of Mission Indians. The Pala Band of Mission Indians declined AB 52 consultation as they AOO
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determined the project site is not within the boundaries of the recognized Pala Indian Reservation.
Both the Gabrieleno Band of Mission Indians – Kizh Nation and the Gabrielino Tongva Indians of California requested tribal consultation under AB52.
On August 19, 2025, the City responded to Kizh Nation to schedule a consultation meeting. A formal consultation meeting was scheduled for October 14, 2025; however, the Kizh Nation representative was unable to attend due to a scheduling conflict. In lieu of the meeting, the Tribe submitted written comments and proposed mitigation language on October 21, 2025. Based on this consultation, the City incorporated the Tribe’ s recommended measures as Mitigation Measures MM TCR- 1 through MM TCR- 3, with minor modifications. The revised measures were provided to Kizh Nation on October 28, 2025. As of the date of publication, consultation with Kizh Nation remains open.
The City responded to Gabrielino Tongva Indians of California request for consultation on August 28, 2025 with the Project Cultural Resources Memorandum, and followed up on September 11, 2025 and September 25, 2025 to request a meeting time. As of the date of publication, the City has not received any responses from the Gabrielino Tongva Indians of California to schedule consultation.
No known tribal cultural resources have been identified on the project site. Notwithstanding, the potential exists for the discovery of unknown buried archaeological or tribal cultural resources during ground disturbing activities. To address potential impacts during ground- disturbing activities, the proposed Project would be required to comply with MM CUL-1, which requires that, if cultural resources are discovered during Project activities, earthwork and ground- disturbing activities would halt within 60 feet of the find and a qualified archaeologist would be hired to assess the find. Should the find be deemed significant, a Cultural Resources Monitoring and Treatment Plan would be created. Additionally, as outlined in MM TCR- 1, the Project applicant would be required to retain a Native American Monitor for ground disturbing activity. If a tribal cultural resource is identified, all construction activities within 50 feet shall cease until the resource has been assessed. Kizh Nation shall recover and retain the resource and determine appropriate treatment. If human remains are found, implementation of MM TCR-2 and MM TCR-3 would be required, which details instructions when inadvertent discovery of human remains occurs and procedures for burials and funerary remains. Therefore, with implementation of MM CUL-1 and MM TCR- 1 through MM TCR-3 the Project would result in a less than significant impact concerning a substantial adverse change in the significance of a tribal cultural resource.
Mitigation Measures
MM TCR- 1 Prior to issuance of a grading permit, the applicant shall retain a Native American Monitor Prior to Commencement of Ground- Disturbing Activities to the extent that soil deeper than 4 feet are disturbed:
A. The project applicant shall retain a Native American Monitor from or approved by the Gabrieleño Band of Mission Indians – Kizh Nation. The monitor shall be retained prior to the commencement of any “ ground- disturbing activity” for the subject project at all project locations ( i.e., both on-site and any off-site locations that are included in the project description/ definition and/ or required in connection with the project, such as public improvement work). As the existing project site was previously AOO
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developed, “ Ground- disturbing activity” shall include, but is not limited to, boring, grading, excavation, drilling, and trenching that disturbed soil deeper than 4 feet below grade.
B. A copy of the executed monitoring agreement shall be submitted to the lead agency 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”.
C. The monitor will 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 will identify and describe any discovered TCRs, including but not limited to, Native American cultural and historical artifacts, remains, places of significance, etc., (collectively, tribal cultural resources, or “TCR”), as well as any discovered Native American ( ancestral) human remains and burial goods. Copies of monitor logs will be provided to the project applicant/ lead agency.
D. On-site tribal monitoring shall conclude upon the latter of the following ( 1) written confirmation to the Kizh from a designated point of contact for the project applicant/ lead agency that all ground- disturbing activities and phases that may involve ground- disturbing activities on the project site or in connection with the project are complete; or (2) a determination and written notification by the Kizh to the project applicant/ lead agency that no future, planned construction activity and/ or development/ construction phase at the project site possesses the potential to impact Kizh TCRs.
E. 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 Kizh monitor and/ or Kizh archaeologist. The Kizh 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.
MM TCR- 2 Prior to issuance of grading permit, the following notes shall be listed on the grading plans for the project:
A. Native American human remains are defined in PRC 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 Public Resources Code, Section 5097.98, are also to be treated according to this statute.
B. If Native American human remains and/ or grave goods discovered or recognized on the project site, then all construction activities shall immediately cease. 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, AOO
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he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission, and Public Resources Code, Section 5097. 98, shall be followed.
C. Human remains and grave/ burial goods shall be treated alike per California Public Resources Code section 5097. 98(d)(1) and (2).
D. Construction activities may resume in other parts of the project site at a minimum of 200 feet away from discovered human remains and/ or burial goods, if the Kizh 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 Kizh monitor and/ or archaeologist deems necessary). ( CEQA Guidelines Section 15064. 5(f).) E. Preservation in place ( i.e., avoidance) is the preferred manner of treatment for discovered human remains and/ or burial goods.
F. Any discovery of human remains/ burial goods shall be kept confidential to prevent further disturbance.
MM TCR- 3 Prior to issuance of grading permit, the following notes shall be listed on the grading plans for the project:
A. As the Most Likely Descendant (“ MLD”), the Koo-nas-gna Burial Policy 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.
B. 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.
C. 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 orby means as necessary to ensure complete recovery of all sacred materials.
D. 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.
E. In the event preservation in place is not possible despite good faith efforts by the project applicant/ developer 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.
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F. 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 six 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.
G. 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 recoveryrelated 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.
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4.19 UTILITIES AND SERVICE SYSTEMS
ENVIRONMENTAL IMPACTS
Potentially
Significant
Issues
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
19. UTILITIES AND SERVICE SYSTEMS. Would the project:
a) Require or result in the relocation or construction of new or expanded water, wastewater treatment or storm
water drainage, electric power, natural gas, or
telecommunications facilities, the construction or
relocation of which could cause significant environmental effects?
X
b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development
during normal, dry, and multiple dry years?
X
c) 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?
X
d) 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?
X
e) Comply with federal, State, and local management and reduction statutes and regulations related to solid waste? X
a) Require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects? Less than Significant Impact. The following discusses the Project’ s potential impacts on water, wastewater ( conveyance and treatment), storm water drainage, electric power infrastructure, natural gas facilities, and telecommunications facilities and infrastructure.
Water
The City of Fullerton would continue to provide water service to the project site via connection to an existing 12-inch water main in Orangethorpe Avenue and an 8-inch water main in Cypress Way.
The Project proposes water connections for domestic water, fire protection, and landscape irrigation. The Project also includes relocation of the existing on-site water loop to align with the proposed site configuration.
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The City of Fullerton Public Works Department Water Division oversees the City’s water system, including upgrades and repair to infrastructure, water conservation, and water quality. The 2020 Urban Water Management Plan ( 2020 UWMP) is a comprehensive document that evaluates a water supplier’ s reliability over a long- term ( 20 to 25 year) horizon. UWMP water demand forecasts are based on adopted general plans. The 2020 UWMP forecasts water demand for commercial land uses within the City to increase from 4,478 AF in 2025 to 4,987 AF by 2045. The proposed Project’ s water demand would account for less than one percent of the overall anticipated water demand for commercial land uses from 2025 through 2045. The Project’ s water demand is shown in Table 33: Project Water Demand.
Table 33: Project Water Demand
Condition Total Water Demand ( gpd) Total Water Demand ( gpm) Existing Conditions 2,852 1.98
Proposed Project 3,196 2.22
Net Change + 344 (increase) + 0.24 (increase)
Source: Appendix J: Water Demand Assessment
Although the proposed Project would increase water demand over existing conditions, the Water Demand Assessment concluded the proposed water demand increase would not impact the existing infrastructure and the City would be able to serve the Project. The 2020 UWMP forecasted total water demand to be 25,655 AF in 2025. 99 The proposed Project would demand up to 3,196 gallons per day or 3.58 AF. 100 Project implementation would account for less than one percent of current water demand of 25,655 AF in 2025. Further, it is not anticipated that the Project would generate significant population growth. Therefore, the proposed Project would not require the construction of new or expanded water supply or treatment facilities. Impacts would be less than significant and no mitigation is required.
Wastewater
The City of Fullerton would also continue to provide sewer service to the project site via connection to an existing 8-inch sanitary sewer main in Cypress Way. In addition, a secondary point of connection may be extended to an existing City of Placentia sewer main in Orangethorpe Avenue. Compliance with the City of Placentia applicable requirements for the proposed connection would be confirmed through the City’ s review process prior to permit issuance.
The Sewer Capacity Analysis prepared for the Project ( Appendix K) assumed all sewage generation would for the Project would utilize the existing City of Fullerton owned sewer main line in Cypress Way. However, the Project proposes that approximately 2,104 gallons per day GPD) of the total wastewater flow, corresponding to the southern half of the warehouse, would be directed to the City of Placentia owned sewer main in Orangethorpe Avenue. As such, the analysis presented for the City of Fullerton in the Sewer Capacity Analysis represents a conservative evaluation of available sewer capacity.
99 Arcadis. August 2025. 2020 Urban Water Management Plan Table 4-4 Retail: Total Water Use ( Potable and Non-Potable), Available at:
https:// www.cityoffullerton.com/home/ showpublisheddocument/ 5052/ 637598829614070000, Accessed August 11, 2025. 100 1 AF equals about 892 AF per year
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The project site is within the City’ s Sewer Maintenance District 2 and served by an existing 8-inch sanitary sewer main and manhole at station 7+94 in Cypress Way. The existing buildings are connected to an existing sewer main that connects east of the manhole. The City of Fullerton 2009 Sewer Master Plan identified system deficiencies concerning capacity and structural condition, and developed a 20-year Capital Improvement Program ( CIP), which addresses these deficiencies.
The proposed sewage generation for the Project has been estimated using the sewage generation factors from Table F229 of the Sewer Capacity Analysis; see Appendix K: Sewer Capacity Analysis.
Projected sewage generation for the Project compared to existing conditions is provided in Table 34: Project Sewer Demand. The Project would result in a net total decrease of 52 gpd over existing conditions.
Table 34: Project Sewer Demand
Description Facility Description Size ( SF)
Sewage Generation
Factor in Gallons per
Day (GPD) Total
Office Space Office 10,000 120/ 1,000 gross SF 1,200 GPD Warehouse Space Warehouse 100,232 30/ 1,000 gross SF 3,007 GPD Project Total Total GPD 4,207 GPD
Existing Development Total GPD 4,259 GPD
Net Project Difference - 52 GPD
decrease)
Source: Pacific Consulting Group, Inc. (July 2025). Cedarwoods Fullerton Sewer Capacity Analysis.
As indicated in Table 34, the Project would result in a net total decrease of 52 GPD compared to existing conditions; therefore, the Project would not contribute to any existing sewer capacity deficiencies. Therefore, the Project applicant would not be required to contribute a fair-share cost to the City for the Sewer Master Plan improvement projects for sewer capacity. Additionally, the maximum flow capacity ( assuming 50 percent full flow) of the 8-inch sewer main in Cypress Way is 17.15 GPM, which exceeds the Project’ s sewage generation estimate. Based on the findings in Sewer Capacity Analysis, the proposed sewage generation from the Project would not have any impact on the existing sewer infrastructure. As noted above, this is a conservative analysis as 2,104 GPD of the total 4,207 GPD would be serviced by a lateral connection to an existing City of Placentia owned sewer main line in Orangethorpe Avenue.
The proposed sewer connection in Orangethorpe Avenue has been coordinated with the City of Placentia staff, who has confirmed its feasibility. In addition, Placentia staff has confirmed the existing sewer- main in Orangethorpe Avenue has sufficient capacity to accommodate the estimated 2,104 GPD associated with the proposed Project. 101 The additional sewer generation would not result in a significant increase, such that it would exceed the capacity of the existing line.
The Project would be required to comply with applicable requirements outlined City of Placentia Municipal Code Chapter 16.12, Sewer Connection, which would be confirmed through the City of Placentia’ s standard review process prior to sewer connection permit issuance. Therefore, following compliance with the established regulatory framework described above, the Project 101 Based on phone conversation with City of Placentia, Deputy Director of Public Works, Gabriel Guerrero- Gabany ( 714) 993-8250, on October 29, 2025.
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would not result in new or expanded wastewater facilities which could cause a significant environmental effect. A less than significant impact would occur and no mitigation is required.
Storm Water Drainage Facilities
See Threshold 4.10c concerning drainage patterns and stormwater drainage systems. As discussed in Threshold 4.10c, the Project proposes on-site drainage improvements. No off-site drainage improvements are proposed or required. The environmental impacts associated with the proposed drainage improvements are analyzed as a part of the overall Project analysis in this Initial Study.
As concluded in this Initial Study, following compliance with the established regulatory framework, the proposed drainage improvements’ environmental effects would be less than significant and no mitigation is required.
Electric Power, Natural Gas, and Telecommunications Facilities Electrical power is provided by Southern California Edson (SCE). See Section 4.6: Energy for further discussions concerning electricity. The Project’ s anticipated electricity demand would be approximately 0.830 GWh per year, which would represent less than 0.01 percent of SCE’ s projected sales when then Project is operational. The proposed Project would not connect to or utilize natural gas. Telecommunications services are provided by Spectrum, Frontier, and AT& T.
The project site is served by existing telecommunication infrastructure. The various telecommunication providers would continue to provide service coverage to the proposed Project.
The Project proposes to connect to existing electrical and telecommunications infrastructure and no off-site improvements are proposed or required. The environmental effects associated with the necessary on-site electrical and telecommunications improvements are analyzed as a part of the overall Project analysis in this Initial Study. As concluded in this Initial Study, following compliance with the established regulatory framework, the proposed utility improvements’ environmental effects would be less than significant and no mitigation is required. b) 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. The City of Fullerton is a retail water supplier and supplies water currently provide water to the business park on the project site. The 2020 UWMP indicates that water supplies would meet the water demands for normal, single- dry, and multiple dry-year conditions through 2045. Population growth forecasts within adopted general plans are factored into UWMP water demand forecasts
The City meets all of its water demand through a combination of imported water and local groundwater. The City works together with two primary agencies, the Metropolitan Water District of Southern California ( MWD) and the Orange County Water District ( OCWD), to ensure water supply reliability. Groundwater from the Orange County Groundwater Basin ( Basin) accounts for approximately 79 percent of the City’ s overall supply, followed by imported water at 21 percent.
It is projected that by 2045, the water supply portfolio will change to approximately 85 percent groundwater and 15 percent imported water. If the City exceeds their groundwater allocation, a purchase agreement is in place with MET that allows purchase of supplemental imported water.
The City maintains seven imported water connections to MET and six emergency interconnections with other utilities.
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The OC Basin is not adjudicated and as such, pumping from the OC Basin is managed through a process that uses financial incentives to encourage groundwater producers to pump a sustainable amount of water. The framework for the financial incentives is based on establishing the Basin Production Percentage ( BPP), the percentage of each Producer’ s total water supply that comes from groundwater pumped from the OC Basin. The BPP is set based on groundwater conditions, availability of imported water supplies, and OC Basin management objectives. OCWD has a policy to manage the groundwater basin within a sustainable range to avoid adverse impacts to the OC Basin.
The 2020 UWMP forecasted its total water demand to be 27,850 AF by 2045. Additionally, the population is expected to increase from 141,648 persons in 2020 to 189,687 persons by 2045. In the case of a water supply shortage, the City has prepared a Water Shortage Contingency Plan to ensure adequate service. Further, the Project proposes to remove the existing on-site structures and develop a new warehousing building, consistent with the project site’s land use (I) designation and Southwest Industrial Focus Area. Significant new employment opportunities would not be generated and would not require a significant increase in water demand. Further, development, as proposed, would result in a FAR of 0.53, which is less than the 1.0 projected development intensity for the Southeast Industrial Focus Area, and, therefore, less than the development capacity assumptions identified in The Fullerton Plan. Therefore, the Project’ s anticipated water demand is accounted for in the 2020 UWMP. The 2020 UWMP indicates adequate water supplies would be available to serve future water demands during normal, dry and multiple years, which includes water demand associated with the existing site. Therefore, impacts to water supplies would be less than significant.
c) 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. City-owned wastewater collection facilities that serve the City are operated and maintained by the City of Fullerton Public Works Engineering Division. The City’ s current wastewater system includes 330 miles of pipeline and 6,850 manholes. The City’ s wastewater system discharges to several of the Orange County Sanitation District’ s (OCSD) trunk lines. The City of Placentia wastewater collection system also conveys untreated wastewater to Orange County Sanitation District’s (OCSD) trunk sewer system. OCSD collects, treats, and disposes of and/ or reclaims wastewater generated by residents in northwestern and central Orange County.
OCSD has two operating facilities, Reclamation Plant No. 1 and Treatment Plant No. 2, located in the cities of Fountain Valley and Huntington Beach, respectively. Through these facilities, OCSD collects, conveys, treats, and/ or reclaims more than approximately 170 million gallons of wastewater generated daily in its service area. 102
Wastewater is collected and treated at Treatment Plant No. 2. The estimated daily flow of wastewater received at Plant No. 2 is 68 million gallons ( mgd). This facility currently has a total primary treatment capacity of 168 mgd, with an average daily treatment of approximately 127 mgd. Therefore, there is approximately 41 mgd of excess primary treatment capacity at OCSD Plant 102 Orange County Sanitation District. (OCSAN). Regional Sewer Service. https:// www.ocsan.gov/regional-sewer-service/# waterreclamation.
Accessed August 11, 2025.
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No. 2. As discussed above, the proposed Project would result in a total decrease in wastewater generated of 52 gpd. This represents a nominal decrease in wastewater treatment demand at Treatment Plant No. 2. Existing wastewater treatment capacity is sufficient to meet Project demand and Project implementation would not require or result in the construction of new wastewater treatment facilities or expansion of existing facilities. A less than significant impact would occur and no mitigation is required.
d) 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? Or,
e) Would the project comply with federal, State, and local management and reduction statutes and regulations related to solid waste?
Less Than Significant Impact. The Project is anticipated to generate solid waste during the temporary, short-term construction phase, as well as the operational phase, but it is not anticipated to result in inadequate landfill capacity. The City contracts with Republic Services to provide solid waste and recycling services. The majority of solid waste generated in the City is disposed of at the Olinda Alpha Landfill located at 1942 Valencia Avenue in the City of Brea.
According to CalRecycle, the maximum permitted throughput for the landfill is 8,000 tons/ day and the maximum permitted capacity is 148,800,000 CY. The remaining capacity is approximately 17,500,000 CY. 103
The Fullerton Plan EIR identifies a solid waste generation rate of 6.0 pounds per 1000 square feet per day for business parks, offices, and commercial uses. Given the 110,232 square feet of proposed warehouse and ancillary office space the anticipated solid waste generation from the Project according to this generation factor is approximately 661.40 pounds per day ( 0.33 tons/ day) 104. The solid waste volume would be less than one ton per day and therefore considered a nominal amount of the daily capacity of any of the landfills serving the City.
Regulations specifically applicable to the proposed Project include the California Integrated Waste Management Act of 1989 (AB 939), and CalGreen Code Section 4.408, and AB 341. The Integrated Waste Management Act, which requires every city and county in the State to prepare a Source Reduction and Recycling Element (SRRE) to its Solid Waste Management Plan, identifies how each jurisdiction will meet the State’ s mandatory waste diversion goal of 50 percent by and after the year 2000. AB 341 requires that at least 75 percent of waste generated from construction activities be diverted to recycling centers.
The 2025 CalGreen Code Section 4.408 requires preparation of a Construction Waste Management Plan that outlines ways in which the contractor would recycle and/ or salvage for reuse a minimum of 65 percent of the nonhazardous construction and demolition debris. During the construction phase, the Project would be required to comply with the CalGreen Code through the recycling and reuse of at least 65 percent of the nonhazardous construction and demolition debris from the project site.
103 CalRecycle. ( 2025). Solid Waste Information System ( SWIS) Facility Details – Olinda Alpha Landfill ( 30-AB-0035). Retrieved from https:// www2.calrecycle.ca.gov/SolidWaste/ SiteActivity/ Details/ 2757?siteID=2093. Accessed on August 11, 2025. 104 110,232 SF x 6.0lbs per day/ 1000 SF = 661.40 lbs/ day AOO
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Construction and operational activities would be required to comply with all applicable federal, State, and local statutes and regulations for solid waste, including those identified under the most recent CALGreen Code. There is sufficient landfill capacity to serve the proposed Project, and the proposed Project would not conflict with solid waste reduction goals. The Project would result in a less than significant impact concerning solid waste and no mitigation is required.
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4.20 WILDFIRE
ENVIRONMENTAL IMPACTS
Potentially
Significant
Issues
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
20. WILDFIRE. If located in or near State responsibility areas or lands classified as very high fire hazard severity zones, would the project:
a) Substantially impair an adopted emergency response plan or emergency evacuation plan?
X
b) 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?
X
c) 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?
X
d) Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a
result of runoff, post-fire slope instability, or drainage changes?
X
a) 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 CAL FIRE’ s Fire Hazard Severity Zones Map for the City, the project site is not located in or near a State Responsibility Area ( SRA) nor Very High Fire Hazard Severity Zone VHFHSZ) 105. As illustrated in the Fullerton 2021-2029 Safety Element Exhibit 5: Fire Hazard Severity Zones in Fullerton the project site is located in a Local Responsibility Area (LRA). 106 As shown in CAL FIRE’ s FHSZ Viewer, the closest VHFHZ to the project site is located approximately 4 miles northwest of the site, bordering Beach Boulevard and the northern boundary of the City.107 The project site is bordered to the south by Orangethorpe Ave, which is identified as a potential evacuation route. 108 Therefore, the proposed Project would not substantially impair an adopted emergency response plan or emergency evacuation plan due to a wildfire, and no impact would occur. 105 CAL FIRE. ( 2024). Fire Hazard Severity Zones Viewer. https:// egis. fire.ca.gov/ FHSZ/. Accessed on July 9, 2025. 106 City of Fullerton. (2024). Safety Element Supplement, Exhibit 5 Fire Hazard Severity Zones in Fullerton.:
https:// www.cityoffullerton. com/ home/ showpublisheddocument/ 8834/ 638586480019470000. Accessed July 9, 2025. 107 CAL FIRE. ( 2024). Fire Hazard Severity Zones Viewer. Retrieved from: https:// egis.fire.ca.gov/ FHSZ/. Accessed on July 9, 2025. 108 City of Fullerton. (2024). Safety Element Supplement, Exhibit 1: Potential Evacuation Routes in Fullerton. https:// www.cityoffullerton. com/ home/ showpublisheddocument/ 8834/ 638586480019470000. Accessed July 9, 2025.
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b) 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 noted in Threshold 4.20(a) above, the project site is not located in or near an SRA and the project site does not contain lands classified as VHFHSZs. The Project would not exacerbate wildfire risks or expose Project occupants to pollutant concentrations, or the uncontrolled spread of a wildfire and no impact would occur.
c) 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 noted in Threshold 4.20(a) above, the project site is not located in or near an SRA and does not contain lands classified as VHFHSZs. The Project would include construction and operation of a warehouse/ distribution facility and would connect to the existing sanitary sewer, water, and fire water infrastructure available in Cypress Way; see Figure 10. Construction and operation of the Project would not increase the risk of fire, nor would it require the installation/ maintenance of infrastructure that would exacerbate fire risk, and no impact would occur.
d) 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 noted in Threshold ( a) above, the project site is not located in or near an SRA and does not contain lands classified as VHFHSZs. Further, because the project site and surrounding area is relatively flat and located within an urbanized area, it would not expose people or structures to significant risks as a result of runoff, post-fire slope instability, or drainage changes and no impact would occur.
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4.21 MANDATORY FINDINGS OF SIGNIFICANCE
ENVIRONMENTAL IMPACTS
Potentially
Significant
Issues
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
21. MANDATORY FINDINGS OF SIGNIFICANCE. Does the project:
a) Have the potential to substantially degrade the quality of the environment, substantially reduce thehabitat of afish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the
number or restrict therange of arare or endangered plant or animal or eliminate important examples of the major
periods of California history or prehistory?
X
b) Does the project have impacts that are individually
limited, but cumulatively considerable? (" Cumulatively considerable" means that the incremental effects of a
project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)? X
c) Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly?
X
a) Have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below selfsustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? Less than Significant Impact. As discussed throughout this Initial Study, the proposed Project does not have the potential to significantly degrade the quality of the environment or result in significant impacts to the environment that cannot be reduced to less than significant following compliance with the established regulatory framework ( i.e., local, State, and federal regulations) and the recommended mitigation measures.
As concluded in Section 4.4: Biological Resources, the Project would not substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self- sustaining levels, threaten or eliminate a plant or animal community, or substantially reduce the number or restrict the range of a rare or endangered plant or animal.
As concluded in Section 4.5: Cultural Resources, the Project would not eliminate important examples of the major periods of California history or prehistory. SCCIC records search and historic aerial imagery review did not indicate any historical buildings or resources within the project site.
The project site’ s existing commercial retail buildings and structures does not meet the criteria of AOO
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architecturally significant” or a “ historic resource” under CEQA. Therefore, the proposed Project would not cause a change in the significance of a historical resource. b) Does the project have impacts that are individually limited, but cumulatively considerable? Cumulatively considerable" means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of othercurrent projects, and the effects of probable future projects)?
Less Than Significant Impact. The Project does not have impacts that are individually limited but cumulatively considerable. Incremental impacts resulting from Project construction and operations and other cumulative projects that would be under construction include biological resources, cultural resources, geology and soils, and tribal resources. The analysis concluded that these incremental impacts are each less than significant or can be mitigated to a less than significant level. When viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects, these impacts are not cumulatively considerable. There would be no cumulative impacts in connection with this or other projects. The project complies with long-term regional air quality plans, and regional population forecasts, and is within the service capabilities of utility purveyors. There would be no significant adverse environmental impacts. The analysis contained in this Initial Study evaluated existing conditions, potential impacts associated with project development, and possible environmental cumulative impacts. The Project does not have any impact on projected growth or planned projects for the City or neighboring jurisdictions known as of the date of this analysis. c) Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly?
Less Than Significant Impact. As discussed in this Initial Study, there are no known substantial adverse effects on human beings that would be caused by the proposed Project. The environmental evaluation has concluded that no significant environmental impacts would result from the proposed Project. Therefore, impacts concerning adverse effects on human beings would be less than significant.
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5.0 REFERENCES
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2012. The Fullerton Plan.
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development/ planning- zoning/ general- plan/ the-fullerton- plan-current- version. Accessed September 10, 2025
N.D. Fire Station Locations & Apparatus.
https:// www. cityoffullerton. com/ government/ departments/ fire/ about- us/ fire-stationlocations- apparatus, Accessed July 30, 2025. 2024. Municipal Code. https:// codelibrary. amlegal. com/ codes/ fullerton/ latest/ fullerton_ca/ 0-0- 0-22940# JD_Chapter13. 19. Accessed July 30, 2025.
N.D. Fullerton Police About Us.
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Elliott H. Berger, Rick Neitzel, and Cynthia A. Kladden. 2010. Noise Navigator Sound Level Database with Over 1700 Measurement Values.
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Southern California Association of Governments. 2024. Connect SoCal (2024 – 2050 Regional Transportation Plan/ Sustainable Communities Strategy).
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WSP. 2017. RCTC Truck Study and Regional Logistics Mitigation Fee, Technical Memorandum 1: Exiting and Future Conditions, Warehouse- Related Land Use Data & Truck Travel Patterns.
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