RESOLUTION NO. PC-2025-21
A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF
FULLERTON, CALIFORNIA, RECOMMENDING THAT THE CITY COUNCIL
ADOPT A MITIGATED NEGATIVE DECLARATION, INCLUDING MITIGATION
MEASURES AND MITIGATION MONITORING AND REPORTING PROGRAM FOR A NEW INDUSTRIAL WAREHOUSE BUILDING LOCATED AT 2461 TO 2495 EAST ORANGETHORPE AVENUE
PRJ2025-00005, LRP-2025-0011, ZON-2025-0013
APPLICANT: LTCGG LLC
PROPERTY OWNER: LTCGG LLC
WHEREAS, applications were filed with the City of Fullerton Community and Economic Development Department for a Zoning Amendment (LRP-2025-0011) and a Major Site Plan (ZON-2025-0013), to amend the zoning designation along southerly side of the parcel from CM-ES to M-P-100ES to be consistent with northerly half of the parcel and for the demolition of an existing business park for the construction of a new 110,232 square foot warehouse facility (Cedarwoods Fullerton Project) with associated onsite improvements on a parcel of land more specifically described as Orange County Assessor’s Parcel No. 338-172-24 WHEREAS, the City of Fullerton, as Lead Agency, prepared a Draft Initial Study/Mitigated Negative Declaration to identify the potential environmental impacts associated with the construction and implementation of the project in conformance with the provisions of the California Environmental Quality Act (CEQA) (California Public Resources Code, Sections 21000 et seq.) and CEQA Guidelines (California Code of Regulations, Title 14, Section 15000 et seq.); and
WHEREAS, mitigation measures were identified to reduce or avoid significant effects on the environment, and a Mitigation Monitoring and Reporting Program will be prepared to ensure and document compliance with the mitigation measures during project implementation; and WHEREAS, the City of Fullerton is the Lead Agency on the project, and the Planning Commission is the advisory body to the City Council, which is the decision-making body for the applications associated with the proposed project; and
WHEREAS, the City provided a Notice of Intent to Adopt a Mitigated Negative Declaration to owners all owners, as well as to the location of the properties, within 300 feet of the project site and to potentially interested public agencies and to the Orange County ClerkRecorder advertising a 20-day public review period; and WHEREAS, comments on the Mitigated Negative Declaration were received and responses to comments were prepared and made available as an attachment to the project; and Resolution No. PC-2025-21
WHEREAS, the Planning Commission has considered the information contained in the Draft Initial Study/Mitigated Negative Declaration dated November 2025, Technical Appendices and the responses to comments; and
WHEREAS, the Planning Commission does hereby recommend that the City Council adopt the Mitigated Negative Declaration for the Cedarwoods Fullerton Project, PRJ2025- 00005.
NOW, THEREFORE, BE IT FOUND, DETERMINED AND RESOLVED by the Planning Commission of the City of Fullerton, as follows:
1. The Planning Commission of the City of Fullerton recommends that the City Council adopt the Mitigated Negative Declaration for the Cedarwoods Fullerton Project, PRJ2025-00005, located at 2461 to 2495 East Orangethorpe Avenue.
2. The Mitigated Negative Declaration for PRJ2025-00005 adequately address the anticipated environmental impacts of the project. On the basis of their review, the Planning Commission finds that there is no evidence from which it can be fairly argued that the project will have a significant adverse effect on the environment and that the Mitigated Negative Declaration reflects the Lead Agency’s independent judgement and analysis.
ADOPTED BY THE FULLERTON PLANNING COMMISSION ON DECEMBER 10, 2025.
Arnel Dino, Chairman
Attachments
Exhibit A – Initial Study/Mitigated Negative Declaration dated November 2025 Cedarwoods Fullerton Project
Initial Study/Mitigated Negative Declaration
Prepared By:
Kimley- Horn and Associates, Inc.
1100 Town and Country Road, Suite 700
Orange, CA 92868
November 2025
Kimley»Horn
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Table of Contents
1.0 INTRODUCTION AND PURPOSE ................................................................................................... iv
1.1 Purpose and Scope of the Initial Study ............................................................................... 1
1.2 Summary of Findings ......................................................................................................... 1
1.3 Initial Study Public Review Process .................................................................................... 2
1.4 Report Organization .......................................................................................................... 3
2.0 DESCRIPTION OF PROPOSED PROJECT .......................................................................................... 4
2.1 Project Location and Setting .............................................................................................. 4
2.2 Existing General Plan Land Use and Zoning ........................................................................ 5
2.3 Project Characteristics ....................................................................................................... 6
2.4 Discretionary Actions and Approvals .................................................................................. 9
3.0 INITIAL STUDY CHECKLIST ........................................................................................................... 20
3.1 Environmental Factors Potentially Affected ..................................................................... 22
4.0 ENVIRONMENTAL EVALUATION ................................................................................................. 23
4.1 AESTHETICS .................................................................................................................... 23
4.2 AGRICULTURE AND FORESTRY RESOURCES ...................................................................... 27
4.3 AIR QUALITY .................................................................................................................... 29
4.4 BIOLOGICAL RESOURCES ................................................................................................. 54
4.5 CULTURAL RESOURCES .................................................................................................... 58
4.6 ENERGY ........................................................................................................................... 61
4.7 GEOLOGY AND SOILS ....................................................................................................... 73
4.8 GREENHOUSE GAS EMISSIONS......................................................................................... 79
4.9 HAZARDS AND HAZARDOUS MATERIALS .......................................................................... 95
4.10 HYDROLOGY AND WATER QUALITY................................................................................ 101
4.11 LAND USE AND PLANNING ............................................................................................. 110
4.12 MINERAL RESOURCES .................................................................................................... 115
4.13 NOISE ............................................................................................................................ 116
4.14 POPULATION AND HOUSING ......................................................................................... 138
4.15 PUBLIC SERVICES ........................................................................................................... 140
4.16 RECREATION .................................................................................................................. 144
4.17 TRANSPORTATION ......................................................................................................... 146
4.18 TRIBAL CULTURAL RESOURCES ...................................................................................... 150 O
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4.19 UTILITIES AND SERVICE SYSTEMS ................................................................................... 156
4.20 WILDFIRE ....................................................................................................................... 163
4.21 MANDATORY FINDINGS OF SIGNIFICANCE ..................................................................... 165
5.0 REFERENCES ............................................................................................................................. 167 Tables
Table 1: Existing On-Site Land Use ........................................................................................................... 4 Table 2: Existing Surrounding Land Use Designations and Zoning ............................................................. 6 Table 3: Building Summary ...................................................................................................................... 7 Table 4: Air Contaminants and Associated Public Health Concerns......................................................... 31 Table 5: Ambient Air Quality Data.......................................................................................................... 33 Table 6: State and Federal Ambient Air Quality Standards ..................................................................... 34 Table 7: South Coast Air Basin Attainment Status .................................................................................. 37 Table 8: South Coast Air Quality Management District Significance Thresholds ...................................... 40 Table 9: Local Significance Thresholds for Construction and Operations ................................................ 41 Table 10: Project Construction Emissions............................................................................................... 45 Table 11: Project Operational Emissions ................................................................................................ 46 Table 12: Equipment- Specific Grading Rates .......................................................................................... 48 Table 13: Localized Project Construction Emissions ............................................................................... 49 Table 14: Localized Project Operational Emissions ................................................................................. 50 Table 15: Energy Resources Used to Generate Electricity for South California Edison ............................. 62 Table 16: Annual Orange County Electricity Consumption...................................................................... 63 Table 17: Annual Orange County Automotive Fuel Consumption ........................................................... 63 Table 18: Project Construction Energy Consumption ............................................................................. 68 Table 19: Project Operational Energy Consumption ............................................................................... 70 Table 20: Project Construction Greenhouse Gas Emissions .................................................................... 89 Table 21: Project Operational Greenhouse Gas Emissions ...................................................................... 90 Table 22: Regional Transportation Plan/ Sustainable Communities Strategy Consistency ........................ 91 Table 23: General Plan Policy Consistency ........................................................................................... 111 Table 24: Existing Noise Measurement Locations and Measurements.................................................. 117 Table 25: Land Use Compatibility for Community Noise Environments ................................................ 120 Table 26: City of Fullerton Noise Standards.......................................................................................... 121 Table 27: City of Placentia Noise Standards ......................................................................................... 124 Table 28: Typical Construction Noise Levels ......................................................................................... 127 Table 29: Project Construction Noise Levels ......................................................................................... 129 Table 30: Composite Noise Levels ........................................................................................................ 133 Table 31: Typical Construction Equipment Vibration Levels ................................................................. 135 O
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Table 32: VMT Analysis ........................................................................................................................ 148 Table 33: Project Water Demand ......................................................................................................... 157 Table 34: Project Sewer Demand ......................................................................................................... 158 Figures
Figure 1: Regional Map .......................................................................................................................... 10 Figure 2: Vicinity Map ............................................................................................................................ 11 Figure 3: Existing On-Site Conditions...................................................................................................... 12 Figure 4: Existing Land Use Designation ................................................................................................. 13 Figure 5: Existing Zoning Classifications ................................................................................................. 14 Figure 6: Proposed Zoning Classification ................................................................................................ 15 Figure 7: Conceptual Site Plan ............................................................................................................... 16 Figure 8: Conceptual Elevations ............................................................................................................. 17 Figure 9: Conceptual Landscape Plan ..................................................................................................... 18 Figure 10: Conceptual Utility Plan .......................................................................................................... 19 Figure 11: Noise Monitoring Locations Map ......................................................................................... 118 Appendices
Appendix A: Air Quality and Greenhouse Gas Modeling Data Appendix B: Cultural Resources Memorandum
Appendix C: Energy Calculations
Appendix D: Geotechnical Engineering Investigation
Appendix E: Paleontological Resources Records Search
Appendix F: Phase I Environmental Site Assessment
Appendix G: Preliminary Water Quality Management Plan
Appendix H: Hydrology and Hydraulics Report
Appendix I: Noise and Vibration Data
Appendix J: Water Demand Assessment
Appendix K: Sewer Capacity Assessment
Appendix L: Transportation Assessment Policies and Procedures ( TAPP) Worksheet and Trip Generation Table
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1.0 INTRODUCTION AND PURPOSE
1.1 Purpose and Scope of the Initial Study
Pursuant to State California Environmental Quality Act ( CEQA) Guidelines Section 15367, the City of Fullerton ( City) is the Lead Agency for the Cedarwoods Fullerton Project (proposed Project or Project). The Lead Agency is the public agency that has the principal responsibility for carrying out or approving a project. The City has the authority for environmental review in accordance with CEQA and certification of the environmental documentation.
This Initial Study has been prepared to evaluate the potential environmental effects associated with the construction and operation of the proposed Project. This document has been prepared in accordance with the CEQA ( California Public Resources Code [ PRC] § 21000 et seq.) and the State CEQA Guidelines California Code of Regulations, Title 14, §15000 et seq). Pursuant to CEQA requirements, this Initial Study includes a description of the proposed Project; an evaluation of the Project’ s potential environmental impacts; the findings of the environmental analyses; and recommended mitigation measures to avoid or lessen the Project’ s significant adverse environmental impacts.
This Initial Study evaluates each of the environmental issue areas contained in the Environmental Checklist Form provided in Section 3.0 below. It provides decision- makers and the public with information concerning the potential environmental effects associated with the Project’ s construction and ongoing operations, and ways to avoid or reduce potential environmental impacts. The City will use this Initial Study as a resource when considering and taking action on the Project. Any responsible agency may elect to use this environmental analysis for discretionary actions associated with Project implementation. No trustee agencies are applicable to this Project.
1.2 Summary of Findings
Based on the Environmental Checklist Form completed for the proposed Project and supporting environmental analyses, the Project would result in no impact or a less than significant impact on the majority of the environmental issues analyzed in this Initial Study. The following environmental study areas would have no impact or a less than significant impact: Aesthetics, Agriculture and Forestry Resources, Air Quality, Biological Resources, Energy, Greenhouse Gas Emissions, Hazards and Hazardous Materials, Hydrology, Land Use and Planning, Mineral Resources, Population and Housing, Public Services, Recreation, Utilities and Service Systems, and Wildfire. The Project’ s impacts on the following issue areas would be less than significant with mitigation incorporated: Cultural Resources, Geology and Soils, Noise, and Tribal Cultural Resources. All impacts would be less than significant after mitigation.
As set forth in State CEQA Guidelines Section 15070 (Decision to Prepare a Negative or Mitigated Negative Declaration), a public agency shall prepare or have prepared a proposed negative declaration or mitigated negative declaration for a project pursuant to CEQA when:
a) The initial study shows that there is no substantial evidence, in light of the whole record before the agency, that the project may have a significant effect on the environment, or b) The initial study identifies potentially significant effects, but:
1) Revisions in the project plans or proposals made by, or agreed to by the applicant before a proposed mitigated negative declaration and initial study are released for public review O
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would avoid the effects or mitigate the effects to a point where clearly no significant effects would occur, and
2) There is no substantial evidence, in light of the whole record before the agency, that the project as revised may have a significant effect on the environment.
1.3 Initial Study Public Review Process
The City has provided the Notice of Intent (NOI) to adopt a Mitigated Negative Declaration ( MND) to the Orange County Clerk- Recorder and mailed the NOI to responsible agencies, nearby property owners, and other parties who expressed interest in receiving the NOI. In conjunction with the NOI, the City has released the Initial Study/ Mitigated Negative Declaration ( IS/ MND) for a 20-day public review period pursuant to State CEQA Guidelines Section 15105. As the Project does not affect resources under the jurisdiction of a State trustee or responsible agency and is not considered regionally significant, a 20-day review period is appropriate. During the public review period, the IS/ MND, including technical appendices, can be accessed on the City’ s website and is available for review at the location listed below. https:// portal. laserfiche. com/ Portal/ Browse. aspx?id=1539720& repo=r-3261686e City of Fullerton
Community and Economic Development Department
303 West Commonwealth Avenue – 2nd Floor
Fullerton, CA 92382
In reviewing the IS/ MND, affected public agencies and interested members of the public should focus on the adequacy of the document in identifying and analyzing the Project’ s potential environmental impacts and the ways in which the potentially significant impacts can be avoided or mitigated.
If public agencies or any members of the public have comments on the IS/ MND, they can be sent to:
David Lopez, Senior Planner
City of Fullerton – Community and Economic Development Department 303 West Commonwealth Avenue – 2nd Floor
Fullerton, CA 92382
714) 738-6878
david.lopez@cityoffullerton. com
Comments sent via email should include “ Cedarwoods Fullerton Project” in the subject line and a valid mailing address.
Following receipt and evaluation of comments from agencies, organizations, and/ or individuals, the City will determine whether the comments raise any substantial new environmental issues. If so, further documentation may be required. If not, or if the issues raised do not provide substantial evidence that the Project would have a significant effect on the environment, the IS/ MND and the Project will be considered for adoption and approval, respectively.
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1.4 Report Organization
This document includes the following sections:
Section 1.0 – Introduction and Purpose. This section provides an introduction and overview describing purpose of the CEQA document and the Initial Study conclusions.
Section 2.0 – Description of Proposed Project. This section includes the Project Description, which identifies the Project location, key characteristics, and includes a list of anticipated discretionary actions.
Section 3.0 – Initial Study Checklist. The Environmental Checklist Form provides an overview of the potential impacts that may or may not result from Project implementation.
Section 4.0 – Environmental Evaluation. This section contains an analysis of environmental impacts for each resource area identified in the Environmental Checklist Form.
Section 5.0 – References. The section identifies resources used to prepare the Initial Study.
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2.0 DESCRIPTION OF PROPOSED PROJECT
2.1 Project Location and Setting
The Cedarwoods Fullerton project site ( project site) is located in Orange County, in the southeastern portion of the City of Fullerton ( City). The project is located within a largely urbanized area of the City near its boundary with the cities of Anaheim and Placentia. Regional access is provided via State Route 57 SR- 57) approximately 0.5 mile to the east and SR-91 approximately 0.4 mile to the south of the project site. Figure 1: Regional Map depicts the project site in a regional context.
The approximately 4.79-acre (rounded to 4.8 acres) project site is comprised of one generally rectangularshaped developed parcel ( Assessor’ s Parcel Number [ APN] 338-172-24) located at 2461-2495 East Orangethorpe Avenue. The site is generally bordered by industrial warehouse/ manufacturing uses to the north and east, Orangethorpe Avenue to the south, and a small local- serving commercial retail strip mall and towing company lot to the west. Across Orangethorpe Avenue to the south of the project site are additional industrial uses, which are within the incorporated boundaries of the City of Anaheim. Local vehicular access is currently provided directly via two driveways on Orangethorpe Avenue and one driveway at the terminus of the Cypress Way cul-de-sac, see Figure 2: Vicinity Map.
On-Site Land Uses
The project site is relatively flat and gradually slopes north to south from approximately 215 feet to 193 feet above mean sea level. The project site was developed in 1983 as a five-building multi-tenant business park, referred to as “ Cedarwoods Business Park” and currently operates as such. The five buildings have a total of approximately 85,700 square feet of industrial and commercial uses, a surface parking lot, and landscaping, as depicted on Figure 3: Existing On-Site Conditions. Table 1: Existing On-Site Land Use summarizes the existing buildings on the site. Prior to the current development, the project site was historically used for agricultural purposes or was vacant.
Table 1: Existing On-Site Land Use
Building Type Address/ Unit
Building 1 - southwest side of the project site
Two-story, concrete tilt-up office building 2461 East Orangethorpe Avenue, Unit 101 2461 East Orangethorpe Avenue, Unit 102
2461 East Orangethorpe Avenue, Unit 103
2461 East Orangethorpe Avenue, Unit 104
2461 East Orangethorpe Avenue, Unit 105
2461 East Orangethorpe Avenue, Unit 200
Building 2 – west side of the project site
Single- story, concrete tilt-up industrial building 2465/ 2467 East Orangethorpe Avenue 2469 East Orangethorpe Avenue
2471 East Orangethorpe Avenue
Building 3 – north side of the project site
two-story, concrete tilt-up industrial building 2473 East Orangethorpe Avenue 2475 East Orangethorpe Avenue
2477 East Orangethorpe Avenue
2479 East Orangethorpe Avenue
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Table 1: Existing On-Site Land Use
Building Type Address/ Unit
2483 East Orangethorpe Avenue
Building 4 – east side of the project site
single- story, concrete tilt-up industrial building 2487 East Orangethorpe Avenue 2489 East Orangethorpe Avenue
2491 East Orangethorpe Avenue
2493 East Orangethorpe Avenue
Building 5 – southeast side of the project site
two-story, concrete tilt-up office building 2495 East Orangethorpe Avenue, Unit 100 2495 East Orangethorpe Avenue, Unit 101
2495 East Orangethorpe Avenue, Unit 110
2495 East Orangethorpe Avenue, Unit 200
2495 East Orangethorpe Avenue, Unit 210
Source: Orswell & Kasman, Inc. (October, 2023). Phase I Environmental Site Assessment Report. Included as Appendix F.
2.2 Existing General Plan Land Use and Zoning
The Fullerton Plan (General Plan) identifies 12 geographic focus areas in the City to concentrate potential change through community- led planning processes. The proposed Project is located within Focus Area K:
Southeast Industrial, which recommends a maximum Floor Area Ratio (FAR) of 1.0 and highly recommends future development types of office and industrial uses.
General Plan Exhibit 2: Community Development Plan depicts the City’ s community development types land use designations) which identifies the project site designated as Industrial (I) with a permitted 0.35 to 0.5 FAR. 1,2 The Industrial (I) designation is meant 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. 3 Figure 4: Existing Land Use Designation depicts the existing on-site and surrounding properties’ land use designations. The proposed Project is consistent with and would be an allowed use within the existing community development type. No General Plan amendment would be required.
The City of Fullerton Zoning Map depicts the City’ s zoning classifications and identifies that the project site is zoned Manufacturing Park with a 100,000-square-foot minimum lot size and an Emergency Shelter Overlay (MP-100-ES) on the northern portion of the site. The MP-100-ES zoning classification is intended for a wide range of light industrial activities, often based on a multi-tenant type development. The proposed Project is consistent with the existing MP-100-ES zoning classification on the northern portion of the site. On the remaining southern portion of the property, the project site is zoned Commercial Manufacturing with an Emergency Shelter Overlay ( CM-ES). The CM zoning classification is intended to provide for selected areas where on- premises retail sales and services along with the related assembling, processing and manufacturing can be carried out. The proposed warehouse Project would not be an allowed use within the CM zone. Therefore, the Project would rezone the southern portion of the site to 1 City of Fullerton. (2025). Fullerton - GoZone GIS Webtool. Available at:
https:// gis.cityoffullerton. com/ portal/ apps/ webappviewer/ index.html?id=38a7db5f8a8748b1818bc31269bfa3b0 2 Maximum FAR increase based on focus area policies
3 City of Fullerton. ( 2012). The Fullerton Plan, Page 125 O
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MP-100-ES. The ES Overlay would remain on the entirety of the site. Figure 5: Existing Zoning Classifications and Figure 6: Proposed Zoning Classification depicts the existing and proposed zoning districts for the project site and surrounding properties. In addition, the existing community development types and zoning districts are summarized in Table 2: Existing Surrounding Land Use Designations and Zoning.
Table 2: Existing Surrounding Land Use Designations and Zoning Direction
Community Development Type
land use designation) Zone Classification
Project Site Industrial
Manufacturing Park with a 100,000 square-foot
minimum lot size (MP-100)
Commercial Manufacturing ( CM)
Emergency Shelter Overlay ( ES)
North Industrial Manufacturing Park with a 200,000 square-foot minimum lot size (MP-200)
South City of Anaheim: Industrial (I-L) City of Anaheim: Industrial East Industrial Manufacturing Park with a 100,000 square-foot minimum lot size (MP-100)
West Industrial
Manufacturing, General (MG)
Commercial Manufacturing ( CM)
Emergency Shelter Overlay ( ES)
Sources:
City of Fullerton. Fullerton - GoZone GIS Webtool. Available at:
https:// gis.cityoffullerton. com/ portal/ apps/ webappviewer/ index.html?id=38a7db5f8a8748b1818bc31269bfa3b0. Retrieved July, 2025 City of Anaheim. Zoning and General Plan Viewer. Available at:
https:// gis.anaheim. net/ portal/ apps/ webappviewer/ index.html?id=a5931cb4134b4a7ebf5a629e95f56e8f. Retrieved July, 2025
2.3 Project Characteristics
Site Development
The Applicant is proposing 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 with a gated truck court, surface parking lot, and landscaping. The proposed building would consist of 100,232 square feet of warehouse space and 10,000 square feet of ancillary office space. The office space would be split evenly between the ground level and mezzanine with one area on the north of the building and one area on the south of the building to maximize flexibility for a future tenant. Consistent with the proposed MP-100-ES zoning district, the proposed structure would be a concrete tilt-up warehouse building and would have a maximum roof line of approximately 44 feet in height, inclusive of the parapet, and a FAR of 0.53. A solar photovoltaic ( PV) system would be installed on the roof over the office areas of the warehouse. The office areas are the only areas that are being proposed to be mechanically ventilated. The Project would have 91 passenger vehicle parking stalls on the north and west perimeters of the site. The truck court, which is proposed to have 15 dock doors, would be located on the west side of the building; see Table 3: Building Summary. Additional site components would include a trash enclosure, pump house, and bike racks to be located near the ancillary office spaces in the warehouse building. See Figure 7: Conceptual Site Plan.
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Table 3: Building Summary
Warehouse
sf)
Office
sf)
Mezzanine
Office ( sf)
Total
Building ( sf)
Loading
Docks
Automobile Parking Stalls
Required1 Proposed
100,232 5,000 5,000 110,232 15 91 91
1. Warehouse parking space requirement 1 space for every 2,000 sf, Office parking space requirement 1 space for every 250 sf. sf = square feet
Source: Fullerton Municipal Code (FMC) Chapter 15.40
The proposed Project is currently planned as a “ speculative project.” Therefore, the future tenants of the building are not currently known. Without knowing the identity of a future tenant, the exact number of future employees or hours of operation cannot be determined. Therefore, this IS/ MND and associated technical reports use approximate potential on-site employees, hours of operation, and vehicular traffic generation based on the proposed Project’ s characteristics ( i.e., square footage). This IS/ MND and the associated technical reports have assumed uses and intensities that may be greater than what might actually be expected at buildout and operation, which provide a conservative estimation of impacts.
Circulation and Parking
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 the three driveways. The driveway off of Cypress Way would be a 64-foot-wide truck ingress and egress point that would provide access to the gated truck court on the west side of the building, as well passenger vehicle parking. The Cypress Way driveway would also have an 8-foot high rolling gate and knox pad lock. The western driveway along Orangethorpe Avenue would be 40 feet wide and allow for truck ingress and egress. The western driveway would also provide access to the gated truck court and passenger vehicle parking. The eastern driveway along Orangethorpe Avenue would be 26 feet wide with an 8-foot high rolling gate and knox pad lock, which would exclusively allow for passenger and emergency vehicle ingress and egress. The eastern driveway would provide access to the drive aisle along the eastern perimeter of the site which would lead to passenger vehicle parking.
All internal drive aisles would be 26 feet wide and accommodate standard fire lane turning radiuses and hammerhead turnaround maneuvers for emergency vehicles and fire services. All entry gates on the project site would be equipped with knox boxes for access by the City of Fullerton Fire Department and Police Department for emergencies.
Consistent with the Fullerton Municipal Code ( FMC) Table 15.40.050.A, the Project would provide 91 vehicle parking spaces: 44 standard stalls, 26 compact stalls, 4 electric vehicle charging stations ( EVCS), 13 electric vehicle capable stalls, and 4 Americans with Disabilities Act (ADA) stalls for employee and visitor parking. Passenger vehicle parking stalls are proposed on the north and west perimeters of the project site. The gated truck court would be located on the west side of the warehouse and would be secured by 8-foot-high rolling gates. Pedestrian access within the project site would be provided by sidewalks.
Existing pedestrian sidewalks along Orangethorpe Avenue would remain.
Building Design, Landscaping, Lighting
The conceptual design for the Project includes concrete tilt-up panels with architectural treatments, such as panel reveals, variation in façade material, and horizontal and vertical articulations to provide visual relief on the building facades, as shown in Figure 8: Conceptual Elevations. The exterior elevations would be white and grey with blue window glazing. Rooftop mechanical equipment would be screened, if visible O
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from the public right-of-way. Consistent with FMC Table 15.40.040.B, a retaining wall would be located along a portion of the western perimeter of the site and an 8-foot-high wrought iron fence would be located along the western perimeter of the site containing the truck court area, the eastern half of the northern perimeter of the site, and the entirety of the eastern perimeter of the site.
The Project would be subject to compliance with the development standards in FMC Section 15.40.040, which include requirements for building setbacks. Consistent with the FMC, the proposed warehouse would be set back over 20 feet from Orangethorpe Avenue. The Project would also be subject to compliance with the development standards in FMC Section 15.40.040.F, which include requirements for landscaping and FMC Chapter 15.50, which outline additional landscaping and irrigation requirements.
The Project would provide a total of 19,109 square feet of landscaping, which would include ground cover, shrubs, and trees focused near parking lot areas, the warehouse, site perimeter, and driveway entries, see Figure 9: Conceptual Landscape Plan.
Site lighting would be used to provide adequate lighting for circulation, safety, and security. All project site entries, exits, parking areas, loading areas, trash enclosures, outdoor areas, and pedestrian pathways would include dusk to dawn lighting for security purposes. Lighting provided to illuminate any parking area shall be arranged so as to reflect the light and glare away from adjacent properties.
Utility and Off-Site Improvements
The Project would connect with the existing utility infrastructure, including water service, sanitary sewer service, storm drain infrastructure, and electrical, as depicted in Figure 10: Conceptual Utility Plan. 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 includes relocation of the existing on-site water loop. 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.
A secondary point of connection may be extended to an existing City of Placentia sewer main in Orangethorpe Avenue. The Project does not propose connection to or use of natural gas. The project site is currently served and would continue to be served by Southern California Edison (SCE).
Roadway Improvements
Along Orangethorpe Avenue, the existing western driveway would be relocated resulting in the construction of a new driveway with sidewalk and curb and gutter improvements and reconstruction at the existing driveway location. The existing eastern driveway on Orangethorpe Avenue would remain in its existing location and configuration.
Construction
Project construction is expected to commence in late 2027 with a duration of approximately 13 months completed in one phase. Approximately 929 cubic yards ( cy) of fill are anticipated. The final grading plan would be reviewed and approved by the City prior to grading permit issuance.
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2.4 Discretionary Actions and Approvals
The following discretionary actions and/ or approvals are required for the proposed Project:
City of Fullerton
Adoption of the Initial Study/ Mitigated Negative Declaration. The proposed Project requires CEQA compliance through the adoption of an IS/ MND prior to Project approval. This Initial Study and the proposed MND would serve as the primary environmental document for all actions associated with approval of the Cedarwoods Fullerton Project.
Zoning Amendment ( LRP- 2025-0011). The Project would require a zoning amendment on the southern portion of the parcel from Commercial Manufacturing with an Emergency Shelter Overlay ( CM- ES) to Manufacturing Park with a 100,000 square- foot minimum lot size and an Emergency Shelter Overlay (MP-100-ES) to be consistent with the northern half of the parcel.
Major Site Plan ( ZON-2025- 0013). The Project requires review of the site improvements and compliance with the applicable development standards.
Other
Santa Ana Regional Water Quality Control Board ( Regional Board). National Pollutant Discharge Elimination System (NPDES) Compliance/ Low Impact Development ( LID) approvals.
City of Placentia. Project may extend a point of connection from the site to a City of Placentia owned sanitary sewer main line in Orangethorpe Avenue. A sewer permit would be required.
Other permits required for the Project may include, but are not limited to, issuance of encroachment permits for driveways, sidewalks, signs, building permits, grading permits, demolition permits, tenant improvement permits, and permits for new utility connections.
O
urore”
o"UL4
Not to scale. Cedarwoods Fullerton Project
Source:
710
105
L o s A n g e l e s
San Fernando
Malibu
Calabasas
La Cañada
Flintridge
Beverly Hills
Carson
South Gate
Huntington Park
Burbank
Glendale
Santa Monica
Long Beach
Simi Valley
Downey
Inglewood
Torrance
Pasadena
East Los Angeles
Los Angeles
1830 ft
10066 ft
2 10
15 15
5 405
Cerritos
Chino Hills
GlendoraArcadia
Tustin
La Habra
Jurupa Valley
Rancho
Cucamonga
Anaheim
West Covina
Fontana
Norwalk
Fullerton
OntarioPomona
Corona
Santa Ana
El Monte
Orange
5688 ft
4620 ft
5 O r a nge
Rancho Santa
Margarita
Laguna Beach
San Clemente
Lake Forest
Fountain Valley
Laguna Niguel
Mission Viejo
Huntington
Beach Costa Mesa
Irvine
173
215
Grand Terrace
Crestline
Rialto
San Bernar
Riverside
Lakeland Village
Wildomar
Lake Elsinore
City of Fullerton Boundary
Project Site
Fullerton
Figure 1: Regional Map
Source: 2025Source: ESRI, ESRI, 2025
PlacentiaPlacentia
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Not to scale.
Source:
Cedarwoods Fullerton Project
Figure 2: Vicinity Map
Source: 2025Source: Nearmaps, Nearmaps, 2025
Project Site
EAveE Orangethorpe Orangethorpe Ave
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Not to scale. Cedarwoods Fullerton Project
Figure 3: Existing On- Site Conditions
O R A N G E T H O R P E A V E N U E
ARCHITECTURAL
PHOTOGRAPHS OF THE SITE
05N. T.S. DRC-A1. 1PHOTOGRAPHS SCALE OF THE SITE
CHECKED
SHEET TITLE
SHEET NUMBER
JOB No.
DRAWN
24-059
No. ISSUANCE DATE
STEVE HONG
CONSULTANTS
S T E V E K H O N G A R C H I T E C T
STEVE HONG
4 0 0 0 W E S T E R L Y P L A C E S U I T 1 0 0
N E W P O R T B E A C H C A L I F O R N I A 9 2 6 6 0
PROJECT MANAGER: STEVE HONG
714 - 822 - 1171, STEVE@SKHARCHITECT. COM
CIVIL ENGINEER
LANDSCAPE ARCHITECT
PACIFIC CONSULTING GROUP, INC.
COSTA MESA, CATEL: 818- 800- 6991EMAIL: KYLE@PACIFICCONSULTINGINC. COMATTN: KYLE PROUTY RODARTE LANDSCAPE ARCHITECTURE, INC.
740 13TH. SUITE 320
SAN DIEGO, CA 92101
TEL: 909- 771- 8171
EMAIL: LORENZO@RODARTELANDARCH. COM
ATTN: LORENZO RODARTE
L T C G G L L C
TRUENORTH
1 2
3 4
5 2
1 354
Source: SKH Architect, 2025
3 4
5 KimleyHorn
A
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18 Sh
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35 H
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3 A
l
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i
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al
Not to scale. Cedarwoods Fullerton Project
Figure 4: Existing Land Use Designation
Source: City of Fullerton - Go Zone, 2025
Project Site
Land Use Designation
Industrial (I)
Avejet
peemot? et‘
I
pve
1 • Rob!
f
192 ft
0/
J93ft
l
l
l
J
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i 5 /
3 o
5 v.
c
2 f
0 z
v)
woran9
1 Kimberly Ave
i1
oun"
I
Quality Inn
Placentia
Anaheim
Fullerton
E
Kimberly Ave
E Orangethorpe Ave
tn
w) Kimley>» Horn
Bur
t
P
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St a
t
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C
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v
d
S
t
a
t
e
C
o
l
le
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e
B
l
v
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Not to scale. Cedarwoods Fullerton Project
Figure 5: Existing Zoning Classifications
Source: City of Fullerton - Go Zone, 2025
Project Site
Zoning
Manufacturing Park
Manufacturing, General
Commercial Manufacturing
ES - Emergency Shelter Overlay
M-P-200
M-P-100
M-P-100ES
f 0
M-G
I
E Orangethorpe Ave
S
J
l
192fi
l •
I
193 ft
4 I
i
i/
I 0
RAILROAD
Kimberly Ave
t
out"
pvee
ora09" N
o
oAveRob
IP
w) Kimley»H
i
Quality Inn
Placentia
Anaheim
Fullerton
3 9
O1
2 etnot?
M-P-200ES
E Orangethorpe Ave
M-G ES'
OES
M-GES
RAILROAD
Kimberly Ave
M-GES
Bur
t
P
I
PA
S
b
o
e
i
s
s
k
St a
t
e
C
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r
S
t
St a
t
e
C
o
l
le
g
e
B
l
v
d
0 Not to scale. Cedarwoods Fullerton Project
Figure 6: Proposed Zoning Classification
Source: City of Fullerton - Go Zone, 2025
Project Site
Zoning
Manufacturing Park
Manufacturing, General
Commercial Manufacturing
ES - Emergency Shelter Overlay
M-P-100ES
E Orangethorpe Ave
M-P-200
M-P-100
f 0
M-G
AveRob
I t
I
193 ft
s
1 i
i
l
3 j s
1 0Is
192 ft
RAILROAD
Kimberly Ave
out"
3 9
O
O
pvee
ora09"
N
O
O
IP
Quality Inn
Placentia
Anaheim
Fullerton
2 etnot?
M-P-200ES
E Orangethorpe Ave
M-G ES'
OES
M-GES
RAILROAD
Kimberly Ave
M-GES
w Kimley>» Horn
Bur
t
P
I
PA
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b
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C
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B
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1 Not to scale.
Source: SKH Architect, 2025
Cedarwoods Fullerton Project
Figure 7: Conceptual Site Plan
EV CAP
EVC
S
EV CHA RG
ING
ONL Y
EVC
S
EVC
S
EV CAP
EV CAP
EV CAP
EV CAP
EV CAP
EV CAP
EVCAP
EVCAP
EVCAP
EVCAP
EVCAP
EVCAP
EVC
S
COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT 6'-0" 6'-0" 10@8'= 80'- 0" 6'-0" 10@8'= 80'- 0" 6@8'= 48'- 0" 6@8'-6"=51'-0" 6'-
0 4@
8 6
3 4
0 27@
8 6
2 2
9 6
20'-
0 7@
8 6
5 9
6 6'-
0 5@
8 6
4 2
6 4'-
0 45'-
1 0
23'-
8 40'-
0 6'-
0 6@
8 6
5 1
0 26'-
0 31'-
1 1
48'-
0 11"
503
0 21'-
2 50'-
0 55'-
6 56'-
0 56'-
0 56'-
0 56'-
0 56'-
0 56'-
0 56'-
0 55'-
6 6'-
0 26'-
0 16'-
0 POTENTIAL
OFFICE
19'-0"
26'-0"
DRIVEWAY
40'-0"
DRIVEWAY
57'-6"
15 D
O
C
K
D
O
O
R
S
TYP. TYP.
TYP. TYP.
TYP.
TYP.
TYP.
TYP.
25'-6"
8'H WI FENCE
20'-0"
8'H WI FENCE
25'-6"
8' H WI FENCE
20'- 0"
8' H WI FENCE
139
1 0
8'
H
W
I
F
E
N
C
E
TYP. TYP. TYP.
TYP. TYP.
TYP.
TYP.
TYP.
TYP. TYP.
TYP. TYP.
TYP.
TYP.
TYP.
TYP.
TYP.
TYP.
TYP.
TYP.
TYP.
TYP.
TYP.
TYP. TYP.
26'
W
ID
E
F
IR
E
L
A
N
E
26'
W
ID
E
F
IR
E
L
A
N
E
26' WIDE FIRE LANE
C Y P R E S S W A Y
O R A N G E T H O R P E A V E N U E
POTENTIALOFFICE
TYP.
PROPERTY LINE
PROPERTY LINE
PRO
P
E
R
T
Y
L
IN
E
PRO
P
E
R
T
Y
L
IN
E
40'-0"
329'- 7"
573
0 369'- 0"
470
7 29'-
2 101
6 6'-6"
139
4 RET
A
IN
IN
G
W
A
L
L
W
WI F
E
N
C
E
TYP.
59'-
7 43'-
5 88'-
6 RET
A
IN
IN
G
W
A
L
L
TYP. TYP.
TELESC. GATE, TYP.
175'- 0"
8'H WI FENCE
528
7 8' H
W
I
F
E
N
C
E
TYP.
TYP.
TYP.
TYP. TYP.
3@
8 6
2 5
6 43'-
0 19'- 0"
143'-0" 186'-0"
66'- 0" 60'- 0" 60'- 0"
34'-0" 6'-0"
6" 19'- 0" 123'- 6" 8'- 0" 26'- 0"
3@8'- 6"= 25'- 6" 34'-4" 6'-6"
SWING GATE, TYP.
43'-
11 19'-0" 40'-0" 19'-0" 6'-6" 57'-6"
24'-
1 154'- 2"
TYP.
TYP.
TYP.
64'-
0 DRI V
E
W
A
Y
R20
0 R20
0 R10
0 R9'-
0 ARCHITECTURAL
OVERALL SITE PLAN
011" 30'-0" DRC- A1. 1OVERALL SCALE SITE PLAN
CHECKED
SHEET TITLE
SHEET NUMBER
JOB No.
DRAWN
24- 059
No. ISSUANCE DATE
STEVE HONG
CONSULTANTS
S T E V E K H O N G A R C H I T E C T
STEVE HONG
0N4 0 0 0 W E S T E R L Y P L A C E S U I T 1 0E W P O R T B E A C H C A L I F O R N I A 9 2 6 6 0 PROJECT MANAGER: STEVE HONG
714 - 822 - 1171, STEVE@SKHARCHITECT. COM
CIVIL ENGINEER
LANDSCAPE ARCHITECT
PACIFIC CONSULTING GROUP, INC.
COSTA MESA, CATEL: 818- 800- 6991
EMAIL: KYLE@PACIFICCONSULTINGINC. COM
ATTN: KYLE PROUTY
RODARTE LANDSCAPE ARCHITECTURE, INC.
740 13TH. SUITE 320SAN DIEGO, CA 92101
TEL: 909- 771- 8171
EMAIL: COMATTN: LORENZO@RODARTELANDARCH.
LORENZO RODARTE
L T C G G L L C
GENERAL NOTES
CIVIL1 SITE PAVING WITH HEAVY BROOM FINISH. SEE
KEYNOTES
DECORATIVE PAVEMENT AT ENTRY - COLORED CONCRETE W/
PATTERN2 SAW CUT
BUILDING3 PRIMARY
FINISH4 PEDESTRIAN CONCRETE WALKWAY WITH MEDIUM BROOM
5 RETAINING WALL.
6 8' H WROUGHT IRON FENCE.
8'PADLOCK. H BLACK PAINTED VEHICULAR ROLLING GATE WITH KNOX MANUALLY OPERATED. PROVIDE CONDUITS FOR FUTURE
OPERATOR
7 5'- 6" X 6' X 4" THICK CONCRETE LANDING PAD AT ALL EXTERIOR MANDOORS WITH MEDIUM BROOM FINISH.
8 USED9 NOT
USED10 NOT
ENCLOSURE11 TRASH
HOUSE12 PUMP
STAIR13 EXTERIOR CONCRETE
WITHBOLLARD APPROXIMATE LOCATION OF ELEC. TRANSFORMER SCREENING14 PROTECTION AND LANDSCAPE 15 LEGEND
1. ALL DIMENSIONS ARE TO FACE OF CONCRETE WALL, FACE OF
CONCRETE CURB OR GRID LINES UNLESS NOTED OTHERWISE,
2. ENTIRE PROJECT SHALL BE PERMANENTLY MAINTAINED WITH A SMART AUTOMATIC IRRIGATION SYSTEM.
3. SEE CIVIL DRAWINGS FOR ADDITIONAL INFORMATION REGARDING SITE DRAINAGE, TOPOGRAPHY AND UTILITIES.
4. FOR PAVING SECTIONS, CONCRETE CURBS, SWALES AND GUTTERS SEE CIVIL DRAWINGS.
5. PROPERTY LINE ARE REFERENCE ONLY. REFER TO CIVIL DRAWINGS FOR HORIZONTAL CONTROL.
6. LANDSCAPE AREAS SHALL BE DELINEATED WITH A MIN. 6" CONCRETE CURB.
STANDARD PARKING STALL 8'- 6" X 19'
COMPACT PARKING STALL 8'- 0" X 16'
STALL16 SHORT TERM - BICYCLE RACK 5% OF PARKING
ENTRY17 DESIGNATED SMOKING AREA - 25' AWAY FROM ANY
ADA PARKING VAN 12' X 19' WITH 5' CLR AISLE
PROPERTY LINE
ACCESSIBLE PATH OF TRAVEL. MAX 5% SLOPE AND MAX 2%
CROSS SLOPE WITH 48" MIN. CLEAR, UNLESS NOTED OTHERWISE
WITH ADA ACCESSIBLE RAMP
LANDSCAPE, SEE LANDSCAPE DRAWINGS
APPLICANT/ OWNER
PROJECT ADDRESS / APN
LTCGG LLC.
13925 CITY CENTER DRIVE, SUITE 200CHINO HILLS, CA 91709 ANNIE@HKV. ONEATT: ANNIE TAVETIAN GALLAGHER
PROJECT DESCRIPTION
2461- 2495 E. ORANGETHORPE AVE.
FULLERTON, CA 92831APN: 338- 172- 24
NEW CONSTRUCTION FOR ( 1) SPECULATIVE 110, 232 SF TYPE III- B, S- 1/ B OCCUPANCY WAREHOUSE WITH ESFR FIRE SPRINKLER SYSTEM.
PROPOSED SITE IMPROVEMENTS CONSIST OF TRASH ENCLOSURE,
PUMP HOUSE, SITE LIGHTING STANDARDS, WROUGHT IRON FENCE AND HARDSCAPE/ LANDSCAPE IMPROVEMENTS PER CITY STANDARDSTOTAL OCCUPANT LOAD; WAREHOUSE ( S- 1): 201 AND OFFICE ( B): 40.
PROJECT DATA
VICINITY MAP
NOT USED.
E. ORANGETHOPE AVE
S.
S
T
A
T
E
C
O
L
L
E
G
E
B
L
V
D
S.
P
L
A
C
E
N
T
I
A
A
V
E
PROJECT SITE
CYPRESS WAY
VAN ( 12' X19') EVCS WITH ISA SIGN AND MARKING " EVCHARGING ONLY" WITH 5' ACCESSIBLE AISLE.EV CH
AR
G
IN
G
ONL
Y
STANDARD EVCS PARKING STALL 8'- 6" X 19' EVCS
EVCAP.
EVCS
STANDARD EV CAPABLE PARKING STALL 8'- 6" X 19'
CO
M
P
A
C
T
TRUENORTH
EV CAP
EVC
S
EV
CHA
R
G
IN
G
ONL
Y
EVC
S
EVC
S
EV CAP
EV CAP
EV CAP
EV CAP
EV CAP
EV CAP
EV CAP
EV CA
P
EV CAP
EV CAP
EV CAP
EV CA
P
EVC
S
COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT 6@8'-6"=51'-0" 6'-0" 10@8'=80'-0" 6'-0" 10@8'=80'-0" COMPACT6'- 0" 6@8'=48'-0" 6'-
0 4@
8 6
3 4
0 27@
8 6
2 2
9 6
20'-
0 7@
8 6
5 9
6 6'-
0 5@
8 6
4 2
6 4'-
0 45'-
1 0
23'-
8 40'-
0 6'-
0 6@
8 6
5 1
0 26'- 0"31'- 11" 48'- 11" 0
503
0 21'-
2 50'-
0 55'-
6 56'-
0 56'-
0 56'-
0 56'-
0 56'-
0 56'-
0 56'-
0 55'- 6- 26'- 0"6" 0 16'-
POTENTIAL
OFFICE
19'-0"
26'-0"
DRIVEWAY
40'-0"
DRIVEWAY
57'-6"
15 D
O
C
K
D
O
O
R
S
TYP. TYP.
TYP. TYP.
TYP.
TYP.
TYP.
TYP.
25'-6"
8'H WI FENCE
20'-0"
8'H WI FENCE
25'-6"
8'H WI FENCE
20'-0"
8'H WI FENCE
139
1 0
8' H
W
I
F
E
N
C
E
TYP. TYP. TYP.
TYP. TYP.
TYP.
TYP.
TYP.
TYP. TYP.
TYP. TYP.
TYP.
TYP.
TYP.
TYP.
TYP.
TYP.
TYP.
TYP.
TYP.
TYP.
TYP.
TYP. TYP.
26'
W
ID
E
F
IR
E
L
A
N
E
26'
W
ID
E
F
IR
E
L
A
N
E
LANEC26' WIDE FIRE YRESWPSA
O R A N G E T H O R P E A V E N U E
POTENTIALOFFICE
TYP.
PROPERTY LINE
PROPERTY LINE
PRO
P
E
R
T
Y
L
IN
E
PR
O
P
E
R
T
Y
L
IN
E
40'-0"
329'-7"
573
0 369'-0"
470
7 29'-2" 101'- 6"
6'-6"
139
4 RET
A
IN
IN
G
W
A
L
L
W
WI
F
E
N
C
E
TYP.
59'-
7 43'-
5 88'-
6 RET
A
IN
IN
G
W
A
L
L
TYP. TYP.
TELESC. GATE, TYP. 8'H 175'- WI FENCE 0"
528
7 8' H
W
I
F
E
N
C
E
TYP.
TYP.
TYP. TYP. TYP.
3@
8 6
2 5
6 43'-
0 19'-0"
143'-0" 186'-0"
66'-0" 60'-0" 60'-0"
34'-0" 6'-0"
6" 19'-0" 123'-6" 8'-0" 26'-0"
34'-4" 3@8'-6"=25'-6"6'-6"
SWING GATE, TYP.
43'-
1 1
19'-0" 40'-0" 19'-0" 6'-6" 57'-6"
24'-
1 64'-0" DRIVEWAY TYP. 154'-2"TYP. TYP.
R200 R20
0 R10
0 R9'
0 ARCHITECTURAL
OVERALL SITE PLAN
011" 30'- 0" DRC-A1. 1OVERALLSCALE SITE PLAN
CHECKED
SHEET TITLE
SHEET NUMBER
JOB No.
DRAWN
24-059
No. ISSUANCE DATE
STEVE HONG
CONSULTANTS
S T E V E K H O N G A R C H I T E C T
STEVE HONG
0N4E0WHONG714 - 0 0P O0PROJECT W822 - RETS1171, BT EEMANAGER: RASTEVE@SKHARCHITECT. LC YH CPALSTEVE LAICF EO R SN UI AI T9COM21606
CIVIL ENGINEER
LANDSCAPE ARCHITECT
PACIFIC CONSULTING GROUP, INC.
COSTA MESA, CA
TEL: 818- 800- 6991
EMAIL: KYLE@PACIFICCONSULTINGINC. COM
ATTN: KYLE PROUTY
RODARTE LANDSCAPE ARCHITECTURE, INC.
740 13TH. SUITE 320
SAN DIEGO, CA 92101
TEL: 909- 771- 8171
EMAIL: LORENZO@RODARTELANDARCH. COM
ATTN: LORENZO RODARTE
L T C G G L L C
GENERAL NOTES
CIVIL1 SITE PAVING WITH HEAVY BROOM FINISH. SEE
KEYNOTES
DECORATIVE PAVEMENT AT ENTRY - COLORED CONCRETE W/
PATTERN2 SAW CUT
BUILDING3 PRIMARY
FINISH4 PEDESTRIAN CONCRETE WALKWAY WITH MEDIUM BROOM
5 RETAINING WALL.
6 8'H WROUGHT IRON FENCE.
8'H BLACK PAINTED VEHICULAR ROLLING GATE WITH KNOX PAD
LOCK. MANUALLY OPERATED. PROVIDE CONDUITS FOR FUTURE
OPERATOR
7 5'- 6" X 6' X 4" THICK CONCRETE LANDING PAD AT ALL EXTERIOR MANDOORS WITH MEDIUM BROOM FINISH. 8
USED9 NOT
USED10 NOT
ENCLOSURE11 TRASH
HOUSE12 PUMP
STAIR13 EXTERIOR CONCRETE
APPROXIMATE LOCATION OF ELEC. TRANSFORMER WITH SCREENING14 BOLLARD PROTECTION AND LANDSCAPE 15 LEGEND
1. ALL DIMENSIONS ARE TO FACE OF CONCRETE WALL, FACE OF
CONCRETE CURB OR GRID LINES UNLESS NOTED OTHERWISE,
2. ENTIRE PROJECT SHALL BE PERMANENTLY MAINTAINED WITH A SMART AUTOMATIC IRRIGATION SYSTEM.
3. SEE CIVIL DRAWINGS FOR ADDITIONAL INFORMATION REGARDING SITE DRAINAGE, TOPOGRAPHY AND UTILITIES.
4. FOR PAVING SECTIONS, CONCRETE CURBS, SWALES AND GUTTERS SEE CIVIL DRAWINGS.
5. PROPERTY LINE ARE REFERENCE ONLY. REFER TO CIVIL DRAWINGS FOR HORIZONTAL CONTROL.
6. LANDSCAPE AREAS SHALL BE DELINEATED WITH A MIN. 6" CONCRETE CURB.
STANDARD PARKING STALL 8'- 6" X 19'
COMPACT PARKING STALL 8'-0" X 16'
STALL16 SHORT TERM - BICYCLE RACK 5% OF PARKING
ENTRY17 DESIGNATED SMOKING AREA - 25' AWAY FROM ANY
ADA PARKING VAN 12' X 19' WITH 5' CLR AISLE
PROPERTY LINE
ACCESSIBLE PATH OF TRAVEL. MAX 5% SLOPE AND MAX 2%
CROSS SLOPE WITH 48" MIN. CLEAR, UNLESS NOTED OTHERWISE
WITH ADA ACCESSIBLE RAMP
LANDSCAPE, SEE LANDSCAPE DRAWINGS
OWNERPROJECT APPLICANT/ APNLTCGG ADDRESS / 13925 200CHINO 91709ANNIE@HKV. ONEATT: ANNIE CITY HILLS, LLC. CENTER TAVTIAN CA DRIVE, SUITE GALLAGHERPROJECT DESCRIPTION2461- FULLERTON, 92831APN: 2495 338-172- E. ORANGETHORPE CA24 AVE.
NEW CONSTRUCTION FOR (1) SPECULATIVE 110,232 SF TYPE III-B, S-1/B OCCUPANCY WAREHOUSE WITH ESFR FIRE SPRINKLER SYSTEM.
PROPOSED SITE IMPROVEMENTS CONSIST OF TRASH ENCLOSURE,
PUMP HOUSE, SITE LIGHTING STANDARDS, WROUGHT IRON FENCE
AND HARDSCAPE/ LANDSCAPE IMPROVEMENTS PER CITY STANDARDS TOTAL OCCUPANT LOAD; WAREHOUSE (S-1): 201 AND OFFICE (B): 40.
PROJECT DATA
VICINITY MAP
NOT USED.
E. ORANGETHOPE AVES. STATE COLLEGE BLVD SITECYPRESS WAY S. PLACENTIA AVEPROJECT VAN ( 12' X19') EVCS WITH ISA SIGN AND MARKING " EV
CHARGING ONLY" WITH 5' ACCESSIBLE AISLE.
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STANDARD EVCS PARKING STALL 8'-6" X 19' EVCS
EVCAP.
EVCS
STANDARD EV CAPABLE PARKING STALL 8'-6" X 19'
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Not to scale.
Source: SKH Architect, 2025
Cedarwoods Fullerton Project
Figure 8: Conceptual Elevations
EAST ELEVATION
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FITZGERALD FORMLINERS. 16021
PAINTED W/ SW 7076 CYBERSPACE
PAINTED CONCRETE SHERVN- MLLIAMS
SW2819 DOWNING SLATE
PAINTED CONCRETE SHERWNWLLIAMS
SW 7005 PURE WHITE
PAINTED CONCRETE SHERWN- MLLIAMS
SW7076 CYBERSPACE
CANOPY: REYNOBONDACM DURAGLOSS 5000
PROGRAM WHITE
GLAZING LEGEND
TEMPERED VISION GLASS
TEMPERED CONCRETE BACKED SPANDREL GLASS
COLOR / FINISH LEGEND
WAREHOUSE GLAZING AREA:
SINGLE PANE 2 VITROGLAZING VISTALCOOL PACIFICA.
OFFICE / POTENTIAL OFFICE AREAS:
VITROGLAZING, MISTACOOL ( 2) PACIFICA + SOLARBAN 60 ( 3) VLT: 26, SHGC: 0.17, U VALUE: 0.29
1" INSULATED UNIT MTH2" AIRSPACE AND ( 2)1" UNITS
GENERAL NOTES
2. ALL PAINT FINISHES ARE TO BE FLAT UNLESS NOTED OTHERMSE.
3. 5.
6. USE ADHESIVE BACK WOOD STRIPS FOR ALL REVEAL FORMS.
9. 12.
KEYNOTES
CONTRACTOR TO PROVIDE MOCK UP PAINT FOR OWNER AND
ARCHITECT’ S APPROVAL PRIOR TO COMMENCING THE WORK.
ALL EXTERIOR DOORS AND LOUVERS SHALL BE FABRICATED AND
WEATHER STRIPPED TO MITHSTAND VIND EXPOSURE " C"
FOR SPANDREL GLAZING, ALLOW SPACE BEHIND SPANDREL TO
BREATH BY PROVIDING A MINIMUM 2" DIAMETER HOLE ON THE
CORNER.
STOREFRONT CONSTRUCTION: GLASS, METAL ATTACHMENTS AND
LINTELS SHALL BE DESIGNED TO RESIST WIND EXPOSURE " C"
MINDS. CONTRACTOR SHALL SUBMIT SHOP DRAWINGS PRIOR TO
INSTALLATION.
WATER BLAST EXTERIOR FACE OF BUILDING WALLS PRIOR TO
PAINT.
ALL CONCRETE PANEL JOINTS SHALL BE CLEARED OF DEBRIS BY
PRESSURING WASHING THE CAVITY AND GRIND ANY SHARP EDGES PRIOR TO APPLY PANEL CAULK JOINT.
ALL PAINT COLOR CHANGES TO OCCUR AT INSIDE CORNERS
UNLESS NOTED OTHERWISE.
CONTRACTOR SHALL FULL PAINT ONE CONCRETE PANEL MITH
SELECTED COLORS. ARCHITECT AND OWNER SHALL APPROVE
PRIOR TO PAINT REMAINDER OF BUILDING.
FIRST COAT OF PAINT TO BE ROLLED- ON AND THE SECOND COAT TO BE SPRAYED ON.
BACK SIDE OF PARAPETS TO HAVE SMOOTH FINISH AND BE PAINTED MTH ELASTOMERIC PAINT.
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Source: Rodarte Landscape Architecture, 2025.
Figure 9: Conceptual Landscape Plan
Cedarwoods Fullerton Warehouse Project
9191
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SYMBOL TREE NAME QTY. WUCOLS
CHILOPSIS LINEARIS, DESERT WILLOW
24" BOX SIZE. STANDARD TRUNK.
PARKING LOT SHADE TREE
RHUS LANCEA, AFRICAN SUMAC
24" BOX SIZE. STANDARD TRUNK.
EVERGREEN SCREEN TREE
PINUS ELDARICA, MONDELL PINE
24" BOX SIZE. STANDARD TRUNK.
OLEA E. , OLIE TREE
36" BOX SIZE. STANDARD TRUNK.
GROUND COVERS
SYMBOL NAME WUCOLS
M
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1 GAL. SIZE @ 36" O.c.
ROSMARINUS O. ‘ PROSTRATUS’, CREEPING ROSEMARY
1 GAL. SIZE @ 36" O.C.
DIANELLA TASMANICA ‘ VARIEGATA’, WHITE STRIPED TASMAN FLAX LILY 1 GAL. SIZE @ 24" O.C.
SALVIA GREGGII, AUTUMN SAGE
I GAL. SIZE @ 36" O. C.
LANTANA C. ‘ NEW GOLD’, GOLD SPREADING LANTANA
1 GAL . SIZE @ 36" O. C.
SALVIA LEUCANTHA, MEXICAN BUSH SAGE
1 GAL. SIZE @ 42" O. C.
MUHLENBERGIA RIGENS, DEER GRASS
1 GAL. SIZE @0 36" O.C.
HESPERALOE PARVIFLORA, RED YUCCA
1 GAL. SIZE @ 36" O.c.
LANTANA MONTEVIDENSIS, PURPLE LANTANA
1 GAL. SIZE @ 30" O. C.
CAREX DIVULSA, BERKELY SEDGE
1 GAL. SIZE @ 18" O. c.
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8 Not to scale. Cedarwoods Fullerton Project
Figure 10: Conceptual Utility Plan
Source: Pacific Consulting Group, 2025
EV CHA R
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COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT COMPACT 223
CO
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E:
PCG
JOB
DAT
SCA
SHE
SHE
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THE EXISTENCE AND LOCATION OF UNDERGROUND UTILITY PLANS
OR STRUCTURES SHOWN ON THESE PLANS WERE OBTAINED BY
A SEARCH OF AVAILABLE RECORDS AND MAY NOT REFLECT ALL
EXISTING UTILITIES. THE CONTRACTOR SHALL TAKE DUE
PRECAUTIONS OF THE RECORDED UTILITIES AS WELL AS ANY NOT
SHOWN AND SHALL CONFIRM ALL ALIGNMENTS AND GRADES BY
FIELD INVESTIGATIONS. THE CONTRACTOR IS REQUIRED TO TAKE
ALL PRECAUTIONARY MEASURES TO PROTECT THE UTILITIES
SHOWN, AND IS RESPONSIBLE FOR THE PROTECTION OF, AND
ANY DAMAGE TO THESE LINES OR STRUCTURES.
UNDERGROUND UTILITIES &
STRUCTURES
COORDINATION POINT
BACKFLOW ASSEMBLY
WATER METER VAULT
FIRE DEPARTMENT CONNECTION ( FDC)
FIRE WATER PIPE
IRRIGATION WATER
IR2) INSTALL 2" SCHEDULE 40 PVC WATER SIZE PIPE.TO BE CONFIRMED.
ELECTRICAL
PROPOSED TRANSFORMER AND SWITCHGEAR. SEE ELECTRICAL PLANS.
NOTES:
w) KimleyHorn
BACKFLOW PREVENTORS SHOWN HEREON, ARE FOR COORDINATION PURPOSES ONLY.
THE CONTRACTOR AGREES THAT HE SHALL ASSUME SOLE AND
COMPLETE RESPONSIBILITY FOR JOB SITE CONDITIONS DURING
THE COURSE OF CONSTRUCTION OF THIS PROJECT, INCLUDING
SAFETY OF ALL PERSONS AND PROPERTY: THAT THIS
REQUIREMENT SHALL APPLY CONTINUOUSLY AND NOT BE LIMITED TO NORMAL WORKING HOURS; AND THAT THE CONTRACTOR
SHALL DEFEND, INDEMNIFY, AND HOLD THE OWNER AND THE
ENGINEER HARMLESS FROM ANY AND ALL LIBAILITY, REALL OR
ALLEGED, IN CONNECTION WITH THE PERFORMANCE OF WORK ON
THIS PROJECT, EXCEPTING FOR LIABILITY ARISING FROM THE
SOLE NEGLIGENCE OF THE OWNER OR THE ENGINEER.
CAUTION: THE ENGINEER PREPARING THESE PLANS WILL NOT BE
RESPONSIBLE FOR, OR UABLE FOR, UNAUTHORIZED CHANGES OR
USES OF THESE PLANS. ALL CHANGES TO THE PLANS MUST BE
IN WRITING AND MUST BE APPROVED BY THE PREPARER OF
THESE PLANS.
ENGINEER’S NOTICE TO CONTRACTOR
IR3) INSTALL APPROVED 2" REDUCED PRESSURE BACKFLOW PREVENTOR.
SEE PLUMBING PLANS FOR DETAILS. SIZE TO BE CONFIRMED.
IR4) POINT OF CONNECTION TO IRRIGATION SYSTEM. SEE IRRIGATION PLANS FOR CONTINUATION, DETAIL AND SPECIFICATION.
3. SERVICE LATERALS SHALL BE INSTALLED PER CITY OF FULLERTON STANDARD PLAN 701.
4. SEE SHEET C010 FOR KNOWN EXISTING UTILITIES WITHIN SITE. SHOWN EXISTING UTILITIES ARE BASED UPON AVAILABLE RECORDS.
2. ALL STREET TRENCHES REQUIRED FOR THE INSTALLATION OF UTILITY CONNECTIONS SHALL COMPLY WITH CITY OF FULLERTON STANDARDS NO. 312 AND 313.
IR1) 2” IRRIGATION WATER METER PER CITY OF FULLERTON STD. DETAIL 602. . CONTRACTOR TO COORDINATE WATER SERVICE CONNECTION WITH JHA. SIZE TO BE CONFIRMED.
STORM DRAIN SHOWN FOR REFERENCE
WATER PIPE
ss--------- SANITARY SEWER PIPE FIRE WATER
DEMOLITION OF EXISTING UTILITY CONTRACTOR TO ORDER AND COORDINATE NEW FIRE WATER SERVICE CONNECTION FROM JHA.
W7) INSTALL 8" DOMESTIC WATER MAIN. SEE CITY OF FULLERTON STANDARD PLAN 600 & 701.
NOTESLEGEND CONSTRUCTION
SEWERLANDSCAPE AREA BY OTHERS SANITARY
PEDESTRIAN CONCRETE
ASTROTURF
PERMEABLE PAVEMENT BY OTHERS
RETAINING WALL
PROPERTY LINE
GRADE BREAK
RIDGE LINE
FLOW LINE
DOMESTIC WATER
CATCH BASIN
AREA DRAIN
GARDEN WALL ( W2) 3" DOMESTIC WATER METER PER CITY OF FULLERTON STANDARD PLAN WITHPOINT 603. CONTRACTOR TO COORDINATE WATER SERVICE CONNECTION OF CONNECTION JHA. SIZE TO BE CONFIRMED.
POSSIBLE NEW SEWER LATERAL HOUSE CONNECTION. NEW HOUSE
CONNECTION TO BE COORDINATED WITH THE CITY OF PLACENTIA AND INSTALLED PER CITY OF PLACENTIA STANDARDS AND REQUIREMENTS.
INSTALL 6” PVC, SDR-35 SANITARY SEWER PIPE. MIN. SLOPE = 2%.
SIZE TO BE VERIFIED
POINT OF CONNECTION 5‘ OUTSIDE BUILDING ENVELOPE. SEE PLUMBING DRAWINGS FOR CONTINUATION.
CONTRACTOR TO ORDER AND COORDINATE NEW DOMESTIC WATER
SERVICE CONNECTION FROM JHA
CONTRACTOR TO LOCATE AND CONNECT TO EXISTING SEWER LATERAL.
IF UNAVAILABLE OR INSUFFICIENT SIZE, INSTALL HOUSE CONNECTION PER CITY OF FULLERTON STD PLAN NO. 209A & 209B.
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Cedarwoods Fullerton Project
Initial Study/ Mitigated Negative Declaration
3.0 INITIAL STUDY CHECKLIST
1. Project title:
Cedarwoods Fullerton Project
2. Lead agency name and address:
City of Fullerton
303 West Commonwealth Avenue
Fullerton, California 92832
3. Contact person and phone number:
David Lopez, Senior Planner
Community and Economic Development Department
714) 738-6878
david.lopez@cityoffullerton. com
4. Project location:
The Project would be located at 2461- 2495 East Orangethorpe Avenue, Fullerton, CA 92838. The approximately 4.79-acre project site includes one parcel described as APN 338-172-24.
5. Project sponsor' s name and address:
LTCGG LLC
Attn: Annie Gallagher
13925 City Center Drive, Suite 200
Chino Hills, CA 91709
6. General Plan designation:
Industrial (I)
7. Zoning:
Manufacturing Park with a 100,000 square- foot minimum lot size and an Emergency Shelter Overlay ( MP-100-ES)
Commercial Manufacturing with an Emergency Shelter Overlay (CM-ES)
8. Description of project:
See Section 2.3: Project Characteristics.
9. Surrounding land uses and setting:
See Section 2.1: Project Location and Setting.
10. Other public agencies whose approval is required ( e.g., permits, financing approval, or participation agreement).
Santa Ana Regional Water Quality Control Board
City of Placentia
11. Have California Native American tribes traditionally and culturally affiliated with the project area requested consultation pursuant to Public Resources Code section 21080. 3.1? If so, is there a plan for consultation that includes, for example, the determination of significance of impacts to tribal cultural resources, procedures regarding confidentiality, etc.? Refer to Section 4.18: Tribal Cultural Resources for details.
O
urore”
o"UL4
Cedarwoods Fullerton Project
Initial Study/ Mitigated Negative Declaration
NOTE: Conducting consultation early in the CEQA process allows tribal governments, lead agencies, and project proponents to discuss the level of environmental review, identify and address potential adverse impacts to tribal cultural resources, and reduce the potential for delay and conflict in the environmental review process. ( See Public Resources Code section 21080.3.2.) Information may also be available from the California Native American Heritage Commission’ s Sacred Lands File per Public Resources Code section 5097.96 and the California Historical Resources Information System administered by the California Office of Historic Preservation. Please also note that Public Resources Code section 21082.3(c) contains provisions specific to confidentiality.
O
urore”
o"UL4
Cedarwoods Fullerton Project
Initial Study/ Mitigated Negative Declaration
3.1 Environmental Factors Potentially Affected
The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a “ Potentially Significant Impact” as indicated by the checklist on the following pages.
All impacts can be mitigated to a less than significant level.
Aesthetics
Air Quality
Agricultural and Forestry
Resources
Biological Resources
Cultural Resources
Energy
Geology/ Soils
Greenhouse Gas Emissions
Hazards & Hazardous
Materials
Hydrology/ Water Quality
Land Use/ Planning
Mineral Resources
Noise
Population/ Housing
Public Services
Recreation
Transportation
Tribal Cultural Resources
Utilities/ Service Systems
Wildfire
Mandatory Findings of
Significance
DETERMINA TION:
On the basis of this initial evaluation ( check one):
I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.
I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.
I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.
I find that the proposed project MAY have a " potentially significant impact" or " potentially significant unless mitigated" impact on the environment, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.
I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects ( a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIV E DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required.
CERTIFICATION:
Signature
11/ 5/ 2025
Date
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4.0 ENVIRONMENTAL EVALUATION
4.1 AESTHETICS
ENVIRONMENTAL IMPACTS
Potentially
Significant
Issues
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
1. AESTHETICS. Except as provided in Public Resources Code Section 21099, would the project:
a) Have a substantial adverse effect on a scenic vista? X b) Substantially damage scenic resources, including but not limited to trees, rock outcroppings, and historic buildings within a State scenic highway?
X
c) In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? ( Public views are those that are
experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing
scenic quality?
X
d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area? X
a) Have a substantial adverse effect on a scenic vista? No Impact. There are no scenic vistas that are visible from the project site. A scenic vista is defined as a viewpoint that provides expansive views of a highly valued landscape for the public’ s benefit.
Scenic vistas within the City include views of the West and East Coyote Hills, which are located approximately 8.1 miles northwest and 3.1 miles north of the project site respectively. 4 Views of the Coyote Hills are obstructed by existing nearby development and are not visible from the project site. Therefore, Project implementation would not have an adverse effect on a scenic vista. No impacts would occur, and no mitigation is required.
b) Substantially damage scenic resources, including but not limited to trees, rock outcroppings, and historic buildings within a State scenic highway?
No Impact. According to the California Department of Transportation ( Caltrans) State Scenic Highway System Map, there are no officially designated scenic highways within the City or near the project site. 5 The closest eligible scenic highway near the project site is SR- 57, approximately 10 miles to the north, and the closest officially designated scenic highway is SR-91 starting at the intersection of SR 55 and SR-91, approximately 6 miles to the east. The Project would not be visible 4 City of Fullerton. ( 2012). The Fullerton Plan - Final Program EIR, Section 5.3 Aesthetics and Light/ Glare. Retrieved from:
https:// www.cityoffullerton.com/home/ showpublisheddocument/ 3700/ 637470826653170000. Accessed September 10, 2025. 5 California Department of Transportation. ( 2019). California State Scenic Highway Map. Retrieved from https:// caltrans.maps.arcgis.com/ apps/ webappviewer/ index.html?id=465dfd3d807c46cc8e8057116f1aacaa. Accessed on September 10, 2025.
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from any State scenic highway. The City has identified scenic corridors for special planning consideration, as well as Scenic Corridor Design Guidelines in order to provide a series of special controls for land improvements fronting these rights-of-way. The project site is not located on a City-designated scenic corridor. Therefore, the Project would not damage scenic resources and no impact would occur.
c) If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
Less than Significant Impact. The project site is located within an urbanized area of Fullerton and is bordered by existing industrial, warehouse, and retail uses. The project site is located within the Southeast Industrial Focus Area, which is envisioned to be characterized by preserved industrial and employment- generating uses and to undergo moderate to significant change through infill, reuse, revitalization, and redevelopment by The Fullerton Plan. The Project proposes to remove the existing on-site structures and construct a new industrial building, consistent with the vision of The Fullerton Plan and the existing land use and zoning for the project site. The Project would be subject to the requirements of FMC Chapter 15.40, Industrial Zone Classifications, which addresses permitted and prohibited development intended to provide for industrial uses. The Project would also be subject to FMC Section 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; refer to Section 4.11: Land Use and Planning.
As part of the City’ s Site Plan Review process required under FMC Chapter 15.47, Site Plan Review, the Project’ s 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. Criteria used for review of a site plan includes: creating a development that is pleasant in character and is harmonious with the past development of Fullerton; minimizing the disruption of existing natural features such as trees and other vegetation and natural ground forms; illustrating a design compatibility with the desired developing character of the surrounding area; recognizing views, climate and the nature of outside activities in the design of exterior spaces; preserving public views and scenic vistas from unreasonable encroachment; screening exterior trash and storage areas and service yards from view of nearby streets and adjacent structures in a manner that is compatible with building site design; designing and/ or screening all rooftop mechanical and electrical equipment as an integral part of the building design; designing landscaping to create a pleasing appearance from both within and off the site; and providing landscaping adjacent to and within parking areas in order to screen vehicles from view and minimize the expansive appearance of parking areas ( FMC Section 15.47.060, Design Review Criteria).
Consistent with FMC Section 15.40.040, the Project would be set back over 20 feet from Orangethorpe Avenue, providing visual relief from public view. Additionally, the project would provide a total of 19,109 square feet of landscaping, including ground cover, shrubs, and trees focused near parking lot areas, the warehouse, site perimeter, and driveway entries (see Figure 9:
Conceptual Landscape Plan) to create a visually pleasing exterior and screen views of the warehouse, specifically trash and storage areas, parking lots, and the truck court, from public view.
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The warehouse would also have a maximum roof line of approximately 44 feet which be compatible with the existing scenic character of surrounding buildings and would screen all rooftop mechanical and electrical equipment. These project characteristics align with the desired development characteristics of the surrounding area and align with FMC Section 15.40.040.
Therefore, the Project would not conflict with applicable zoning and other regulations governing scenic quality and no impact would occur.
d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Less Than Significant Impact. The project site is developed with a business park and is bordered by industrial, warehouse, and retail uses and therefore, currently experiences lighting typical of a developed and urbanized area ( security and landscape lighting, automobile headlights, potential glare from glass surfaces, etc.).
Glare is created by the reflection of sunlight and electric lights from windows and building surfaces.
Daytime glare is generally caused by the reflection of sunlight from highly reflective surfaces at or above eye level. Reflective surfaces are typically associated with buildings constructed with broad expanses of highly polished surfaces or broad, light-colored areas of paving. Daytime glare is usually present during early morning and late afternoon hours when the sun is at a low angle and the potential exists for intense reflected light to interfere with vision and driving conditions.
Daytime glare may also hinder outdoor activities performed within surrounding land uses.
Nighttime glare includes direct, intense, focused light, along with reflected light. Glare generated by direct light typically comes from mobile sources ( e.g., automobiles). Glare is also less frequently caused by intense stationary sources, such as floodlights or cargo crane lights. As with daytime sun glare, intense nighttime light may cause undesirable interference with driving or other activities.
The Project would remove the existing on-site structures and construct a new warehouse building.
No nighttime construction is proposed and construction activities would be subject to FMC Section
15.90.050, which restricts construction activities to between the hours of 7:00 AM and 8:00 PM Monday through Saturday. Therefore, the proposed project would not require construction lighting, except for security and safety lighting.
When the proposed Project is operational, it would generate light from two primary sources:
interior building lighting and exterior lighting ( e.g., signage, parking area lighting, security lighting, and landscape lighting), which would be similar to existing conditions and typical of warehouse uses. With respect to the warehouse structure, the exterior elevations would be white and grey with blue window glazing ( Figure 8: Conceptual Elevations). The Project would be required to comply with the California Code of Regulations ( CCR) Title 24 standards which would require all glass used in the building design to have minimal reflectivity to reduce glare to surrounding neighbors. Buildings with large facades constructed of reflective surfaces ( e.g., brightly colored building facades, metal surfaces, and reflective glass) could increase existing levels of daytime glare. The Project’ s proposed design does not include such surfaces or components.
Access to the project site would continue to occur from the two existing driveways along 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. Therefore, the Project would not introduce new conditions related to headlights from vehicles and trucks exiting the site.
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All lighting installed would be subject to compliance with the provisions of the FMC, which includes standards for the provision of lighting in the various non-residential zones. Specifically, FMC Section 15.56.110, Illumination of Premises, requires lighting within parking areas to be arranged so as to reflect the light and glare away from adjacent properties. FMC Section 15.40.080.F requires all on-site lighting within industrial zones to limit glare/ spillover onto adjacent properties with a residential zone classification; it is noted that residentially zoned properties are not located adjacent to the project site. Additionally, the proposed development would undergo site plan review to ensure compliance with the development standards of the M-P zoning district.
Therefore, compliance with the FMC provisions specific to lighting would ensure proper design, installation, and operation of all exterior lighting, thereby reducing the potential for glare effects, light spillover onto adjacent properties, or conflicts with adjacent land uses. Therefore, compliance with the City’ s established regulatory framework, which would be verified through the City’ s plan review process, would ensure potential impacts associated with proposed Project lighting and glare would be reduced to a less than significant impact.
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4.2 AGRICULTURE AND FORESTRY RESOURCES
ENVIRONMENTAL IMPACTS
Potentially
Significant
Issues
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
2. AGRICULTURE AND FORESTRY RESOURCES. In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Department of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the State’ s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project:
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance ( Farmland), as shown on the
maps prepared pursuant to the Farmland Mapping and
Monitoring Program of the California Resources Agency,
to non-agricultural use?
X
b) Conflict with existing zoning for agricultural use, or a Williamson Act contract?
X
c) Conflict with existing zoning for, or cause rezoning of, forest land ( as defined in Public Resources Code section 12220( g)), timberland ( as defined by Public Resources Code section 4526), or timberland zoned Timberland
Production ( as defined by Government Code section
51104( g))?
X
d) Result in the loss offorest land or conversion offorest land to non-forest use?
X
e) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of
forest land to non-forest use?
X
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance ( Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and MonitoringProgram of the California Resources Agency, to non-agricultural use?
No Impact. The project site is located in an urbanized area along the southern border of Fullerton and adjacent to the cities of Anaheim and Placentia. The project site is bordered by industrial uses to the north, East Orangethorpe Avenue to the south, and industrial and commercial uses to the east and west. There are no agricultural or forestry resources located on or near the project site.
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The project site is currently developed with a five-building multi-tenant business park. The State of California Department of Conservation Farmland Mapping and Monitoring Program ( FMMP) maps designate the project site as Urban and Built-Up Land6. Urban and Built-Up Land is defined as land developed at a density of at least one dwelling unit (du) per 1.5 acres, or approximately six structures to a 10-acre parcel. 7 Land uses include but are not limited to residential, industrial, office/ commercial, institutional, and public administration. There is no Prime Farmland, Unique Farmland, Farmland of Statewide Importance, or Farmland of Local Importance on the project site or in the vicinity of the project site.8 Additionally, no farmland would be converted. Therefore, the Project would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, and no impact would occur.
b) Conflict with existing zoning for agricultural use, or a Williamson Act contract? No Impact. A Williamson Act contract between local governments and private landowners restricts specified parcels of land to agricultural or related open space use in return for a lower property tax assessment. The project site is not under a Williamson Act contract. 8 According to Chapter 15.30 Commercial Zone Classifications of the FMC, the existing zoning district (C-M) for the project site does not allow for agricultural use without the approval of a conditional use permit (CUP). 9 A CUP has not been requested or required. Therefore, the proposed Project would not conflict with agricultural zoning designation or a Williamson contract, and no impact would occur. c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned TimberlandProduction (as definedby Government Code section 51104(g))? Or, d) Result in the loss of forest land or conversion of forest land to non-forest use? No Impact. The proposed Project would not conflict with existing zoning for forest land, timberland, or timberland production. The project site and surrounding areas are not zoned for forest land or timberland. 10 The existing zoning for the project site does not permit forest land, timberland, or timberland production. Therefore, the Project would not result in the loss of forest land or conversion of forest land to a non-forest use, and no impact would occur. e) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to nonforest use? No Impact. The project site and surrounding area do not include, nor are located proximate to, agricultural uses or forest lands. 13 Therefore, the Project would not directly or indirectly result in the conversion of property from agricultural or timberland uses, and no impact would occur. 6 California Department of Conservation. ( ND). California Important Farmland Finder. Retrieved from:
https:// maps.conservation.ca.gov/dlrp/ciff/. Accessed July 9, 2025. 7 California Department of Conservation. ( ND). Important Farmland Categories. Retrieved from:
https:// www.conservation. ca.gov/ dlrp/ fmmp/ Pages/ Important-Farmland-Categories.aspx. Accessed July 9, 2025. 8 California Department of Conservation. ( ND). California Williamson Act Enrollment Finder Map. Retrieved from:
https:// maps.conservation.ca.gov/agriculture/. Accessed July 9, 2025. 9 City of Fullerton. (2024). Municipal Code. Retrieved from: https:// codelibrary. amlegal. com/ codes/ fullerton/ latest/ fullerton_ca/ 0-0-0-30337.
Accessed July 10, 2025.
10 City of Fullerton. (2023). City of Fullerton Zoning Map Atlas. Retrieved from:
https:// www.cityoffullerton. com/ home/ showpublisheddocument/ 1542/ 637449029859970000. Accessed July 9, 2025.
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4.3 AIR QUALITY
ENVIRONMENTAL IMPACTS
Potentially
Significant
Issues
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
3. AIR QUALITY. Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations. Would the project:
a) Conflict with or obstruct implementation of the applicable air quality plan? X
b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or State ambient air quality standard?
X
c) Expose sensitive receptors to substantial pollutant
concentrations?
X
d) Result in other emissions ( such as those leading to odors adversely affecting a substantial number of people?
X
Air quality modeling outputs and results are included in Appendix A: Air Quality and Greenhouse Gas Emissions Data of this Initial Study.
Background
Climate and Topography
The California Air Resources Board ( CARB) divides the State into 15 air basins that share similar meteorological and topographical features. The project site is located within the South Coast Air Basin SCAB), which includes the non-desert portions of Los Angeles, Riverside, and San Bernardino counties, as well as all of Orange County. The SCAB is on a coastal plain with connecting broad valleys and low hills, bounded by the Pacific Ocean on the southwest and high mountains forming the remainder of the perimeter11. The SCAB’ s air quality is determined by natural factors such as topography, meteorology, and climate, in addition to the presence of existing air pollution sources and ambient conditions.
The SCAB is part of a semi- permanent high- pressure zone in the eastern Pacific. As a result, the climate is mild and tempered by cool sea breezes. This usually mild weather pattern is occasionally interrupted by periods of extreme heat, winter storms, and Santa Ana winds. The annual average temperature throughout the 6,645-square-mile SCAB ranges from low 60 to high 80 degrees Fahrenheit with little variance. With more oceanic influence, coastal areas show less variability in annual minimum and maximum temperatures than inland areas. Contrasting the steady pattern of temperature, rainfall is seasonally and annually highly variable. Almost all annual rainfall occurs between the months of 11 South Coast Air Quality Management District. (1993). CEQA Air Quality Handbook.
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November and April. Summer rainfall is reduced to widely scattered thundershowers near the coast, with slightly heavier activity in the east and over the mountains.
Although the SCAB has a semiarid climate, the air closer to the Earth’ s surface is typically moist because of the presence of a shallow marine layer. Except for occasional periods when dry, continental air is brought into the SCAB by offshore winds, the “ ocean effect” is dominant. Periods of heavy fog are frequent and low clouds known as high fog are characteristic climatic features, especially along the coast.
Annual average humidity is 70 percent at the coast and 57 percent in the eastern portions of the SCAB.
Wind patterns across the SCAB are characterized by westerly or southwesterly on-shore winds during the day and easterly or northeasterly breezes at night. Wind speed is typically higher during the dry summer months than during the rainy winter. Between periods of wind, air stagnation may occur in both the morning and evening hours. Air stagnation is one of the critical determinants of air quality conditions on any given day. During winter and fall, surface high- pressure systems over the SCAB, combined with other meteorological conditions, result in very strong, downslope Santa Ana winds. These winds normally continue for a few days before predominant meteorological conditions are reestablished.
The mountain ranges to the east affect the diffusion of pollutants by inhibiting the eastward transport of pollutants. The SCAB’ s air quality generally ranges from fair to poor and is like air quality in most of coastal Southern California. The entire region experiences heavy concentrations of air pollutants during prolonged periods of stable atmospheric conditions.
In addition to the characteristic wind patterns that affect the rate and orientation of horizontal pollutant transport, two distinct types of temperature inversions control the vertical depth through which air pollutants are mixed. These inversions are the marine inversion and the radiation inversion. The height of the base of the inversion at any given time is called the “mixing height.” The combination of winds and inversions is a critical determinant leading to highly degraded air quality for the SCAB in the summer and generally good air quality in the winter.
Air Pollutants of Concern
The air pollutants emitted into the ambient air by stationary and mobile sources are regulated by State and federal laws. These regulated air pollutants are known as “ criteria air pollutants” and are categorized into primary and secondary pollutants.
Primary air pollutants are emitted directly from a source and include carbon monoxide ( CO), reactive organic gases ( ROG), nitrogen oxide ( NOX), sulfur dioxide ( SO2), coarse particulate matter ( PM10), fine particulate matter (PM2.5), and lead. Of these primary pollutants, CO, NOX, SO2, PM10, and PM2.5 are criteria pollutants. ROG and NOX are criteria pollutant precursors and form secondary criteria pollutants through chemical and photochemical reactions in the atmosphere. For example, the criteria pollutant ozone ( O3) is formed by a chemical reaction between ROG and NOX in the presence of sunlight. The principal secondary pollutants are O3 and nitrogen dioxide ( NO2). Sources and health effects commonly associated with criteria pollutants are summarized in Table 4: Air Contaminants and Associated Public Health Concerns.
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Table 4: Air Contaminants and Associated Public Health Concerns Pollutant Major Man-Made Sources Human Health Effects
Particulate Matter
PM10 and PM2.5)
Power plants, steel mills, chemical
plants, unpaved roads and parking lots,
wood-burning stoves and fireplaces,
automobiles, and others.
Increased respiratory symptoms, such as
irritation of the airways, coughing, or difficulty
breathing; asthma; chronic bronchitis;
irregular heartbeat; nonfatal heart attacks;
and premature death in people with heart or
lung disease. Impairs visibility.
Ozone (O3) Formed by a chemical reaction between
reactive organic gases / volatile organic
compounds ( ROG or VOC) 1 and nitrogen
oxides ( NOX) in the presence of sunlight.
Motor vehicle exhaust, industrial
emissions, gasoline storage and
transport, solvents, paints, and landfills.
Irritates and causes inflammation of the
mucous membranes and lung airways; causes
wheezing, coughing, and pain when inhaling
deeply; decreases lung capacity; aggravates
lung and heart problems. Damages plants;
reduces crop yield.
Sulfur Dioxide
SO2)
A colorless gas formed when fuel
containing sulfur is burned and when
gasoline is extracted from oil. Examples
are petroleum refineries, cement
manufacturing, metal processing
facilities, locomotives, and ships.
Respiratory irritant. Aggravates lung and heart
problems. In the presence of moisture and
oxygen, sulfur dioxide converts to sulfuric acid,
which can damage marble, iron, and steel.
Damages crops and natural vegetation.
Impairs visibility. Precursor to acid rain.
Carbon Monoxide
CO)
An odorless, colorless gas formed when
carbon in fuel is not burned completely;
a component of motor vehicle exhaust.
Reduces the ability of blood to deliver oxygen
to vital tissues, affecting the cardiovascular
and nervous system. Impairs vision, causes
dizziness, and can lead to unconsciousness or
death.
Nitrogen Dioxide
NO2)
A reddish- brown gas formed during fuel
combustion for motor vehicles and
industrial sources. Sources include
motor vehicles, electric utilities, and
other sources that burn fuel.
Respiratory irritant; aggravates lung and heart
problems. Precursor to O3. Contributes to
global warming and nutrient overloading,
which deteriorates water quality. Causes
brown discoloration of the atmosphere.
1 Volatile Organic Compounds ( VOCs or Reactive Organic Gases [ ROG]) are hydrocarbons/ organic gases that are formed solely of hydrogen and carbon. There are several subsets of organic gases including ROGs and VOCs. Both ROGs and VOCs are emitted from the incomplete combustion of hydrocarbons or other carbon-based fuels. The major sources ofhydrocarbons are combustion engine exhaust, oil refineries, and oil-fueled power plants; other common sources are petroleum fuels, solvents, dry cleaning solutions, and paint (via evaporation).
Source: California Air Pollution Resources Board. (N.D.). Criteria Air Pollutants . Retrieved from: https:// www.epa.gov/ criteria-air-pollutants.
Accessed August 26, 2025.
Toxic Air Contaminants
Toxic air contaminants ( TACs) are airborne substances that can cause short-term (acute) or long-term (i.e., chronic, carcinogenic, or cancer- causing) adverse human health effects (i.e., injury or illness). TACs include both organic and inorganic chemical substances. They may be emitted from a variety of common sources, including gasoline stations, automobiles, dry cleaners, industrial operations, and painting operations. The current California list of TACs includes more than 200 compounds, including particulate emissions from diesel-fueled engines.
CARB identified diesel particulate matter ( DPM) as a toxic air contaminant. DPM differs from other TACs in that it is not a single substance but rather a complex mixture of hundreds of substances. Diesel exhaust AOO
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is a complex mixture of particles and gases produced when an engine burns diesel fuel. DPM is a concern because it causes lung cancer; many compounds found in diesel exhaust are carcinogenic. DPM includes the particle- phase constituents in diesel exhaust. The chemical composition and particle sizes of DPM vary between different engine types ( heavy- duty, light-duty), engine operating conditions ( idle, accelerate, decelerate), fuel formulations ( high/ low sulfur fuel), and the year of the engine. Some short-term (acute) effects of diesel exhaust include eye, nose, throat, and lung irritation, and diesel exhaust can cause coughs, headaches, light-headedness, and nausea. DPM poses the greatest health risk among the TACs.
Almost all diesel exhaust particle mass is 10 microns or less in diameter. Due to their extremely small size, these particles can be inhaled and eventually trapped in the bronchial and alveolar regions of the lung.
Ambient Air Quality
CARB monitors ambient air quality at approximately 250 air monitoring stations across the State. Air quality monitoring stations usually measure pollutant concentrations ten feet above ground level; therefore, air quality is often referred to in terms of ground- level concentrations. Existing levels of ambient air quality, historical trends, and projections near the project site are documented by measurements made by the South Coast Air Quality Management District ( SCAQMD), the SCAB’ s air pollution regulatory agency that maintains air quality monitoring stations, which process ambient air quality measurements.
The pollutants of concern in the SCAB are O3, NO2, PM10, and PM2.5. The air monitoring station nearest the project site that monitors ambient concentrations for O3, NO2, PM10, and PM2.5 is the Anaheim – Loara School Station located approximately 3.6 miles to the southeast. Local air quality data from 2022 to 2024 the latest currently available) are provided in Table 5: Ambient Air Quality Data, which lists the annual monitored maximum concentrations and number of exceedances of the National Ambient Air Quality Standards ( NAAQS) and California Ambient Air Quality Standards ( CAAQS).
Sensitive Receptors
Sensitive populations are more susceptible to the effects of air pollution than the general population.
Sensitive receptors that are in proximity to localized sources of toxics are of particular concern. Land uses considered sensitive receptors include residences, schools, playgrounds, childcare centers, long- term health care facilities, rehabilitation centers, convalescent centers, and retirement homes. The nearest 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. 12 12 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).
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Table 5: Ambient Air Quality Data
Criteria Pollutant 20221 20231 20241
Ozone (O3)
1-hour Maximum Concentration ( ppm) 0.102 0.089 0.104
8-hour Maximum Concentration ( ppm) 0.076 0.076 0.079
Number of Days Standard Exceeded
CAAQS 1-hour (>0.09 ppm) 1 0 3
NAAQS 8-hour (>0.070 ppm) 1 2 3
Carbon Monoxide ( CO)
1-hour Maximum Concentration ( ppm) 1.188 2.513 2.770
Number of Days Standard Exceeded
NAAQS 1-hour (>35 ppm) 0 0 0
CAAQS 1-hour (>20 ppm) 0 0 0
Nitrogen Dioxide ( NO2)
1-hour Maximum Concentration ( ppm) 0.053 0.051 0.053
Number of Days Standard Exceeded
NAAQS 1-hour (>100 ppm) 0 0 0
CAAQS 1-hour (>0.18 ppm) 0 0 0
Particulate Matter Less Than 10 Microns ( PM10)
National 24-hour Maximum Concentration 67.0 97.8 118.9
State 24-hour Maximum Concentration 66.7 99.4 42.7
State Annual Average Concentration ( CAAQS= 20 µg/ m3) - - - Number of Days Standard Exceeded
NAAQS 24-hour (>150 µg/ m3) - - 0
CAAQS 24-hour (>50 µg/ m3) - - -
Particulate Matter Less Than 2.5 Microns ( PM2.5)
National 24-hour Maximum Concentration 33.1 45.6 49.7
State 24-hour Maximum Concentration 33.1 50.7 49.7
Number of Days Standard Exceeded
NAAQS 24-hour (>35 µg/ m3) 0 1.0 5.1
1 Measurements for O3, CO, NO2, PM10, and PM2.5 taken at the Anaheim – Loara School located at 1630 Pampas Lane, Anaheim, CA 92802 CARB # 30178).
NAAQS = National Ambient Air Quality Standards; CAAQS = California Ambient Air Quality Standards; ppm = parts per million; µg/ m3 = micrograms per cubic meter; – = not measured
Source: All pollutant measurements are from the CARB Aerometric Data Analysis and Management system database https:// www.arb.ca.gov/ adam) except for CO, which were retrieved from the CARB Air Quality and Meteorological Information System https:// www.arb.ca.gov/ aqmis2/aqdselect.php).
Regulations
Federal Clean Air Act
Air quality is federally protected by the Federal Clean Air Act (FCAA) and its amendments. Under the FCAA, the U.S. Environmental Protection Agency (U.S. EPA) developed the primary and secondary NAAQS for the criteria air pollutants including O3, NO2, CO, SO2, PM10, PM2.5, and lead. Depending on whether the standards are met or exceeded, the local air basin is classified as in “ attainment” or “ nonattainment.” AO
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Some areas are unclassified, which means no monitoring data are available. Unclassified areas are considered to be in attainment. Proposed projects in or near nonattainment areas could be subject to more stringent air-permitting requirements. The FCAA requires that each state prepare a State Implementation Plan ( SIP) to demonstrate how it will attain the NAAQS within federally imposed deadlines. Air quality attainment plans outline emissions limits and control measures to achieve and maintain these standards by the earliest practical date. The U.S. EPA has designated enforcement of air pollution control regulations to the individual states. Applicable federal and State standards are summarized in Table 6: State and Federal Ambient Air Quality Standards.
Table 6: State and Federal Ambient Air Quality Standards Pollutant Averaging Time State Standards1, 2 Federal Standards3, 4,5 Ozone ( O3) 6
1 Hour 0.09 ppm (180 µg/ m3) NA
8 Hour 0.070 ppm (137 µg/ m3) 0.070 ppm (137 µg/ m3)
Respirable Particulate Matter
PM10) 7
24-Hour 50 µg/ m3 150 µg/ m3
Annual Arithmetic Mean 20 µg/ m3 NA
Fine Particulate Matter
PM2.5)
7 24-Hour NA 35 µg/ m3
Annual Arithmetic Mean 12 µg/ m3 9.0 µg/ m3
Carbon Monoxide ( CO)
1 Hour 20 ppm (23 mg/ m3) 35 ppm (40 mg/ m3)
8 Hour 9.0 ppm (10 mg/ m3) 9.0 ppm (10 mg/ m3)
Nitrogen Dioxide ( NO2) 8
1 Hour 0.18 ppm (339 µg/ m3) 100 ppb (188 µg/ m3)
Annual Arithmetic Mean 0.030 ppm (57 µg/ m3) 0.053 ppm (100 µg/ m3) Sulfur Dioxide (SO2) 9
1 Hour 0.25 ppm (655 µg/ m3) 75 ppb (196 µg/ m3)
24 Hour 0.04 ppm (105 µg/ m3) 0.14 ppm (365 µg/ m3)
Annual Arithmetic Mean NA 0.03 ppm (80 µg/ m3)
Lead (Pb)10, 11
30-Day Average 1.5 µg/ m3 NA
Calendar Quarter NA 1.5 µg/ m3
Rolling 3-Month Average NA 0.15 µg/ m3
Visibility Reducing Particles12 8 hours See Note 11 NA
Sulfates ( SO4-2) 24 Hour 25 µg/ m3 NA
Hydrogen Sulfide ( H2S) 1 Hour 0.03 ppm (42 µg/ m3) NA
Vinyl Chloride ( C2H3CI) 10 24 Hour 0.01 ppm (26 µg/ m3) NA 1 California standards for O3, carbon monoxide ( except Lake Tahoe), sulfur dioxide ( 1-hour and 24-hour), nitrogen dioxide, suspended particulate matter (PM10, PM2.5, and visibility reducing particles), are values that are not to be exceeded. All others are not to be equaled or exceeded. California ambient air quality standards are listed in the Table of Standards in Section 70200 of Title 17 of the California Code of Regulations.
2 Concentration expressed first in units in which it was promulgated. Equivalent units given in parentheses are based upon a reference temperature of 25°C and a reference pressure of 760 torr. Most measurements of air quality are to be corrected to a reference temperature of 25°C and a reference pressure of 760 torr; ppm in this table refers to ppm by volume, or micromoles of pollutant per mole of gas. 3 National standards (other than ozone, particulate matter, and those based on annual arithmetic mean) are not to be exceeded more than once a year. The ozone standard is attained when the fourth highest 8-hour concentration measured at each site in a year, averaged over three years, is equal to orless than the standard. For PM10, the 24 hour standard is attained when the expected number of days per calendar year with a 24-hour average concentration above 150 µg/ m3 is equal to or less than one. For PM2.5, the 24 hour standard is attained when 98 percent of the daily concentrations, averaged over three years, are equal to or less than the standard. Contact the U.S. EPA for further clarification and current national policies.
4 National Primary Standards: The levels of air quality necessary, with an adequate margin of safety to protect the public health. 5 On October 1, 2015, the national 8-hour ozone primary and secondary standards were lowered from 0.075 to 0.070 ppm. 6 On February 7, 2024, the national annual PM2.5 primary standard was lowered from 12.0 µg/ m3 to 9.0 µg/ m3. The existing national 24-hour PM2.5 standards (primary and secondary) were retained at 35 µg/ m3, as was the annual secondary standard of 15.0 µg/ m3. The existing 24- hour PM10 standards ( primary and secondary) of 150 µg/ m3 also were retained. The form of the annual primary and secondary standards is AO
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Table 6: State and Federal Ambient Air Quality Standards the annual mean, averaged over 3 years.
7 To attain the 1-hour national standard, the 3-year average of the annual 98th percentile of the 1-hour daily maximum concentrations at each site must not exceed 100 ppb. Note that the national 1-hour standard is in units of parts per billion (ppb). California standards are in units of parts per million (ppm). To directly compare the national 1-hour standard to the California standards the units can be converted from ppb to ppm. In this case, the national standard of 100 ppb is identical to 0.100 ppm. 8 On June 2, 2010, a new 1-hour SO2 standard was established and the existing 24-hour and annual primary standards were revoked. To attain the 1-hour national standard, the 3-year average of the annual 99th percentile of the 1-hour daily maximum concentrations at each site must not exceed 75 ppb. The 1971 SO2 national standards ( 24-hour and annual) remain in effect until one year after an area is designated for the 2010 standard, except that in areas designated nonattainment for the 1971 standards, the 1971 standards remain in effect until implementation plans to attain or maintain the 2010 standards are approved. Note that the 1-hour standard is in units of parts per billion ppb). California standards are in units of parts per million (ppm). To directly compare the 1-hour standard to the California standard the units can be converted to ppm. In this case, the national standard of 75 ppb is identical to 0.075 ppm. 9 The ARB has identified lead and vinyl chloride as “ toxic air contaminants” with no threshold level of exposure for adverse health effects determined. These actions allow for the implementation of control measures atlevels below the ambient concentrations specified for these pollutants.
10 The national standard for lead was revised on October 15, 2008 to a rolling 3-month average. The 1978 lead standard (1.5 µg/ m3 as a quarterly average) remains in effect until one year after an area is designated for the 2008 standard, except that in areas designated nonattainment for the 1978 standard, the 1978 standard remains in effect until implementation plans to attain or maintain the 2008 standard are approved.
11 In 1989, the ARB converted both the general statewide 10-mile visibility standard and the Lake Tahoe 30-mile visibility standard to instrumental equivalents, which are “extinction of 0.23 per kilometer” and “extinction of 0.07 per kilometer” for the statewide and Lake Tahoe Air Basin standards, respectively.
ppm = parts per million; ppb = parts per billion; µg/ m3 = micrograms per cubic meter; mg/m3 = milligrams per cubic meter; NA = no information available
Source: South Coast Air Quality Management District. (2024). Table of Air Quality Standards . Retrieved from:
https:// ww2.arb.ca.gov/ sites/ default/ files/ 2024-08/ AAQS%20Table_ ADA_FINAL_ 07222024. pdf. Accessed August 27, 2025.
Federal Emissions Standards for On-Road Trucks
To reduce emissions from on-road, heavy- duty diesel trucks, the U.S. EPA established a series of increasingly strict emission standards for new engines, starting in 1988. The U.S. EPA promulgated the final and cleanest standards with the 2007 Heavy-Duty Highway Rule. The particulate matter emission standard of 0.01 gram per horsepower- hour (g/ hp-hr) is required for new vehicles beginning with Model Year 2007. Also, the NOX and nonmethane hydrocarbon standards of 0.20 g/ hp-hr and 0.14 g/ hp-hr, respectively, were phased in together between 2007 and 2010 on a percent of sales basis: 50 percent from 2007 to 2009 and 100 percent in 2010.
Emission Standards for Off-Road Diesel Engines
To reduce emissions from off-road diesel equipment, the U.S. EPA established a series of cleaner emission standards for new off-road diesel engines. Tier 1 standards were phased in from 1996 to 2000 (year of manufacture), depending on the engine horsepower category. Tier 2 standards were phased in from 2001 to 2006. Tier 3 standards were phased in from 2006 to 2008. Tier 4 standards, which generally require add-on emission control equipment to attain them, were phased in from 2008 to 2015.
California Air Resources Board
CARB administers California’ s air quality policy. The CAAQS were established in 1969 pursuant to the Mulford- Carrell Act. These standards are generally more stringent and apply to more pollutants than the NAAQS. In addition to the criteria pollutants, CAAQS have been established for visibility reducing particulates, hydrogen sulfide, and sulfates.
The California Clean Air Act ( CCAA), which was approved in 1988, requires that each local air district prepare and maintain an Air Quality Management Plan (AQMP) to achieve compliance with CAAQS. These AQMPs also serve as the basis for the preparation of the SIP for meeting the NAAQS. Like the U.S. EPA, CARB also designates areas within California as either attainment or nonattainment for each criteria AOO
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pollutant based on whether the CAAQS have been achieved. Under the CCAA, areas are designated as nonattainment for a pollutant if air quality data shows that a CAAQS was violated at least once during the previous three calendar years. Exceedances that are affected by highly irregular or infrequent events such as wildfires, volcanoes, etc. are not considered violations of the CAAQS, and are not used as a basis for designating areas as nonattainment. The applicable CAAQS are summarized in Table 6.
South Coast Air Quality Management District
The SCAQMD is the air pollution control agency for Orange County and the urban portions of Los Angeles, Riverside, and San Bernardino counties. The SCAQMD’ s primary responsibility is ensuring that NAAQS and CAAQS are attained and maintained in the SCAB. The SCAQMD is also responsible for adopting and enforcing rules and regulations concerning air pollutant sources, issuing permits for stationary sources of air pollutants, inspecting stationary sources of air pollutants, responding to citizen complaints, monitoring ambient air quality and meteorological conditions, awarding grants to reduce motor vehicle emissions, conducting public education campaigns, and many other activities. All projects are subject to SCAQMD rules and regulations in effect at the time of construction.
The SCAQMD is also the lead agency in charge of developing the AQMP, with input from the Southern California Association of Governments ( SCAG) and CARB. The AQMP is a comprehensive plan that includes control strategies for stationary and area sources, as well as for on-road and off-road mobile sources.
SCAG has the primary responsibility for providing future growth projections and the development and implementation of transportation control measures. CARB, in coordination with federal agencies, provides the control element for mobile sources.
The 2016 AQMP was adopted by the SCAQMD Governing Board on March 3, 2017. The purpose of the AQMP is to set forth a comprehensive and integrated program that would lead the SCAB into compliance with the federal 24-hour PM2.5 air quality standard, and to update the SCAQMD’ s commitments towards meeting the federal 8-hour O3 standards. The AQMP incorporates scientific and technological information and planning assumptions, including the 2016 Regional Transportation Plan/ Sustainable Communities Strategy ( RTP/ SCS) and updated emission inventory methodologies for various source categories.
On October 1, 2015, the U.S. EPA strengthened the NAAQS for ground-level O3. The 2022 AQMP, adopted by the SCAQMD Governing Board on December 2, 2022, was developed to address the requirements for meeting the 2015 8-hour O3 standard. The 2022 AQMP builds upon measures already in place from previous AQMPs. It also includes a variety of additional strategies such as regulation, accelerated deployment of available cleaner technologies ( e.g., zero emission [ ZE] technologies, when cost-effective and feasible, and low NOX technologies in other applications), best management practices, co-benefits from existing programs ( e.g., climate and energy efficiency), incentives, and other FCAA measures to achieve the 2015 8-hour O3 standard. The 2022 AQMP incorporates the latest scientific and technological information and planning assumptions, including the 2020 RTP/ SCS and updated emission inventory methodologies for various source categories.
The SCAQMD published the CEQA Air Quality Handbook ( approved by the SCAQMD Governing Board in 1993 and augmented with guidance for Local Significance Thresholds [ LST] in 2008). 13 The SCAQMD guidance helps local government agencies and consultants develop environmental documents required 13 South Coast Air Quality Management District. (2008). Final Localized Significance Threshold Methodology. Retrieved from:
https:// www.aqmd.gov/home/rules-compliance/ ceqa/ air-quality-analysis-handbook/ localized-significance-thresholds. Accessed August 27, 2025.
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by CEQA and identifies thresholds of significance for criteria pollutants for both construction and operation ( see discussion of thresholds below). With the help of the CEQA Air Quality Handbook and associated guidance, local land use planners and consultants can analyze and document how existing and proposed projects affect air quality, in order to meet the CEQA review process requirements. The SCAQMD periodically provides supplemental guidance and updates to the handbook on their website.
The State and federal attainment status designations for the SCAB are summarized in Table 7: South Coast Air Basin Attainment Status. The SCAB is currently designated as a nonattainment area with respect to the State O3, PM10, and PM2.5 standards, as well as the national O3 and PM2.5 standards. The SCAB is designated as attainment or unclassified for the remaining NAAQS and CAAQS.
Table 7: South Coast Air Basin Attainment Status
Pollutant State Federal
Ozone (O3)
1 Hour Standard) Nonattainment Nonattainment ( Extreme) Ozone (O3)
8 Hour Standard) Nonattainment Nonattainment ( Extreme) Particulate Matter (PM2.5)
24 Hour Standard) – Nonattainment ( Serious)
Particulate Matter (PM2.5)
Annual Standard) Nonattainment Nonattainment ( Serious) Particulate Matter (PM10)
24 Hour Standard) Nonattainment Attainment ( Maintenance) Particulate Matter (PM10)
Annual Standard) Nonattainment –
Carbon Monoxide ( CO)
1 Hour Standard) Attainment Attainment ( Maintenance)
Carbon Monoxide ( CO)
8 Hour Standard) Attainment Attainment ( Maintenance)
Nitrogen Dioxide ( NO2)
1 Hour Standard) Attainment Unclassifiable/ Attainment
Nitrogen Dioxide ( NO2)
Annual Standard) Attainment Attainment ( Maintenance)
Sulfur Dioxide (SO2)
1 Hour Standard) Attainment Unclassifiable/ Attainment
Sulfur Dioxide (SO2)
24 Hour Standard) Attainment –
Lead (Pb)
30 Day Standard) – Unclassifiable/ Attainment
Lead (Pb)
3 Month Standard) Attainment –
Sulfates ( SO4-2)
24 Hour Standard) Attainment –
Hydrogen Sulfide (H2S)
1 Hour Standard) Unclassified –
Source: South Coast Air Quality Management District. ( 2022). 2022 Air Quality Management Plan.; United States Environmental Protection Agency. (2022). Nonattainment Areas for Criteria Pollutants (Green Book).
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The following is a list of SCAQMD rules that are required of construction activities associated with the proposed Project:
Rule 401 (Visible Emissions) – A person shall not discharge into the atmosphere from any single source of emission whatsoever any air contaminant for a period or periods aggregating more than three minutes in any 1 hour that is dark or darker in shade as that designated No. 1 on the Ringelmann Chart, as published by the United States Bureau of Mines.
Rule 402 ( Nuisance) – This rule prohibits the discharge from any source whatsoever such quantities of air contaminants or other material which cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health, or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property. This rule does not apply to odors emanating from agricultural operations necessary for the growing of crops or the raising of fowl or animals.
Rule 403 ( Fugitive Dust) – This rule requires fugitive dust sources to implement best available control measures for all sources, and all forms of visible particulate matter are prohibited from crossing any property line. This rule is intended to reduce PM10 emissions from any transportation, handling, construction, or storage activity that has the potential to generate fugitive dust. PM10 suppression Best Available Control Measures are summarized below. a) Portions of a construction site to remain inactive longer than a period of three months will be seeded and watered until grass cover is grown or otherwise stabilized. b) All on-site roads will be paved as soon as feasible or watered periodically or chemically stabilized.
c) All material transported off-site will be either sufficiently watered or securely covered to prevent excessive amounts of dust.
d) The area disturbed by clearing, grading, earthmoving, or excavation operations will be minimized at all times.
e) Where vehicles leave a construction site and enter adjacent public streets, the streets will be swept daily or washed down at the end of the work day to remove soil tracked onto the paved surface.
Rule 431.2 (Sulfur Content of Liquid Fuels) - This rule limits the sulfur content in diesel and other liquid fuels for the purpose of both reducing the formation of sulfur oxides and particulates during combustion and to enable the use of add-on control devices for diesel fueled internal combustion engines.
Rule 1113 (Architectural Coatings) – This rule requires manufacturers, distributors, and end users of architectural and industrial maintenance coatings to reduce ROG emissions from the use of these coatings, primarily by placing limits on the ROG content of various coating categories.
Rule 1143 ( Paint Thinners and Solvents) – This rule governs the manufacture, sale, and use of paint thinners and solvents used in thinning of coating materials, cleaning of coating application equipment, and other solvent cleaning operations by limiting their volatile organic compound AOO
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VOC) content. This rule regulates the VOC content of solvents used during construction. Solvents used during the construction phase must comply with this rule.
Rule 1403 ( Asbestos Emissions from Demolition/ Renovation Activities) – This rule requires owners and operators or any demolition or renovation activity and the associated disturbance of asbestos- containing materials, any asbestos storage facility, or any active waste disposal site to implement work practice requirements to limit asbestos emissions from building demolition and renovation activities, including the removal and associated disturbance of asbestos- containing materials.
Rule 1470 ( Requirements for Stationary Diesel- Fueled Internal Combustion and Other Compression Ignition Engines) – This rule would minimize emissions associated with stationary engines over 50 horsepower by establishing operating requirements and emission standards, enforcing the Airborne Toxics Control Measure, and requiring owners and operators to submit a Compliance Status Report and a Compliance Plan to the SCAQMD.
Rule 2305 (Warehouse Indirect Source Rule) - Rule 2305 was adopted by the SCAQMD Governing Board on May 7, 2021 to reduce NOX and particulate matter emissions associated with warehouses and mobile sources attracted to warehouses. This rule applies to all existing and proposed warehouses over 100,000 square feet located in the SCAQMD. Rule 2305 requires warehouse operators to track annual vehicle miles traveled ( VMT) associated with truck trips to and from the warehouse. These trip miles are used to calculate the Project’ s Warehouse Actions and Investments to Reduce Emissions ( WAIRE) Points Compliance Obligation. WAIRE Points are earned based on emission reduction measures and warehouse operators are required to submit an annual WAIRE Report which includes truck trip data and emission reduction measures.
Reduction strategies listed in the WAIRE menu include acquire ZE or near zero emission ( NZE) trucks; require ZE/ NZE truck visits; require ZE yard trucks; install on-site ZE charging/ fueling infrastructure; install on-site energy systems; and install filtration systems in residences, schools, and other buildings in the adjacent community. Warehouse operators that do not earn a sufficient number of WAIRE points to satisfy the WAIRE Points Compliance Obligation would be required to pay a mitigation fee. Funds from the mitigation fee will be used to incentivize the purchase of cleaner trucks and charging/ fueling infrastructure in communities nearby.
The Fullerton Plan
Adopted on May 1, 2012, Chapter 17: Air Quality and Climate Change of the City of Fullerton General Plan Natural Environment Element establishes goals and policies to improve local air quality and protect the community from potentially adverse air quality impacts. The following General Plan goals and policies have been adopted by the City for the purpose of mitigating air emissions resulting from its land use decisions and are applicable to the proposed Project.
GOAL 21 Protection and improvement of air quality.
P21. 1 Jobs-Housing Balance Support regional and subregional efforts to improve the alignment of housing options and employment opportunities to reduce commuting.
P21.2 Transportation System Support regional and subregional efforts to promote a transportation system coordinated with air quality improvements.
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P21.4 Balanced Land Use Support projects, programs, policies and regulations to promote a balance of residential, commercial, industrial, recreational and institutional uses located to provide options to reduce vehicle trips and vehicle miles traveled.
P21. 5 Product Handling and Disposal Impacts Support projects, programs, policies and regulations to reduce impacts to air quality from the improper handling and disposal of commercial products.
P21. 6 Construction Impacts Support projects, programs, policies and regulations to reduce impacts to air quality caused by private and public construction projects.
P21. 7 Development Impacts Support projects, programs, policies and regulations to reduce impacts to air quality caused by the design or operation of a site or use.
Thresholds of Significance
The significance criteria established by SCAQMD may be relied upon to make the determinations listed above. According to the SCAQMD, an air quality impact is considered significant if a project would violate any NAAQS or CAAQS, contribute substantially to an existing or projected air quality violation, or expose sensitive receptors to substantial pollutant concentrations.
Regional Emissions Threshold
The SCAQMD has established numeric thresholds of significance for air pollutants resulting from construction and operational activities of land use development projects within the SCAQMD jurisdictional boundaries, as shown in Table 8: South Coast Air Quality Management District Significance Thresholds. If the SCAQMD thresholds are exceeded, a potentially significant impact may occur, and additional analysis is warranted to fully assess the significance of impacts. However, ultimately the City, as the Lead Agency under CEQA, determines the thresholds of significance for impacts.
Table 8: South Coast Air Quality Management District Significance Thresholds Pollutant
Mass Daily Thresholds ( pounds per day)
Construction Operations
Volatile Organic Compounds ( VOC) 75 55
Nitrogen Oxides ( NOX) 100 55
Carbon Monoxide ( CO) 550 550
Sulfur Oxides (SOX) 150 150
Particulate Matter up to 10 Microns (PM10) 150 150
Particulate Matter up to 2.5 Microns ( PM2.5) 55 55
Source: South Coast Air Quality Management District. (2023). South Coast AQMD Air Quality Significance Thresholds.
Localized Carbon Monoxide
The Project would be subject to the CAAQS and NAAQS for CO. These are addressed though an analysis of localized CO impacts known as the CO “ hot spots” analysis, which determines whether the change in the level of service of an intersection as a result of the Project would have the potential to result in exceedances of the CAAQS or NAAQS. The 2003 AQMP is the most recent AQMP that addressed CO concentrations. As part of the 2003 AQMP CO Modeling Attainment Demonstration, an analysis was AOO
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performed utilizing dispersion modeling. 14 As an initial screening step, if a project roadway segment does not exceed an average daily traffic (ADT) of 100,000 per day, then the project does not need to prepare a detailed CO hot spot analysis.
Localized Significance Threshold
The SCAQMD developed the LSTs for emissions of NO2, CO, PM10, PM2.5 in response to the SCAQMD Governing Boards' Environmental Justice Enhancement Initiative ( I-4). The SCAQMD provided the Final Localized Significance Threshold Methodology ( dated June 2003 [ revised 2008]) to assist lead agencies in analyzing localized impacts associated with project- specific emissions. LSTs represent the maximum emissions that can be generated at the project site that are not expected to cause or substantially contribute to an exceedance of the most stringent CAAQS or NAAQS. LSTs are based on the ambient concentrations of that pollutant within the project source receptor area ( SRA), as demarcated by the SCAQMD, the distance to the nearest sensitive receptor, and the project site acreage.
The SCAQMD’ s Localized Significance Threshold Methodology provides on-site mass emissions rate lookup tables. The project site is located within SCAQMD SRA 16 (North Orange County). LST thresholds are provided for source-receptor distances of 25, 50, 100, 200, and 500 meters. The sensitive receptors nearest the project site are residential uses located approximately 765 feet (233 meters) to the southeast.
Table 9: Local Significance Thresholds for Construction and Operations summarizes the LSTs for 1-acre, 2-acre, and 5-acre projects in SCAQMD SRA 16 with sensitive receptors located 200 meters from the project site.
Table 9: Local Significance Thresholds for Construction and Operations Daily Acres
Disturbed/
Project Size
Maximum Emissions ( pounds per day)
Construction Operations
NOX CO PM10 PM2.5 NOX CO PM10 PM2.5
1 Acre 159 1,975 53 20 159 1,975 13 5
2 Acres 186 2,444 60 24 186 2,444 15 6
5 Acres 249 3,605 78 34 249 3,605 19 8
NOX = nitrogen oxides; CO = carbon monoxide; PM10 = coarse particulate matter; PM2.5 = fine particulate matter Source: South Coast Air Quality Management District. (2008). Localized Significance Threshold Methodology.
LSTs associated with all acreage categories are provided in Table 9 for informational purposes and to demonstrate the LSTs increase as acreages increase. It should be noted that LSTs are screening thresholds and are therefore conservative. The construction LST acreage is determined based on the daily acreage disturbed by the Project. LST analysis for construction is required for all projects that disturb 5 acres or less on a single day. The operational LST acreage is based on the total area of the project site.
Methodology
This air quality impact analysis considers construction and operational impacts associated with the Project. Where criteria air pollutant quantification was required, emissions were modeled using the CARBapproved California Emissions Estimator Model (CalEEMod). CalEEMod is a Statewide land use emissions computer model designed to quantify potential criteria pollutant emissions associated with both 14 South Coast Air Quality Management District. (2003). Air Quality Management Plan, Appendix V, Modeling and Attainment Demonstrations. Retrieved from: https:// www.aqmd.gov/ home/ air-quality/ air-quality-management-plans/ air-quality-mgt-plan/ 2003- aqmp. Accessed August 27, 2025.
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construction and operations from a variety of land use projects. Air quality impacts were assessed according to methodologies recommended by CARB and the SCAQMD.
Project construction would generate emissions from construction equipment, trucks, worker vehicles, and ground- disturbing activities. Daily regional 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.
Project operations would generate emissions from area sources ( consumer products, architectural coating, and landscaping equipment), energy sources ( electricity usage), mobile sources ( motor vehicles from Project- generated vehicle trips), an emergency fire pump, and off-road forklift usage. Projectgenerated increases in operational emissions would be predominantly associated with motor vehicle use.
The mobile source emissions were estimated in CalEEMod based on the Project vehicle trip generation outlined in Table 1 from Appendix L. The trip generation table includes a comparison of the trips associated with the existing and proposed uses and is informed by the Institute of Transportation Engineers ( ITE) Land Use Codes in the City’s Transportation Assessment Policies & Procedures ( TAPP) Analysis Level of Service (LOS) section. The area and energy source emissions 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.
The proposed Project’ s regional construction and operational emissions were compared to the SCAQMD’ s significance thresholds to determine the significance of the Project’ s impact on regional air quality; refer to Table 5. The proposed Project’ s localized construction and operational emissions were evaluated in accordance with the SCAQMD’ s LST methodology, which uses on-site mass emissions rate look-up tables and Project- specific modeling. LSTs represent the maximum on-site emissions from a project that are not expected to cause or contribute to an exceedance of the most stringent applicable NAAQS and CAAQS.
Impact Analysis
a) Conflict with or obstruct implementation of the applicable air quality plan? Less Than Significant Impact. The U.S. EPA requires each state with nonattainment areas to prepare and submit a SIP that demonstrates the means to attain the NAAQS. The SIP must integrate federal, state, and local plan components and regulations to identify specific measures to reduce pollution in nonattainment areas, using a combination of performance standards and marketbased programs. Similarly, under State law, the CCAA requires an air quality attainment plan to be prepared for areas designated as nonattainment regarding the NAAQS and CAAQS. Air quality attainment plans outline emissions limits and control measures to achieve and maintain these standards by the earliest practical date.
The project site is located within the SCAB, which is under SCAQMD’ s jurisdiction. The SCAQMD is required, pursuant to the FCAA, to reduce emissions of criteria pollutants for which the SCAB is in nonattainment. To reduce such emissions, the SCAQMD drafted the 2016 AQMP and 2022 AQMP AQMPs). 15 The AQMPs establishes a program of rules and regulations directed at reducing air pollutant emissions and achieving NAAQS and CAAQS. The AQMPs are a regional and multi- agency 15 The 2016 AQMP ( adopted in March 2017) was developed to address attainment of multiple O3 and PM2.5 standards. The 2022 AQMP adopted in December 2022), was developed to address attainment of the 2015 8-hour O3 standard.
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effort including the SCAQMD, the CARB, the SCAG, and the U. S. EPA. The AQMPs pollutant control strategies are based on the latest scientific and technical information and planning assumptions, including SCAG’ s Connect SoCal, updated emission inventory methodologies for various source categories, and SCAG’ s latest growth forecasts. SCAG’ s latest growth forecasts were defined in consultation with local governments and with reference to local general plans. The Project is subject to the SCAQMD’ s AQMPs.
Criteria for determining consistency with the AQMPs are defined by the following indicators:
Consistency Criterion No. 1: The Project would not result in an increase in the frequency or severity of existing air quality violations, or cause or contribute to new violations, or delay the timely attainment of the AQMP’ s air quality standards or the interim emissions reductions.
Consistency Criterion No. 2: The Project would not exceed the AQMP’ s assumptions or increments based on the years of the Project build- out phase.
According to the SCAQMD’ s CEQA Air Quality Handbook, the purpose of the consistency finding is to determine if a project is inconsistent with the assumptions and objectives of the regional air quality plans, and thus if it would interfere with the region’ s ability to comply with CAAQS and NAAQS. 16
The violations to which Consistency Criterion No. 1 refers are CAAQS and NAAQS. As addressed below in Table 10: Project Construction Emissions and Table 11: Project Operational Emissions, the Project would not exceed the short-term construction or long-term operational thresholds of significance and would therefore not violate any air quality standards. As such, the Project would not result in an increase in frequency or severity of existing air quality violations, or cause or contribute to new violations, or delay the timely attainment of air quality standards or the interim emissions reductions specified in the AQMPs. Therefore, the Project would be consistent with the first criterion.
Concerning Consistency Criterion No. 2, the 2022 AQMP contains air pollutant reduction strategies based on SCAG’ s latest growth forecasts included in the 2020 RTP/ SCS. SCAG’ s growth forecasts are made in consultation with local governments and with reference to their local general plans.
The Project is anticipated to employ approximately 113 employees17 and could indirectly induce population growth if future employees move into the City to work at the proposed warehouse. The Project would provide employment opportunities within a City with substantial housing stock. As such, it is likely that the Project would employ current residents of the City. In the event that the operator of the proposed facility draws employees that are not from the local community, the Project would not directly result in the development of new housing.
The population and employment forecasts, which are adopted by SCAG’ s Regional Council, are based on the local plans and policies applicable to the City. As the Project would not directly result in the development of new housing and the project site land use designation ( Industrial) is consistent with the General Plan, the Project would not cause the General Plan buildout household or employment forecasts to be exceeded. Additionally, as the SCAQMD has incorporated these 16 South Coast Air Quality Management District. (1993). CEQA Air Quality Handbook. 17 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.
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same projections into the AQMPs, it can be concluded that the proposed Project would be consistent with second criterion.
Based on the foregoing, the Project would not conflict with or obstruct the implementation of the AQMPs or any applicable air quality plan and impacts to this regard would be less than significant. b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or State ambient air quality standard? Less Than Significant Impact: Regional Construction Emissions. Project construction activities would generate short-term emissions of criteria air pollutants. The criteria pollutants of primary concern within the area include O3- precursor pollutants ( i.e., ROG and NOX), PM10, and PM2.5.
Construction- generated emissions are short-term and of temporary duration, lasting only as long as construction activities occur, but would be considered a significant air quality impact if the volume of pollutants generated exceeds the SCAQMD’ s thresholds of significance.
Project construction would result in the temporary generation of criteria pollutant emissions from all phases of construction, including demolition, site preparation, grading, infrastructure improvements, building construction, paving, and architectural coating applications. 18 Construction results in the temporary generation of emissions resulting from site grading, road paving, motor vehicle exhaust associated with construction equipment and worker trips, and the movement of construction equipment, especially on unpaved surfaces. Emissions of airborne particulate matter are largely dependent on the amount of ground disturbance associated with site preparation activities, as well as weather conditions and the appropriate application of water.
Project construction activities would occur over approximately 13 months, anticipated to begin as early as the third quarter of 2027 and ending as early as the third quarter of 2028. Constructiongenerated 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. Fugitive dust emissions from construction may temporarily become a nuisance and potential health hazard to those living and working nearby. Project construction would comply with SCAQMD rules and regulations, including SCAQMD Rule 402 (Nuisance), Rule 403 ( Fugitive Dust), and Rule 1113 ( Architectural Coatings). SCAQMD Rule 402 ( Nuisance) prohibits the discharge of air contaminants or other material that cause a nuisance. SCAQMD Rule 403 (Fugitive Dust) requires fugitive dust control measures. SCAQMD Rule 1113 ( Architectural Coatings) provides specifications on painting practices and regulates the ROG content of paint. Project construction would additionally comply with CARB’ s anti-idling regulations, which prohibits heavyduty diesel vehicle idling for more than five minutes. Rule 403 was applied in CalEEMod to reduce fugitive dust emissions. See Appendix A for more information regarding the construction assumptions.
18 Although not proposed, this analysis conservatively assumes the Project would include full-width grind and overlay along Cypress Way.
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Short-term construction emissions attributable to the Project are summarized in are summarized in Table 10: Project Construction Emissions.
Table 10: Project Construction Emissions
Construction Year
Maximum Daily Emissions ( pounds per day) 1, 2
ROG NOX CO SO2 PM10 PM2.5
2027 3.10 28.03 29.02 0.07 7.36 3.76
2028 58.75 16.24 25.92 0.04 1.50 0.74
Maximum Emissions 58.75 28.03 29.02 0.07 7.36 3.76
SCAQMD Threshold 75 100 550 150 55 150
Threshold Exceeded? No No No No No No
1 As recommended by the SCAQMD, emissions were calculated using CalEEMod version 2022.1 and the worst-case seasonal maximum daily emissions are reported.
2 SCAQMD Rule 403 Fugitive Dust was applied. SCAQMD Rule 403 reduction/ credits include: properly maintain mobile and other construction equipment; replace ground cover in disturbed areas quickly; water exposed surfaces three times daily; cover stockpiles with tarps; water all haul roads twice daily; and limit speeds on unpaved roads to 15 miles per hour. Reductions percentages from the SCAQMD CEQA Handbook (Tables XI-A through XI-E) were applied.
ROG = reactive organic gases; NOX = nitrogen oxides; CO = carbon monoxide; SO2 = sulfur dioxide; PM10 = coarse particulate matter; PM2.5 = fine particulate matter; SCAQMD = South Coast Air Quality Management District Source: CalEEMod version 2022.1. Refer to Appendix A for the model outputs.
Table 10 shows the Project construction- related emissions would not exceed the applicable SCAQMD thresholds without assuming compliance with SCAQMD Rules 402 (Nuisance) and 1113 Architectural Coatings) and CARB’ s anti-idling regulations. Therefore, the actual Project construction emissions would be even lower than reported in Table 10. As such, impacts associated with Project regional construction emissions would be less than significant.
Less Than Significant Impact: Regional Operational Emissions. The Project’ s operational emissions would be associated with area sources (consumer products, architectural coating, and landscaping equipment), energy sources, mobile sources (motor vehicles from Project-generated vehicle trips), an emergency fire pump, and off-road forklifts. Primary sources of operational criteria pollutants are from motor vehicle use and area sources.
Long- term operational emissions attributable to the Project are summarized in Table 11: Project Operational Emissions. As shown in the table, the Project’ s operational- related emissions would not exceed the applicable SCAQMD thresholds. As such, impacts associated with Project operational regional emissions would be less than significant.
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Table 11: Project Operational Emissions
Source
Maximum Daily Emissions ( pounds per day)
ROG NOX CO SO2 PM10 PM2.5
Area1 3.44 0.04 4.79 < 0.01 0.01 0.01
Energy1 0.00 0.00 0.00 0.00 0.00 0.00
Mobile – Trucks1 0.12 5.76 2.51 0.05 2.01 0.60
Mobile – Passenger Vehicles1 0.44 0.35 3.96 0.01 1.08 0.28 Emergency Fire Pump 0.11 0.08 0.05 < 0.01 0.01 0.01
Off-Road Forklifts 0.04 0.23 3.21 < 0.01 0.01 0.01
Total2 4.16 6.46 14.52 0.07 3.12 0.90
SCAQMD Threshold 55 55 550 150 150 55
Threshold Exceeded? No No No No No No
1 As recommended by the SCAQMD, emissions were calculated using CalEEMod version 2022.1 and the worst-case seasonal maximum daily emissions are reported.
2 Totals may not add up exactly due to rounding in the modeling calculations.
ROG = reactive organic gases; NO2 = nitrogen dioxide; CO = carbon monoxide; SO2 = sulfur dioxide; PM10 = coarse particulate matter; PM2.5 = fine particulate matter; SCAQMD = South Coast Air Quality Management District PM10 = particulate matter 10 microns in diameter or less; PM2.5 = particulate matter 2.5 microns in diameter or less; SCAQMD = South Coast Air Management District Source: CalEEMod version 2022.1. Refer to Appendix A for the model outputs.
The operational emission sources are described below.
Area Source Emissions. Area source emissions would be generated due to consumer products, architectural coatings, and landscaping equipment. Consumer products are various solvents used in non-industrial applications, which emit VOCs during product use. These typically include cleaning supplies, kitchen aerosols, cosmetics, and toiletries. The entire Project would not use consumer products as specified by the CalEEMod User Guide. The proposed warehouse building would include office spaces and may have small kitchen areas and bathrooms that would use cleaning products and kitchen aerosols, however the majority of the square footage of the proposed warehouse building would be used for warehousing and distribution. As such, negligible quantities of personal care products, home, lawn, and garden products, disinfectants, sanitizers, polishes, cosmetics, and floor finishes would be used.
Area source emissions were calculated in CalEEMod using default rates based on a Statewide average. Therefore, ROG emissions are likely overestimated and therefore a conservative assumption for the purposes of this analysis.
Energy Source Emissions. Energy source emissions ( e.g., water heating systems) would be generated due to natural gas usage associated with the Project. However, the Project would be all-electric and would not connect to or utilize natural gas. Therefore, the Project would not generate energy source emissions.
Mobile Source Emissions. Mobile sources are emissions from motor vehicles, including tailpipe and evaporative emissions. Depending upon the pollutant being discussed, the potential air quality impact may be of either regional or local concern. For example, ROG, NOX, PM10, and PM2.5 are all pollutants of regional concern. NOX and ROG react with sunlight to form O3, known as photochemical smog. Additionally, wind currents readily transport PM10 AO
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and PM2.5. However, CO tends to be a localized pollutant, dispersing rapidly at the source.
Project- generated vehicle emissions are based on the trip generation estimates and have been incorporated into CalEEMod, as recommended by the SCAQMD. According to Table 1 in Appendix L, the Project would result in a net reduction of 422 total daily vehicle trips to the project site. As such, the Project would result in net mobile source emission reductions compared to existing conditions. However, it is conservatively assumed the Project would generate approximately 212 total daily vehicle trips ( 146 passenger vehicles and 66 truck vehicles). The mobile source emissions included in Table 11 are therefore a conservative estimation.
CalEEMod defaults were adjusted to reflect the warehouse truck trip lengths and fleet mix characteristics. The warehouse truck trip lengths were increased to 33.2 miles, based on the distance to the Ports of Los Angeles and Long Beach, as well as CARB estimates for drayage trucks. 19 Trucks are classified by type ( or axle configuration) into light heavy- duty trucks LHDT), medium heavy- duty trucks (MHDT), and heavy heavy- duty trucks (HHDT), reflecting a mix of large trucks with 2, 3, and 4 or more axles. To better represent warehouse- specific operations, the warehouse fleet mix was adjusted to represent 17 percent LHDT, 23 percent MHDT, and 60 percent HHDT. 20 Mobile source emissions rates in CalEEMod utilized the CARBdeveloped EMission FACtors ( EMFAC) 2021 emissions rates consistent with the methodology described in the CalEEMod User’ s Guide.
Emergency Fire Pump. An emergency fire pump would only be used to provide additional water pressure for an early-suppression fast-response fire sprinkler system and would not be part of the Project’ s normal daily operations. Although the Project proposes an electric emergency fire pump, this analysis conservatively assumes the Project would utilize a diesel emergency fire pump. Therefore, emissions associated with a diesel emergency fire pump were included to be conservative. Emissions from a diesel emergency fire pump was calculated separately from CalEEMod using default emission rates; refer to Appendix A. If the Project were to install a diesel emergency fire pump, the end user (the future operator of the proposed warehouse building) would be required to obtain a permit from the SCAQMD prior to installation. The diesel emergency fire pump must comply with SCAQMD Rule 1470 Requirements for Stationary Diesel- Fueled Internal Combustion and Other Compression Ignition Engines), which would minimize emissions if and when a diesel emergency fire pump is used.
Off-Road Forklifts. Operational off-road emissions would be generated by off-road cargo handling equipment used during operational warehouse activities. Although the Project proposes three electric forklifts, it was conservatively assumed that the proposed warehouse building would utilize three diesel forklifts for loading and unloading goods. Emissions from diesel forklifts were calculated separately from CalEEMod using default emission rates; refer to Appendix A. It should be noted that the Project does not include cold storage. Therefore, 19 California Air Resources Board. (N.D.). Mobile Source Emissions Inventory ( MSEI) Documentation – Drayage Trucks, Appendix B: Emissions Estimation Methodology for On-Road Diesel-Fueled Heavy-Duty Drayage Trucks at California Ports and Intermodal Rail Yards. Retrieved from: https:// ww2.arb.ca.gov/ our-work/ programs/ mobile- source-emissions- inventory/ msei-documentation- road-heavy-duty-diesel.
Accessed September 9, 2025.
20 WSP. (2017). RCTC Truck Study and Regional Logistics Mitigation Fee, Technical Memorandum 1: Exiting and Future Conditions, WarehouseRelated Land Use Data & Truck Travel Patterns.
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this analysis models the proposed warehouse building as unrefrigerated, and the Project would not include emissions from transport refrigeration units. c) Expose sensitive receptors to substantial pollutant concentrations? Less Than Significant Impact: Localized Construction Emissions. The SCAQMD provided the Final Localized Significance Threshold Methodology ( dated June 2003 [revised 2008]) for guidance. 21 The LST methodology assists lead agencies in their project- specific analysis of the potential localized impacts associated with proposed projects. LSTs represent the maximum emissions of NOX, CO, PM10, and PM2.5 generated at a project site that are not expected to cause or contribute to an exceedance of the CAAQS or NAAQS ( the more stringent of the two). 22 The SCAQMD’ s methodology states that “off-site mobile emissions from the Project should not be included in the emissions compared to LSTs.” Therefore, only the emissions included in the CalEEMod “ on-site” emissions outputs were considered for the LST analysis.
The construction LSTs are based on the ambient concentrations of that pollutant for each SRA, distance to the nearest sensitive receptor, and daily acres disturbed. The project site is located in SCAQMD SRA 16 (North Orange County). The nearest sensitive receptors to the project site are residential uses located approximately 765 feet (233 meters) to the southeast.
Since CalEEMod calculates construction emissions based on the number of equipment hours and the maximum daily soil disturbance activity possible for each piece of equipment, Table 12:
Equipment- Specific Grading Rates was used to determine the maximum daily disturbed acreage for the construction LST analysis. 23
Table 12: Equipment- Specific Grading Rates
Construction
Phase
Equipment
Type
Equipment
Quantity
Acres Graded
per 8-Hour Day
Operating Hours
per Day
Acres Graded
per Day
Grading
Graders 1 0.5 8 0.5
Dozers 1 0.5 8 0.5
Total 1
1 Total acres graded each day is based on the number of equipment hours and the maximum daily soil disturbance activity possible for each piece of equipment, not the total acreage of the project site.
Source: CalEEMod version 2022.1. Refer to Appendix A for model outputs.
Based on the daily construction equipment assumed for the Project and as identified in Table 12, Project construction is anticipated to disturb a maximum of 1-acre in a single day.
As the LST guidance provides thresholds for distances to sensitive receptors of 25, 50, 100, 200, and 500 meters and projects disturbing 1-, 2-, and 5-acres in size, the LSTs for 1-acre at 200 meters in SCAQMD SRA 16 were utilized for this analysis.
21 South Coast Air Quality Management District. (N.D.) Localized Significance Thresholds. http:// www.aqmd.gov/ home/ rulescompliance/ ceqa/air-quality-analysis-handbook/ localized-significance-thresholds. Accessed September 8, 2025. 22 Ibid.
23 South Coast Air Quality Management District. (2005). Sample Construction Scenarios for Projects Less than Five Acres in Size. https:// www.aqmd.gov/docs/default-source/ ceqa/ handbook/ localized-significance-thresholds/ final-sample-construction-scenarioreport.pdf?sfvrsn=2. Accessed September 8, 2025.
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Table 13: Localized Project Construction Emissions summarizes the localized emissions during each individual and overlapping construction phase.
Table 13: Localized Project Construction Emissions
Construction Phase
Maximum Daily Emissions ( pounds per day)1, 2
NOX CO PM10 PM2.5
Individual Construction Phases
Demolition ( 2027) 19.90 18.63 5.51 1.45
Site Preparation ( 2027) 27.97 28.28 6.28 3.70
Grading ( 2027) 14.23 17.27 2.44 1.44
Infrastructure Improvements ( 2027) 3.66 5.14 0.10 0.09 Infrastructure Improvements ( 2028) 3.58 5.14 0.09 0.08 Building Construction ( 2027) 9.39 12.94 0.34 0.31
Building Construction ( 2028) 8.92 12.94 0.30 0.28
Architectural Coating ( 2028) 0.81 1.12 0.02 0.01
Paving ( 2028) 6.63 9.91 0.26 0.24
Overlapping Construction Phases3
Infrastructure Improvements + Building
Construction ( 2027) 13.05 18.08 0.44 0.40
Infrastructure Improvements + Building
Construction ( 2028) 12.50 18.08 0.39 0.36
Building Construction + Paving ( 2028) 15.55 22.85 0.56 0.51 Maximum Emissions 27.97 28.28 6.28 3.70
SCAQMD Localized Screening Threshold
1-acre of disturbance at 200 meters) 159 1,975 53 20
Threshold Exceeded? No No No No
1 As recommended by the SCAQMD, emissions were calculated using CalEEMod version 2022.1 and the worst-case seasonal maximum daily emissions are reported.
2 SCAQMD Rule 403 Fugitive Dust applied for construction emissions. SCAQMD Rule 403 reduction/ credits include: properly maintain mobile and other construction equipment; replace ground cover in disturbed areas quickly; water exposed surfaces three times daily; water all haul roads three times daily; and limit speeds on unpaved roads to 15 miles per hour. Reductions percentages from the SCAQMD CEQA Handbook (Tables XI-A through XI-E) were applied. 3 Totals may not add up exactly due to rounding in the modeling calculations.
NO2 = nitrogen dioxide; CO = carbon monoxide; PM10 = coarse particulate matter; PM2.5 = fine particulate matter, SCAQMD = South Coast Air Management District
Source: CalEEMod version 2022.1. Refer to Appendix A for model outputs.
As shown in Table 13, pollutant emissions on the peak day of construction would not exceed the respective SCAQMD LSTs and therefore would not result in substantial concentrations of pollutants at the nearest sensitive receptors or cause or contribute to an exceedance of the CAAQS or NAAQS.
Impacts associated with localized Project construction emissions would be less than significant.
Less Than Significant Impact: Airborne Fungus. Coccidioidomycosis, commonly known as Valley Fever, is a lung infection caused by inhaling airborne spores of the Coccidioides immitis fungus.
These spores are typically found in soil and can become airborne when the ground is disturbed by wind, construction, farming, or other soil-disrupting activities. Once inhaled, the spores transform into spherules in the lungs, which grow and release endospores, continuing the infection cycle.
Symptoms range from mild flu-like illness to more severe respiratory conditions, with fatigue, AO
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cough, rash, and joint pain being the most common. While most healthy individuals recover fully within six months without treatment and gain lifelong immunity, certain populations ( e.g., immunocompromised individuals) are at higher risk for developing severe or disseminated disease.
Diagnosis requires laboratory testing, including serology, cultures, or microscopic examination.
Though not contagious between people, Valley Fever poses a significant public health concern in endemic areas. The fungus is endemic to the southwestern United States, including parts of California such as the Antelope Valley. However, the Project site is not located in an endemic area for Valley Fever. 24 Therefore, impacts would be less than significant.
Less Than Significant Impact: Localized Operational Emissions. According to the SCAQMD LST methodology, LSTs would apply to the operational phase of a project only if it includes stationary sources or attracts mobile sources that may spend long periods queuing and idling at the project site ( e.g. warehouse or transfer facilities). Since the Project proposes a warehouse building, the operational LST protocol is conservatively applied to both the stationary source emissions and a portion of the mobile source emissions.
The LST analysis only includes on-site sources. However, the CalEEMod model outputs do not separate on- and off-site emissions for mobile sources. For a worst-case scenario assessment, the emissions shown in Table 14: Localized Project Operational Emissions, conservatively include all on-site stationary sources, on-site emergency fire pump, on-site off-road forklifts, and on-site mobile sources, since a portion of mobile sources could include truck vehicles idling on the site. 25 The project site is located in SCAQMD SRA 16 ( North Orange County). The nearest sensitive receptors to the project site are residential uses located approximately 765 feet (233 meters) to the southeast. The project site is approximately 4.8 acres. The LST guidance provides thresholds for distances to sensitive receptors of 25, 50, 100, 200, and 500 meters and for projects 1, 2, and 5 acres in size. Since LSTs increase with acreage, the LSTs for 5-acres at 200 meters in SCAQMD SRA 16 were utilized for this analysis.
Table 14: Localized Project Operational Emissions
Source
Maximum Daily Emissions ( pounds per day)1
NOX CO PM10 PM2.5
On-site Emission Sources ( Area, Energy, Mobile –
Trucks, Emergency Fire Pump, and Off-Road
Forklifts) 1, 2
0.52 8.13 0.08 0.04
SCAQMD Localized Screening Threshold
5-acre project site at 200 meters) 249 3,605 19 8
Threshold Exceeded? No No No No
1 Mobile on-site emissions were calculated using the following: mobile on-site emissions = (vehicle on-site trip distance/ vehicle total trip distance) * mobile emissions; where it is conservatively assumed the vehicle on-site trip distance is conservatively assumed to be approximately 1-mile and the vehicle total trip distance modeled in CalEEMod is 33.2-miles. 2 Totals may not add up exactly due to rounding in the modeling calculations.
NO2 = nitrogen dioxide; CO = carbon monoxide; PM10 = coarse particulate matter; PM2.5 = fine particulate matter, SCAQMD = South Coast Air Management District
Source: CalEEMod version 2022.1. Refer to Appendix A for model outputs. 24 California Department of Public Health, Valley Fever , https:// www.cdph.ca.gov/ Programs/ CID/ DCDC/ Pages/ ValleyFeverBasics. aspx, accessed October 2025.
25 The on-site one-way trip length is conservatively assumed to be approximately 1-mile, which is approximately 3 percent of the 33.2-mile truck trip length modeled in CalEEMod.
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Table 14 shows the peak day operational pollutant emissions would not exceed the respective SCAQMD LSTs and therefore would not result in substantial concentrations of pollutants at the nearest sensitive receptors or cause or contribute to an exceedance of the CAAQS or NAAQS.
Impacts associated with localized Project operational emissions would be less than significant.
Less Than Significant Impact: Criteria Pollutant Health. On December 24, 2018, the California Supreme Court issued an opinion identifying the need to provide sufficient information connecting a project’ s air emissions to health impacts or explain why such information could not be ascertained ( Sierra Club v. County of Fresno [ Friant Ranch, L.P.] [ 2018] Cal.5th, Case No. S219783).
The SCAQMD has set its CEQA significance thresholds based on the FCAA, which defines a major stationary source ( in extreme O3 nonattainment areas such as the SCAB) as emitting 10 tons per year. The thresholds correlate with the trigger levels for the federal New Source Review ( NSR) Program and SCAQMD Rule 1303 for new or modified sources. The NSR Program 26 was created by the FCAA to ensure that stationary sources of air pollution are constructed or modified in a manner that is consistent with attainment of health-based NAAQS, which establish the levels of air pollutant emissions necessary, with an adequate margin of safety, to protect the public health.
Therefore, projects that do not exceed the SCAQMD’ s mass emissions thresholds and LSTs would not violate any NAAQS or CAAQS or contribute substantially to an existing or projected air quality violation. As such, no criteria pollutant health impacts would occur.
As previously discussed, localized impacts of on-site Project emissions on nearby sensitive receptors were found to be less than significant ( refer to Table 13 and Table 14). The LSTs represent the maximum emissions from a project that are not expected to cause or contribute to an exceedance of the most stringent NAAQS or CAAQS. The LSTs were developed by the SCAQMD based on the ambient concentrations of that pollutant for each SRA and distance to the nearest sensitive receptor. The NAAQS and CAAQS establish the levels of air pollutant emissions necessary, with an adequate margin of safety, to protect public health, including protecting the health of sensitive populations. Information on health impacts related to exposure to O3 and particulate matter emissions published by the U.S. EPA and CARB have been summarized and discussed above in the Regulatory section. Since Project- related emissions would not exceed the regional thresholds or the LSTs, Project-related emissions would not exceed the CAAQS or NAAQS or cause an increase in the frequency or severity of existing violations of air quality standards. Therefore, sensitive receptors would not be exposed to criteria pollutant levels in excess of the health- based ambient air quality standards. Impacts associated with Project criteria pollutant health effects would be less than significant.
Less Than Significant Impact: Toxic Air Contaminants
Construction. Project construction would result in temporary increases in TACs emissions such as DPM from off-road diesel equipment and vehicle trips. The use of diesel-powered construction equipment and vehicle trips would be temporary and episodic. The duration of exposure would be short, and the exhaust from construction equipment dissipates rapidly. The amount to which the receptors are exposed ( a function of concentration and duration of exposure) is the primary factor 26 Code of Federal Regulation ( CFR) [ i.e., PSD ( 40 CFR 52.21, 40 CFR 51.166, 40 CFR 51.165 (b)), Nonattainment NSR ( 40 CFR 52.24, 40 CFR
51.165, 40 CFR part 51, Appendix S).
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used to determine health risk ( i.e., potential exposure to TAC emission levels that exceed applicable standards). Health- related risks associated with DPM emissions are primarily associated with long- term exposure and associated risk of contracting cancer. As such, the calculation of cancer risk associated with exposure to TACs is typically calculated based on a long-term period of exposure. Based on updated guidelines from the Office of Environmental Health Hazard Assessment, cancer risks are based on constant daily exposure for 30 years for off-site residential receptors and 25 years for off-site worker receptors. Construction activities would occur over an approximately 13-month period, which would constitute approximately three percent of the residential and four percent of the worker exposure durations. Furthermore, Project compliance with California regulations ( e.g., California Code of Regulations [ CCR], Title 13, Sections 2485 and 2449), which reduce DPM and criteria pollutant emissions from in-use off-road diesel- fueled vehicles and limit the idling of heavy- duty construction equipment to no more than five minutes, would further reduce nearby sensitive receptors’ exposure to temporary and variable DPM emissions. TAC impacts during Project construction would be less than significant.
Operations. The Project would generate toxic air contaminants ( i.e., DPM) from heavy- duty truck operations. As noted above, cancer risks are based on constant daily exposure for 30 years for offsite residential receptors and 25 years for off-site worker receptors according to OEHHA methodologies. The nearest sensitive receptors to the project site are residential uses located approximately 765 feet to the southeast. Therefore, the nearest sensitive receptors would have limited exposure to on-site emissions due to distance attenuation and the highly dispersive nature of TACs. Additionally, CAPCOA guidance advises avoiding siting sensitive uses within 1,000 feet of distribution centers with more than 100 trucks per day. Under existing conditions, the project site currently generates 28 truck trips per day. As the Project is expected to generate 66 truck trips per day, the Project would result in a net increase of 38 truck trips. Therefore, the Project- generated truck trips would be well below the 100 trucks per day threshold. Therefore, significant health risks related to operational DPM emissions are not anticipated and a quantitative health risk assessment is not required. Additionally, the Project’ s criteria pollutant emissions would remain below SCAQMD’ s thresholds for regional and local air quality standards, indicating no significant longterm health impacts; refer to Table 11 and Table 14. Therefore, the Project would not expose sensitive receptors to substantial pollutant concentrations of TACs during operations. Impacts associated with Project operational TAC emissions would be less than significant.
Less Than Significant Impact: Carbon Monoxide Hotspots. An analysis of CO “ hot spots” is needed to determine whether the change in the level of service of an intersection from the proposed Project would have the potential to result in exceedances of the CAAQS or NAAQS. It has long been recognized that CO exceedances are caused by vehicular emissions, primarily when vehicles are idling at intersections. Vehicle emissions standards have become increasingly stringent in the last 20 years. Currently, the CO standard in California is a maximum of 3.4 grams per mile for passenger cars (requirements for certain vehicles are more stringent). With the turnover of older vehicles, introduction of cleaner fuels, and implementation of control technology on industrial facilities, CO concentrations have steadily declined.
Accordingly, with the steadily decreasing CO emissions from vehicles, even very busy intersections do not result in exceedances of the CO standard. CO attainment within the SCAB was thoroughly AOO
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analyzed as part of the SCAQMD’ s 2003 AQMP. The SCAB was re-designated as attainment in 2007 and is no longer addressed in the SCAQMD’ s AQMP.
The 2003 AQMP is the most recent AQMP that addresses CO concentrations. As part of the SCAQMD CO hot spot analysis, the Wilshire Boulevard and Veteran Avenue intersection, one of the most congested intersections in Southern California with an ADT volume of approximately 100,000 vehicles per day, was modeled for CO concentrations. This modeling effort identified a CO concentration high of 4.6 parts per million (ppm), which is well below the 35-ppm federal standard.
The proposed project considered herein would not produce the volume of traffic required to generate a CO hot spot in the context of SCAQMD’ s 2003 CO hot-spot analysis. As the CO hotspots were not experienced at the Wilshire Boulevard and Veteran Avenue intersection even as it accommodates 100,000 vehicles daily, it can be reasonably inferred that CO hotspots would not be experienced at any intersection within the Project vicinity from the 212 daily vehicle trips attributable to the Project. As such, impacts associated with Project CO hot spots would be less than significant.
d) Result in other emissions ( such as those leading to odors adversely affecting a substantial number of people?
Less Than Significant Impact: Construction Odor. Project construction would generate odors from equipment diesel exhaust, architectural coatings containing VOCs, and paving activities. However, these odors would be temporary, are not expected to affect a substantial number of people and would disperse rapidly. Additionally, the Project would be required to comply with SCAQMD Rule 402 ( Nuisance) to prevent odor nuisances on sensitive receptors. SCAQMD Rule 402 ( Nuisance) states:
A person shall not discharge from any source whatsoever such quantities of air contaminants or other material which cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property.”
Construction odors would be further minimized through Project compliance with heavy- duty construction equipment idling requirements ( CCR, Title 13, Sections 2449( d)(3) and 2485,) and established regulations that address construction materials storage, use, and disposal ( Code of Federal Regulation, Part 1926 – Safety and Health Regulations for Construction, Subpart H – Materials Handling, Storage Use and Disposal, et al.). As such, impacts associated with Project construction odors would be less than significant.
Less Than Significant Impact: Operational Odor: The SCAQMD CEQA Air Quality Handbook identifies certain land uses as potentially significant sources of odors. These land uses include agriculture ( farming and livestock), wastewater treatment plants, food processing plants, chemical plants, composting facilities, refineries, landfills, dairies, and fiberglass molding. The Project proposes the development of a warehouse, which would not involve the types of uses that would emit objectionable odors affecting considerable numbers of people. Therefore, the Project would not include any of the land uses that have been identified by the SCAQMD as significant odor sources. Impacts associated with Project operational odor would be less than significant.
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4.4 BIOLOGICAL RESOURCES
ENVIRONMENTAL IMPACTS
Issues
Potentially
Significant
Issues
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
4. BIOLOGICAL RESOURCES. Would the project:
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the
California Department of Fish and Game or U.S. Fish and Wildlife Service?
X
b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or US Fish and Wildlife
Service?
X
c) Have a substantial adverse effect on State or federally protected wetlands ( including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
X
d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with
established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
X
e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
X
f) Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community Conservation
Plan, or other approved local, regional, or State habitat conservation plan?
X
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? Less Than Significant Impact. The project site is located within an urbanized area and is currently developed with a business park and associated improvements, including surface parking and ornamental landscaping. The surrounding area is developed and comprised primarily of industrial and commercial uses. As indicated in The Fullerton Plan EIR, the areas outside of the West Coyote AO
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Hills and East Coyote Hills Focus Areas are primarily developed and do not contain areas of naturally vegetated vacant land with natural vegetation supportive of sensitive species.
The project site and surrounding area do not provide suitable habitat for any special status species, are devoid of sensitive habitat, and do not contain wetlands or wetland habitat. The project site does contain ornamental vegetation with the potential of providing suitable nesting habitat for birds. The Project would be required to comply with standard condition (SC) BIO-1, which would require construction activities to be completed in compliance with the Migratory Bird Treaty Act MBTA) and Sections 3503, 3503.5, 3513 of the California Fish and Game Code (CFGC). Under MBTA provisions, it is unlawful “ by any means or manner to pursue, hunt, take, capture ( or) kill” any migratory birds except as permitted by regulations issued by the USFWS. The term “take” is defined by USFWS regulation to mean to “pursue, hunt, shoot, wound, kill, trap, capture or collect” any migratory bird or any part, nest or egg of any migratory bird covered by the conventions, or to attempt those activities. Following compliance with SC BIO-1, the proposed Project’ s potential impacts to nesting migratory birds would be less than significant and no mitigation is required. b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or US Fish and Wildlife Service? Or,
c) Have a substantial adverse effect on State or federally protected wetlands ( including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological? No Impact. As noted above, the project site is located within an urbanized area and is currently developed with a business park and associated improvements, including surface parking and ornamental landscaping. The surrounding area is developed and comprised primarily of industrial and commercial uses. Based on review of the U.S. Fish and Wildlife Service ( USFWS) National Wetlands Inventory, the project site does not contain any mapped features. 27 Further, the project site does not contain any water resources (e.g., streams, creeks, channels, vernal pools) nor would any of the proposed land uses potentially affect wetlands. The project site does not contain riparian habitats, sensitive natural communities, or wetlands. Therefore, the proposed Project would not have a substantial adverse effect on any riparian habitat, other sensitive natural community, or federally protected wetlands, and no impact would occur. d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
Less Than Significant Impact. A wildlife corridor can be defined as a physical feature that links wildlife habitats, often consisting of native vegetation that joins two or more larger areas of similar wildlife habitat. Corridors enable migration, colonization, and genetic diversity through interbreeding and are therefore critical for the movement of animals and the continuation of viable populations. As indicated in The Fullerton Plan EIR, although the East Coyote Hills and West Coyote Hills areas contain significant plant and animal populations, these areas are isolated from one another by three miles of urbanization and are surrounded by developed areas. Therefore, they do not provide reliable connections to other large habitat patches. Areas outside of the East Coyote 27 U.S. Fish and Wildlife Service. N.D. National Wetlands Inventory. https:// fwsprimary.wim.usgs.gov/ wetlands/ apps/ wetlands-mapper.
Accessed September 2025.
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Hills and West Coyote Hills areas, such as the project site, are urbanized and generally do not function as wildlife corridors.
As indicated, the project site is located within an urbanized area and is currently developed with a business park and associated improvements, including surface parking and ornamental landscaping. The surrounding area is developed and comprised primarily of industrial and commercial uses. The project site and surrounding area do not serve as a native resident or migratory wildlife corridor or wildlife nursery site, as the area is completely developed and there are no open space areas or corridors within or adjacent to the project site.
While the project site is not a wildlife corridor, it has the potential to support nesting migratory birds that are protected by the MBTA and CFGC. Therefore, potential impacts could occur if vegetation clearing is undertaken during the breeding season. The Project would be required to comply with SC BIO-1, which outlines MBTA and CFGC requirements including pre-construction nesting bird surveys if avoidance during the nesting season is not feasible. If active nests are identified, suitable buffers would be established and the buffer areas would be avoided until the nests are no longer occupied, and the juvenile birds can survive independently from the nests.
Therefore, following compliance with SC BIO- 1, the proposed Project’ s potential impacts to nesting migratory birds would be less than significant and no mitigation is required. e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Less Than Significant Impact. FMC Chapter 9.06, Community Forestry, addresses the planning, planting, maintenance, and removal of all trees and other landscape material in any street or other public area; over any landscape material in any street median, parkway strip or other landscaped portion of a public right-of-way; over trees and other landscape material in other public spaces under the jurisdiction of the City such as parks, trails and public buildings; and over certain trees on private property. It also allows for the designation and protection of Landmark Trees.
The Project would involve the removal of existing trees on the property, including along the frontage of the project site; no City trees would be removed and no Landmark Trees are located on the site. The Project would provide new trees, shrubs, and ground cover within the project site.
The proposed trees and landscaping would be in accordance with the City’ s requirements. The Project would be required to comply with SC BIO- 2, which would require approval of a plot plan prior to the issuance of a building permit, in compliance with FMC Section 9.06.090, Planting Trees.
Implementation of this standard condition would ensure impacts remain less than significant. f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation plan? No Impact. The project site is not located within the boundaries of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation plan. Therefore, the Project would not conflict with any of these plans and no impact would occur.
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Standard Conditions and Requirements
SC BIO-1 Nesting Migratory Birds. To ensure compliance with the Migratory Bird Treaty Act MBTA) and California Fish and Game Code (CFGC) Sections 3503, 3503.5, and 3513 and to avoid potential impacts to nesting birds, vegetation clearing, and ground- disturbing activities shall be conducted outside of the bird nesting season ( generally January 15 to August 31 for raptors and February 15 to August 31 for other bird species). If avoidance of the nesting season is not feasible, then a qualified biologist shall conduct a nesting bird survey within seven days prior to any disturbance of the site, including but not limited to vegetation clearing, disking, demolition activities, and grading. If the qualified biologist determines that no active bird or raptor nests occur, the activities shall be allowed to proceed without any further requirements.
If active nests of any species protected by the MBTA or CFGC are identified, the biologist shall establish suitable disturbance limit buffers around the nests marked using flagging or staking. The disturbance limit buffer size shall depend on the site conditions, level of activity within the buffer, and species observed. The disturbance limit buffer zones shall be avoided until the nests are no longer occupied. Any active nests shall be monitored by a qualified biologist during active construction, at a frequency determined using their best professional judgment, but not less than twice per week. If potential affects to nesting birds are observed, avoidance and minimization measures may be adjusted, and construction activities stopped or redirected by the qualified biologist using their best professional judgement to avoid take of nesting birds. Once a nest is no longer occupied and the juvenile birds can survive independently from the nest, the project can proceed without further regard to the nest site.
SC BIO-2 Tree Planting. All tree plantings, removals, or alterations associated with the project shall be conducted in accordance with the requirements set forth in the Fullerton Community Forestry Ordinance ( Fullerton Municipal Code, Chapter 9.06 et seq.). Specifically, in compliance with Section 9.06.090, Planting Trees, prior to the issuance of a building permit, the Applicant/ Developer shall submit a Plot Plan of the proposed development so the Director of Development Services can determine the tree requirements for site development. The plot plan shall:
1. Clearly show all existing trees, noting location, species, size, and condition;
2. Note whether existing trees will be retained, removed, or relocated;
3. Show proposed utilities, driveways, sidewalks and tree planting locations, and the size and species of proposed street trees; and
4. Conform with ground and aerial setback specifications, as defined in the Community Forest Management Plan.
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4.5 CULTURAL RESOURCES
ENVIRONMENTAL IMPACTS
Potentially
Significant
Issues
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
5. CULTURAL RESOURCES. Would the project:
a) Cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064. 5?
X
b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5? X
c) Disturb any human remains, including those interred
outside of dedicated cemeteries?
X
A Cultural Resources Inventory and Evaluation Report has been prepared for the proposed Project and is included in Appendix B: Cultural Resources Memorandum in this Initial Study and summarized below. a) Cause a substantial adverse change in the significance of a historical resource pursuant to in Section 15064. 5?
No Impact. State CEQA Guidelines Section 15064. 5 defines “ historic resources” as resources listed in the California Register of Historical Resources or determined to be eligible by the California Historical Resources Commission for listing in the California Register of Historic Resources. 28 CEQA allows local historic resource guidelines to serve as the California Register of Historic Resources criteria if enacted by local legislation to act as the equivalent of the State criteria. The project site is currently developed with an existing five-building multi-tenant business park that was constructed in 1983. Review of historical aerial imagery dating back to 1952 shows that the project site was planted agricultural land. By 1980, large warehouses were constructed adjacent to the project site to the east, west, and south. By 1987, the project site was developed into its current configuration with five buildings and a parking area.
A cultural resources records search was conducted on July 22, 2025 through the South Central Coastal Information Center (SCCIC) for the project site and a 0.5-mile buffer. Results indicated that no cultural resources have been previously recorded on and that no cultural studies have been conducted at the project site ( Appendix B). Results noted that 17 cultural studies have been conducted within the 0.5-mile buffer that resulted in the recordation of one cultural resource. The resource, identified as P-19-18604/ P-30-176663, is located approximately 0.4 mile to the north of the project site and is noted as the Burlington Northern Santa Fe (BNSF, formerly Atchison, Topeka, and Santa Fe) Railway, originally constructed in 1888.
In addition, as part of the Cultural Memorandum prepared for the Project, a review of the following cultural resource databases were conducted: National Register of Historic Places, California Register of Historic Places, National Historic Landmarks, and the Built Environment Resources 28 California Public Resources Code Section 5020.1(k), Section 5024.1(g).
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Directory. A review of resource databases and repositories did not result in the identification of any present cultural resources in the project site.
Additionally, 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. 29 Therefore, no known historical resources pursuant to Section 15064. 5 were identified on the project site, and the proposed Project would not cause a change in the significance of a historical resource. No impact would occur and no mitigation is required.
b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064. 5?
Less ThanSignificant Impact with Mitigation Incorporated. As stated above, results of the records search indicate that 17 cultural studies have been conducted within the 0.5-mile buffer that resulted in the recordation of one cultural resource. The one resource, identified as P-19-18604/ P30-176663, is located approximately 0.4 mile to the north of the project site and is noted as the Burlington Northern Santa Fe (BNSF, formerly Atchison, Topeka, and Santa Fe) Railway, originally constructed in 1888. No resources were documented within or adjacent to the project site. 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.
Geologic maps indicate the project site is underlaid by young alluvial fan deposits ( Qyf) from the Holocene and late Pleistocene periods. These deposits are known to have a higher potential to contain archeological resources. The Cultural Memorandum prepared for the Project concluded that due to the presence of Holocene- age subsurface sediments and the proximity to available freshwater sources in the vicinity, the sensitivity of the project site for containing intact buried prehistoric archaeological resources would be considered moderate to high. However, due to the absence of known prehistoric archaeological sites in the immediate area and the prior construction and development of the existing business park, the potential to encounter intact buried archaeological resources on the site is considered low (Appendix B).
As such, archaeological resources are not anticipated to occur; however, there is the potential for unknown or undiscovered resources to be uncovered through construction activities. Therefore, the proposed Project would be subject to MM CUL-1, which requires that in the event of an inadvertent discovery of a cultural resource, earthwork and ground-disturbing activities would halt within 60 feet and the Project archaeologist would coordinate with the City and consulting Tribes to ensure appropriate identification and evaluation of the artifact and resource. If resources are potentially significant, the archaeologist would prepare a mitigation plan for approval by the City and consulting tribe. Therefore, with implementation of MM CUL-1, the proposed Project would not cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines Section 15064. 5; impacts would be less than significant impact with mitigation incorporated.
29 City of Fullerton. 2012. The Fullerton Plan Final Program EIR – Section 5.10 Cultural Resources. Retrieved from:
https:// www.cityoffullerton. com/ home/ showpublisheddocument/ 3686/ 637470826615030000. Accessed September 2025.
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c) Disturb any human remains, including those interred outside of dedicated cemeteries? Less Than Significant Impact with Mitigation Incorporated. No dedicated cemeteries are on or near the project site. The disturbance of most Native American human remains is typically in association with prehistoric archaeological sites. As discussed previously, the project site is not near an identified archaeological resource. Given the extent of on-site disturbances the project site has a low potential for intact archaeological resources. However, as noted above, due to the presence of Holocene- age subsurface sediments and proximity to water, there is low potential for the Project’ s ground- disturbing activities to encounter human remains. Notwithstanding, if previously unknown human remains are discovered during the Project’ s ground- disturbing activities, a substantial adverse change in the significance of such a resource could occur. If human remains are found, implementation of MM TCR- 2 would be required, which details compliance with California State Health and Safety Code Section 7050.5 and Public Resources Code Section 5097.98 for inadvertent discovery of human remains. Therefore, with implementation of MM TCR- 2, the proposed Project would not disturb any human remains, including those interred outside of a dedicated cemetery. A less than significant impact would occur with mitigation incorporated.
Mitigation Measures
MM CUL-1 In the event that archaeological resources are inadvertently unearthed or encountered during demolition, excavation, and/ or grading activities, all work within 60 feet of the find shall cease and an archaeologist that meets Secretary of Interior professional qualifications in archaeology and the consulting Tribes, if any, shall be contacted. The archaeologist shall record and evaluate the resource for potential significance. The lead agency shall confer with the consulting Tribes, if any, regarding the significance of the resource and its potential as a Tribal Cultural Resource ( TCR) under CEQA. Should the archaeologist and/ or consulting Tribes have concerns that the find is potentially significant, the archaeologist shall prepare a mitigation plan for review and approval by the lead agency and any consulting Tribes. If avoidance of the resource( s) is not feasible, salvage operation requirements pursuant to State CEQA Guidelines Section 15064. 5 shall be followed.
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4.6 ENERGY
ENVIRONMENTAL IMPACTS
Potentially
Significant
Issues
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
6. ENERGY. Would the project:
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or
operation?
X
b) Conflict with or obstruct a State or local plan for
renewable energy or energy efficiency?
X
Energy calculations and results are included in Appendix C: Energy Calculations and summarized below.
Background
Energy consumption is analyzed due to the potential direct and indirect environmental impacts associated with the Project. Such impacts include the depletion of non-renewable resources and pollutant emissions during short-term construction and long- term operational phases.
Electricity. Over the past 15 years, electricity generation in California has undergone a transition.
Historically, California has relied heavily on oil- and gas-fired plants to generate electricity. Spurred by regulatory measures and tax incentives, California’ s electrical system has become more reliant on renewable energy sources, including cogeneration, wind energy, solar energy, geothermal energy, biomass conversion, transformation plants, and small hydroelectric plants. Unlike petroleum production, electricity generation is not usually tied to the location of the fuel source and can be delivered over great distances via the electrical grid.
Energy capacity, or electrical power, is generally measured in watts (W) while energy use is measured in watt-hours (Wh). For example, if a light bulb has a capacity rating of 100 W, the energy required to keep the bulb on for one hour would be 100 Wh. If ten 100 W bulbs were on for one hour, the energy required would be 1,000 Wh or one kilowatt- hour (kWh). On a utility scale, a generator’ s capacity is typically rated in megawatts ( MW), which is one million watts, while energy use is measured in megawatt- hours (MWh) or gigawatt- hours (GWh), which is one billion watt-hours.
Southern California Edison ( SCE) is the City’ s electricity provider and provides electricity to approximately 15 million people, 180 incorporated cities, 15 counties, 5,000 large businesses, and 280,000 small businesses throughout its 50,000-square-mile service area. 30 SCE produces and purchases their energy from a mix of conventional and renewable generating sources. Table 15: Energy Resources Used to Generate Electricity for South California Edison identifies the SCE 2023 electric power mix compared to the Statewide 2023 power mix.
30 South California Edison. ( N.D.). By the Numbers: Who We Serve. Retrieved from: https:// www.sce.com/ about-us/ who-we-are. Accessed September 8, 2025.
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Table 15: Energy Resources Used to Generate Electricity for South California Edison Energy Resources 2023 SCE Power Mix 2023 CA Power Mix
Eligible Renewable1 37.6% 36.9%
Biomass and Biowaste 0.1% 2.1%
Geothermal 5.2% 4.8%
Eligible Hydroelectric 0.7% 1.8%
Solar 19.8% 17.0%
Wind 11.7% 11.2%
Coal 0.0% 1.8%
Large Hydroelectric 4.5% 11.7%
Natural Gas 20.0% 36.6%
Nuclear 9.1% 9.3%
Other 0.1% 0.1%
Unspecified Sources of Power2 28.8% 3.7%
Total 100.0% 100.0%
1 The eligible renewable percentage above does not reflect the Renewable Portfolio Standard compliance, which is determined using a different methodology.
2 Electricity that has been purchased through open market transactions and are not traceable to specific generation sources.
Source: South California Edison. (N.D.). 2023 Power Content Label, Southern California Edison Company. https:// www.energy. ca.gov/ filebrowser/ download/ 7362. Accessed September 8, 2025.
According to the California Energy Commission ( CEC), in 2024, the total electricity demand for the SCE service area was approximately 282,783 GWh, while electricity use attributable to the County was approximately 19,225 GWh. 31 The residential, non-residential, and total electricity demand between 2014 and 2024 in the County is summarized in Table 16: Annual Orange County Electricity Consumption. In 2014, residential uses comprised 35 percent of the County’ s electricity demand, while non-residential uses comprised 65 percent. By 2024, these percentages changed to 37 percent for residential uses and 41 percent for non-residential uses. Although the total electricity demand has fluctuated from year to year, overall, between 2014 and 2024, the County’ s total electricity demand decreased by approximately seven percent.
31 California Energy Commission. ( 2025). Electricity Consumption. Retrieved from: https:// www.energy. ca.gov/ data-reports/ energyalmanac/ california- electricity- data/ california- energy- consumption- dashboards- 0. Accessed September 8, 2025.
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Table 16: Annual Orange County Electricity Consumption
Year
Million Kilowatt-Hour (GWh)
Residential Electricity
Consumption
Non-residential Electricity
Consumption
Total Electricity
Consumption
2024 7,136.36 12,088.79 19,225.15
2023 6,863.69 11,989.58 18,853.26
2022 7,248.21 12,324.02 19,572.24
2021 7,079.36 11,649.68 18,729.04
2020 7,499.77 11,663.68 19,163.45
2019 6,763.44 12,641.46 19,404.90
2018 6,778.06 13,154.40 19,932.46
2017 6,760.51 13,318.86 20,079.37
2016 6,672.07 13,512.77 20,184.84
2015 6,892.71 13,840.86 20,733.57
2014 6,987.88 13,622.43 20,610.31
Source: California Energy Commission. ( 2025). Electricity Consumption. https:// www.energy.ca.gov/data-reports/ energy-almanac/ californiaelectricity- data/ california- energy- consumption- dashboards- 0. Accessed September 8, 2025.
Transportation. Of California’ s total energy usage, the breakdown by sector is 44.5 percent transportation, 21.4 percent industrial, 17.1 percent residential, and 17.0 percent commercial. 32 Transportation energy demand in California is largely related to vehicular traffic (e.g., passenger vehicles, light duty trucks, semi- trucks, etc.), with most transportation- related energy demand currently met by gasoline and diesel fuel. Gasoline and diesel fuel is supplied to City residents and non-residents by widely distributed service stations both inside and around the City. Table 17: Annual Orange County Automotive Fuel Consumption summarizes the gasoline and diesel fuel demand between 2014 and 2024 in the County. As shown in the table, between 2014 and 2024, the County’ s gasoline consumption has increased by approximately 0.003 percent and diesel consumption has increased by approximately 18 percent.
Table 17: Annual Orange County Automotive Fuel Consumption Year Million Gallons
Gasoline Consumption Diesel Consumption
2024 1,142.03 135.73
2023 1,164.40 134.66
2022 1,181.10 133.11
2021 1,191.38 131.23
2020 1,053.93 126.41
2019 1,214.39 126.23
2018 1,192.66 125.69
2017 1,200.68 128.63
2016 1,198.45 125.02
2015 1,165.32 117.23
2014 1,138.33 114.86
Source: California Air Resources Board. (2022). EMFAC2021, Emissions Inventory. https:// arb.ca.gov/emfac/emissionsinventory/ cd60f29daaedd924a75a9316202d7f56a9b573e5. Accessed September 8, 2025. 32 United States Energy Information Administration. (2025). California State Profile and Energy Estimates, California Energy Consumption by End-Use Sector. Retrieved from: https:// www.eia.gov/ state/? sid=CA#tabs-2. Accessed September 8, 2025.
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Regulations
Energy and Independence Security Act of 2007
The Energy Independence and Security Act ( EISA; Public Law 110-140) was signed into law by former President George W. Bush on December 19, 2007. The purpose of the EISA is to achieve energy security in the United States by increasing renewable fuel production, improving energy efficiency and performance, protecting consumers, improving vehicle fuel economy, and promoting research on GHG capture and storage. Under the EISA, the Renewable Fuel Standard ( RFS) program ( RFS2) was expanded in several key ways:
Expanded the RFS program to include diesel, in addition to gasoline; Increased the volume of renewable fuel required to be blended into transportation fuel; Established new categories of renewable fuel and set separate volume requirements for each; and
Required the U.S. EPA to apply lifecycle GHG performance threshold standards to ensure that each category of renewable fuel emits fewer GHGs than the petroleum fuel it replaces.
RFS2 lays the foundation for achieving significant reductions of GHG emissions from the use of renewable fuels, reducing imported petroleum, and encouraging the development and expansion of our nation’ s renewable fuels sector.
The EISA also includes a variety of new standards for lighting and for residential and commercial appliance equipment. The equipment includes residential refrigerators, freezers, refrigerator- freezers, metal halide lamps, and commercial walk-in coolers and freezers.
Renewable Portfolio Standards 33
In 2002, California established its Renewable Portfolio Standard (RPS) program with the goal of increasing the annual percentage of renewable energy in the State’ s electricity mix by the equivalent of at least one percent of sales, with an aggregate total of 20 percent by 2017. The California Public Utilities Commission CPUC) subsequently accelerated that goal to 2010 for retail sellers of electricity ( Public Utilities Code 399.15(b)(1)). Then-Governor Schwarzenegger signed Executive Order S-14-08 in 2008, increasing the target to 33 percent renewable energy by 2020. In September 2009, Governor Schwarzenegger continued California’ s commitment to the RPS by signing Executive Order S-21-09, which directs under its AB 32 authority to enact regulations to help the State meet its RPS goal of 33 percent renewable energy by 2020.
In September 2010, CARB adopted its Renewable Electricity Standard regulations, which require all of the State’ s load-serving entities to meet this target. In October 2015, then-Governor Brown signed into legislation Senate Bill (SB) 350, which requires retail sellers and publicly owned utilities to procure 50 percent of their electricity from eligible renewable energy resources by 2030. Signed in 2018, SB 100 revised the goal of the program to achieve the 50 percent renewable resources target by December 31, 2026, and to achieve a 60 percent target by December 31, 2030.
SB 100 established a further goal to have an electric grid that is entirely powered by clean energy by 2045.
Under SB 100, the State cannot increase carbon emissions elsewhere in the western grid or allow resource shuffling to achieve the 100 percent carbon-free electricity target. Approved in 2022, SB 1020 revised the 33 California Public Utilities Commission. (2025). Renewable Portfolio Standard (RPS) Program. Retrieved from: https:// www.cpuc.ca.gov/rps/.
Accessed September 2025.
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State policy to provide that eligible renewable energy resources and zero-carbon resources supply 90 percent of all retail sales of electricity to California end-use customers by December 31, 2035; 95 percent of all retail sales of electricity to California end-use customers by December 31, 2040; 100 percent of all retail sales of electricity to California end-use customers by December 31, 2045; and, 100 percent of electricity procured to serve all State agencies by December 31, 2035.
California Building Energy Efficiency Standards: Title 24, Part 6 The California Energy Code ( Title 24, Part 6) was created as part of the California Building Standards Code Title 24 of the CCR) by the California Building Standards Commission in 1978 to establish statewide building energy efficiency standards to reduce California’ s energy use. In general, Title 24 Energy Code is designed to reduce wasteful and unnecessary energy consumption in newly constructed and existing buildings. The CEC updates the Title 24 Energy Code every three years to allow consideration and possible incorporation of new energy efficiency technologies and methods. The Title 24 Energy Code conserve nonrenewable resources, such as natural gas, and ensure renewable resources are extended as far as possible to reduce the need for constructing new power plants.
In December 2024, the 2025 Title 24 Energy Code was approved by the California Building Standards Commission for inclusion into the California Building Standards Code. The 2025 Title 24 Energy Code encourages efficient electric heat pumps, establishes electric- ready requirements for new homes, expands solar photovoltaic and battery storage standards, strengthens ventilation standards, and more.
Buildings whose permit applications are applied for on or after January 1, 2026, must comply with the 2025 Title 24 Energy Code.
The Title 24 Energy Code include provisions applicable to all buildings, residential and non-residential, which describe requirements for documentation and certificates that the building meets the standards.
These provisions include mandatory requirements for efficiency and design of the following types of systems, equipment, and appliances: air conditioning systems; heat pumps; water chillers; gas- and oilfired boilers; cooling equipment; water heaters and equipment; pool and spa heaters and equipment; gasfired equipment including furnaces and stoves/ ovens; windows and exterior doors; joints and other building structure openings ( envelope); insulation and cool roofs; lighting control devices; and solar photovoltaic systems.
The standards include additional mandatory requirements for space conditioning ( cooling and heating), water heating, indoor and outdoor lighting systems, as well as equipment in non-residential, high-rise residential, and hotel or motel buildings. Mandatory requirements for low-rise residential buildings cover indoor and outdoor lighting, fireplaces, space cooling and heating equipment ( including ducts and fans), and insulation of the structure, foundation, and water piping. The standards require solar photovoltaic systems for new homes. In addition to the mandatory requirements, the standards call for further energy efficiency that can be provided through a choice between performance and prescriptive compliance approaches. Separate sections apply to low-rise residential and to non-residential, high-rise residential, and hotel or motel buildings. In buildings designed for mixed use (e.g., commercial and residential), each section must meet the standards applicable to that type of occupancy.
California Green Building Standards
The California Green Building Standards Code ( CCR, Title 24, Part 11), commonly referred to as the CALGreen Code, is a statewide mandatory construction code that was developed and adopted by the California Building Standards Commission and the California Department of Housing and Community AOO
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Development. CALGreen standards require new residential and commercial buildings to comply with mandatory measures under five topical areas: planning and design; energy efficiency; water efficiency and conservation; material conservation and resource efficiency; and environmental quality. CALGreen also provides voluntary tiers and measures that local governments may adopt which encourage or require additional measures in the five green building topics. The most recent update to the CALGreen Code was adopted in December 2024 (2025 CALGreen Code) and continues to improve upon the existing standards for new construction of, and additions and alterations to, residential and non-residential buildings.
Buildings whose permit applications are applied for on or after January 1, 2026, must comply with the 2025 CALGreen Code.
California Air Resources Board Scoping Plan
Adopted December 15, 2022, CARB’ s 2022 Scoping Plan for Achieving Carbon Neutrality ( 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. To achieve the targets of AB 1279, the 2022 Scoping Plan relies on existing and emerging fossil fuel alternatives and clean technologies, as well as carbon capture and storage. Specifically, the 2022 Scoping Plan focuses on zero-emission transportation; phasing out use of fossil gas use for heating homes and buildings; reducing chemical and refrigerants with high global warming potential ( GWP); providing communities with sustainable options for walking, biking, and public transit; displacement of fossil-fuel fired electrical generation through use of renewable energy alternatives ( e.g., solar arrays and wind turbines); and scaling up new options such as green hydrogen.
The key elements of the 2022 CARB Scoping Plan focus on transportation. Specifically, the 2022 Scoping Plan aims to rapidly move towards ZE transportation ( i.e., electrifying cars, buses, trains, and trucks), which constitutes California’ s single largest source of GHGs. The regulations that impact the transportation sector are adopted and enforced by CARB on vehicle manufacturers and are outside the jurisdiction and control of local governments. The 2022 Scoping Plan accelerates development of new regulations as well as amendments to strengthen regulations and programs already in place.
The Fullerton Plan
The Fullerton Plan establishes goals and policies aimed at sustaining and conserving energy and fuel consumption within the City. The following policies are applicable to the proposed Project:
P1.12 Energy- and Resource- Efficient Design Support projects, programs, policies and regulations to encourage energy and resource efficient practices in site and building design for private and public projects.
P6.12 Bicycle Parking and Facilities Support projects, programs, policies, and regulations to provide convenient bicycle parking and other bicycle facilities in existing and potential high demand locations within the City, such as educational institutions, parks, business districts, transit stops, retail, commercial and employment centers.
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.
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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.
Methodology
This section analyzes energy use from electricity and transportation fuel associated with Project construction and operations. It should be noted that the project would not connect to or utilize natural gas. The electricity associated with Project water usage was quantified using the water usage and water energy intensity factors from the CalEEMod User Guide, Appendix G. The Project building electricity usage was based on CalEEMod, which quantifies energy use for occupancies using default rates. The solar panel energy reduction was quantified using the hourly capacity, assumed to be 34.1 kW, and the annual average sun exposure; refer to Appendix A. Transportation fuel associated with Project construction worker, vendor, and haul truck trips were quantified using CalEEMod emission outputs and conversation ratios from the Climate Registry. Transportation fuel associated with Project operational vehicle trips was quantified using CalEEMod outputs and CARB EMFAC2021 for typical daily fuel usage in the County. The energy associated with Project construction and operations was compared to the County’ s annual energy consumption.
Impact Analysis
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation? Less Than Significant Impact: Construction Energy. Project construction would consist of demolition, site preparation, grading, infrastructure improvements, building construction, paving, and architectural coating applications. 34 Project construction activities would occur over approximately 13 months, anticipated to begin as early as the third quarter of 2027 and ending as early as the third quarter of 2028. Project construction would include electricity use associated with water utilized for dust control, diesel fuel from on-road hauling trips, vendor trips, and offroad construction diesel equipment, as well as gasoline fuel from on-road worker commute trips.
Because construction activities typically do not require natural gas, it is not included in the following discussion. Energy usage associated with Project construction is summarized in Table 18:
Project Construction Energy Consumption.
34 Although not proposed, the modeled Project construction equipment and water usage conservatively account for the full-width grind and overlay improvements along Cypress Way.
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Table 18: Project Construction Energy Consumption
Source
Project Construction
Energy
Orange County Annual
Energy1, 2
Percentage Increase
Countywide
Electricity ( GWh)
Water 0.0005 19,225 0.000003%
Diesel (Gallons)
Off-Site 36,902 136,186,585 0.03%
On-Site 13,039 136,186,585 0.01%
Total 49,941 136,186,585 0.04%
Gasoline ( Gallons)
Off-Site 7,362 1,068,836,093 0.0007%
1 The County’ s most recent total electricity data in 2024. Source: California Energy Commission. ( 2025).:
https:// www.energy.ca.gov/data-reports/ energy-almanac/ california-electricity-data/ california-energy-consumption-dashboards0. Accessed September 8, 2025. 2 The County’s anticipated fuel usage in 2027 (the first construction year). Source: California Air Resources Board. (2022).
EMFAC2021, Emissions Inventory. Retrieved from: https:// arb.ca.gov/ emfac/ emissionsinventory/ cd60f29daaedd924a75a9316202d7f56a9b573e5. Accessed September 8, 2025.
GWh = gigawatt-hours
Refer to Appendix C for the energy calculations.
The energy sources are described in further detail below.
Water Electricity. Electricity usage associated with water usage for construction dust control is calculated based on the total gallons of water used during soil disturbing activities and the energy intensity. The total gallons of water used is calculated based on the acreage disturbed during grading and site preparation and the daily watering rate per acre disturbed. The total acres disturbed are calculated using the methodology described in Chapter 4.2 of Appendix C of the CalEEMod User’ s Guide. The water application rate of 3,020 gallons per acre per day is from the Air and Waste Management Association’ s Air Pollution Engineering Manual (1992).
The energy intensity value is based on the CalEEMod default supply, distribution, and treatment energy intensity per gallon of water for the South Coast Hydrologic Region.
Off-site Diesel Construction Trips. The diesel fuel associated with on-road construction mobile trips is calculated based on VMT from vendor and hauling vehicle trips, the CalEEMod default diesel fleet percentage, and vehicle fuel efficiency in miles per gallon (MPG). VMT for the entire construction period is calculated based on the number of trips multiplied by the trip lengths for each phase shown in CalEEMod. Construction fuel was calculated based on CalEEMod emissions outputs and conversion ratios from the Climate Registry.
On-Site Diesel Construction Equipment. Similarly, the construction diesel fuel associated with the off-road construction equipment is calculated based on CalEEMod emissions outputs and conversion ratios from the Climate Registry.
Off-Site Gasoline Construction Trips. The gasoline fuel associated with on-road construction mobile trips is calculated based on VMT from worker vehicle trips, the CalEEMod default gasoline fleet percentage, and vehicle fuel efficiency in.
As shown in Table 18, the total electricity demand associated with Project construction would be approximately 0.0005 GWh and would represent less than 0.01 percent of the electricity usage in the County in 2024. SCE’ s total energy sales are projected to be 99,361 GWh of electricity in 2027 AOO
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the first year of Project construction). 35 The Project construction electricity consumption of 0.0005 GWh would represent less than 0.01 percent of SCE’ s projected sales. Therefore, it is anticipated that SCE’ s existing and planned electricity capacity and electricity supplies would be sufficient to serve the Project’ s temporary construction electricity demand.
As indicated in Table 18, Project construction is anticipated to consume approximately 49,941 gallons of diesel and approximately 7,362 gallons of gasoline. The County’ s annual gasoline fuel use in 2027 is anticipated to be approximately 136,186,585 gallons of diesel and 1,068,836,093 gallons of gasoline. 36 As such, the Project construction diesel use would represent approximately
0.04 percent of the annual diesel used in the County and the Project construction gasoline use would represent less than 0.01 percent of the annual gasoline used in the County. Based on the total Project’ s relatively low construction fuel use proportional to annual County use, the Project would not substantially affect existing energy fuel supplies or resources. Additionally, the use of construction fuel would be temporary and would cease once the Project is fully developed.
New capacity or additional sources of construction fuel are not anticipated to be required.
Transportation fuels (gasoline and diesel) are produced from crude oil, which can be domestic or imported from various regions around the world. Based on current proven reserves, current crude oil production would be sufficient to meet demand through 2050. 37 As such, it is expected that existing and planned transportation fuel supplies would be sufficient to serve the Project’ s temporary construction demand and Project construction would have a nominal effect on the local and regional energy supplies.
There are no unusual characteristics that would necessitate the use of construction equipment that would be less energy- efficient than at comparable construction sites in the region or State.
Due to increasing transportation costs and fuel prices, contractors and owners have a strong financial incentive to avoid wasteful, inefficient, and unnecessary use of energy during construction. Additionally, the Project would comply with CARB requirements which limits construction equipment idling to five minutes or less. This requirement indirectly relates to construction energy conservation because when air pollutant emissions are reduced through monitoring and the efficient use of equipment and materials, energy use is reduced. Furthermore, Project compliance with the latest U.S. EPA and CARB engine efficiency emissions standards would minimize unnecessary fuel use.
Substantial reduction in energy inputs for construction materials can be achieved by selecting building materials composed of recycled materials that require substantially less energy to produce than non-recycled materials. The project- related incremental increase in the use of energy bound in construction materials such as asphalt, steel, concrete, pipes, and manufactured or processed materials ( e.g., lumber and gas) would not substantially increase demand for energy compared to overall local and regional demand for construction materials. It is reasonable to assume that production of building materials such as concrete, steel, etc., would employ all reasonable energy 35 California Energy Commission. (2023). CEDU 2022 Baseline Forecast- SCE, Form 1.1.b: Electricity Sales by Sector. https:// www.energy. ca.gov/ data-reports/ reports/ integrated- energy- policy-report/ 2022-integrated- energy-policy-report-update- 2.
Accessed September 8, 2025.
36 California Air Resources Board. (2022). EMFAC2021, Emissions Inventory. https:// arb.ca.gov/ emfac/ emissionsinventory/ cd60f29daaedd924a75a9316202d7f56a9b573e5. Accessed September 8, 2025. 37 US Energy Information Administration. (2025). California State Energy Consumption Profile. https:// www.eia.gov/state/ print.php?sid=CA.
Accessed September 8, 2025.
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conservation practices in the interest of minimizing the costs of business. As stated above, Project construction would not result in inefficient, wasteful, or unnecessary energy consumption and impacts are less than significant.
Less Than Significant Impact: Operational Energy. The energy consumption associated with Project operations would occur from building energy, water use, and transportation fuel use. The proposed Project would not connect to or utilize natural gas. Project operational energy consumption is summarized in Table 19: Project Operational Energy Consumption. It should be noted that Table 19 conservatively does not take credit for energy consumption occurring under existing conditions. For example, the Project would result in a net reduction of 422 total daily vehicle trips when compared to existing conditions; refer to Table 1 in Appendix L. Therefore, the Project’ s energy consumption presented in the table is conservative and would be substantially lower when accounting for existing conditions.
Table 19: Project Operational Energy Consumption
Source
Project Operational
Energy
Orange County Annual
Energy1, 2
Percentage Increase
Countywide
Electricity ( GWh)
Building 0.721 19,225 0.004%
Water 0.171 19,225 0.0009%
Solar - 0.062 19,225 0.0003%
Total 0.830 19,225 0.004%
Diesel (Gallons)
Mobile 99,967 135,357,141 0.07%
Gasoline ( Gallons)
Mobile 24,112 1,048,783,959 0.002%
1 The County’ s most recent total electricity data in 2024. Source: California Energy Commission. ( 2025).:
https:// www.energy. ca.gov/ data-reports/ energy-almanac/ california- electricity- data/ california- energy- consumption- dashboards0. Accessed September 8, 2025. 2 The County’ s anticipated fuel usage in 2028 (the first operational year). Source: California Air Resources Board. (2022).
EMFAC2021, Emissions Inventory. Retrieved from: https:// arb.ca.gov/ emfac/ emissionsinventory/ cd60f29daaedd924a75a9316202d7f56a9b573e5. Accessed September 8, 2025.
GWh = gigawatt-hours
Refer to Appendix C for the energy calculations.
The energy sources are described in further detail below.
Building Electricity: The electricity use from the Project is based on CalEEMod defaults and land use activity data.
Water Electricity: The electricity associated with indoor and outdoor Project operational water usage is quantified using the annual water usage and energy intensity factor. The annual water usage is based on CalEEMod defaults and land use activity data. The indoor energy intensity value is based on the CalEEMod default supply, distribution, treatment, and wastewater energy intensity per gallon of water for the South Coast Hydrologic Region. The outdoor energy intensity value is based on the CalEEMod default supply, distribution, and treatment energy intensity per gallon of water for the South Coast Hydrologic Region.
Solar Panels: The electricity provided by on-site solar panels was quantified based on the system size and the yearly average sun exposure. The solar panels are assumed to have an AO
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hourly capacity of 34.1 kW. The average sun exposure is assumed to be 1,825 hours per year based on five daily peak hours per day, 365 days per week; refer to Appendix A.
Diesel Truck and Gasoline Passenger Vehicle Trips: The gasoline and diesel fuel associated with on-road vehicular trips is calculated based on the fleet mix and total VMT from CalEEMod and average fuel efficiency from the Department of Transportation. The total VMT is based on the daily Project trip generation and daily trip lengths. According to Table 1 in Appendix L, the Project would generate approximately 146 passenger vehicles and 66 truck vehicles. As addressed in Section 4.3, Air Quality above, the truck fleet mix and daily trip lengths were adjusted in CalEEMod to better represent warehouse- specific operations. The passenger vehicle fleet mix is based on CalEEMod defaults.
Table 19 shows the Project’ s annual operational electrical demand would total approximately
0.830 GWh per year, considering a reduction of 0.062 GWh provided by the on-site solar panels.
SCE’ S forecasted sales in 2028 (the first operational year) is 100,400 GWh. 38 The proposed Project would represent less than 0.01 percent of SCE’ s projected sales. SCE would review the Project’ s estimated electricity consumption to ensure that the estimated power requirement would be part of the total load growth forecast for their service area and accounted for in the planned growth of the power system. Based on these factors, it is anticipated that SCE’ s existing and planned electricity capacity and supply would be sufficient to serve the Project’ s electricity demand.
Furthermore, the Project design and operations would be subject to compliance with the latest CALGreen Code and Title 24 Standards.
As shown in Table 19, the Project is anticipated to consume 101,005 gallons of diesel and 34,716 gallons of gasoline. The County’ s annual diesel and gasoline fuel use in 2028 is anticipated to be 135,357,141 gallons and 1,048,783,959 gallons, respectively. The Project’ s operational diesel and gasoline use would represent approximately 0.07 percent of diesel use and approximately 0.003 percent of gasoline use in the County. Therefore, the proposed Project would not result in a substantial demand for energy that would require expanded supplies or the construction of other infrastructure or expansion of existing facilities. Transportation fuels ( gasoline and diesel) are produced from crude oil, which can be domestic or imported from various regions around the world. Based on current proven reserves, the global supply of crude oil, other liquid hydrocarbons, and biofuels is expected to be adequate to meet the world’ s demand for liquid fuels through 2050. 39
Project operations would not substantially affect existing energy or fuel supplies or resources.
Furthermore, the Project would comply with applicable energy standards and new capacity would not be required. As such, Project operations would not result in inefficient, wasteful, or unnecessary energy consumption and impacts are less than significant. b) Conflict with or obstruct a State or local plan for renewable energy or energy efficiency? Less Than Significant Impact. As concluded above, the Project would not result in the wasteful, inefficient, or unnecessary consumption of energy resources. 38 California Energy Commission. ( 2023). CEDU 2022 Baseline Forecast – SCE. https:// www.energy. ca.gov/ data-reports/ reports/ 2022- integrated- energy-policy-report-update/ 2022-iepr-workshops- notices- and-2. Accessed September 11, 2025. 39 US Energy Information Administration. (2025). California State Energy Consumption Profile. https:// www.eia.gov/state/ print.php?sid=CA.
Accessed September 8, 2025.
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Buildings adhering to the latest Title 24 Standards and CALGreen Code would be more energy efficient than buildings designed with the prior code. Project design and operations would comply with the 2025 Title 24 Standards, 2025 CALGreen Code, and applicable energy regulations. As such, the proposed warehouse would be more energy efficient than the existing on-site uses. According to Table 1 in Appendix L, Project implementation would result in a net reduction of 422 total daily trips when compared to existing conditions. Therefore, the transportation fuel consumption would be reduced by Project implementation. Although the City has not adopted any specific plans that address energy efficiency, the City of Fullerton Climate Action Plan ( CAP, adopted in 2012) establishes energy and water conservation strategies to reduce citywide GHG emissions.
Therefore, compliance with the CAP strategies would further result in energy conservation and efficiency. As such, the Project would not conflict with applicable plans for renewable energy or energy efficiency.
The Project would receive electricity from SCE, which is subject to the RPS. The RPS requires investor- owned utilities, electric service providers, and community choice aggregators to increase total procurement from eligible renewable energy resources to 33 percent by 2020 and 50 percent by 2030. As noted above, SB 100 revised the goal of the program to achieve the 50 percent renewable resources target by December 31, 2026, and to achieve a 60 percent target by December 31, 2030. SB 100 also established a further goal to have an electric grid that is entirely powered by clean energy by 2045. Renewable energy is generally defined as energy that comes from resources which are naturally replenished within a human timescale, such as sunlight, wind, tides, waves, and geothermal heat. The SCE satisfies its renewable energy portfolio standards and consists of approximately 37.6 percent of renewable energy sources. 40 The Project would not otherwise conflict with or obstruct compliance with plans for renewable energy. As such, the Project would be designed to meet all applicable State building energy efficiency standards as well as the City’ s energy efficiency standards. Therefore, the Project would not conflict with or obstruct a State or local plan for renewable energy or energy efficiency and impacts would be less than significant.
40 South California Edison. (N.D.). 2023 Power Content Label, Southern California Edison Company. Retrieved from:
https:// www.energy. ca.gov/ filebrowser/ download/ 7362. Accessed September 8, 2025.
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4.7 GEOLOGY AND SOILS
ENVIRONMENTAL IMPACTS
Potentially
Significant
Issues
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
7. GEOLOGY AND SOILS. Would the project:
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death
involving:
i) Rupture of a known earthquake fault, as delineated
on the most recent Alquist-Priolo Earthquake Fault
Zoning Map issued by the State Geologist for the
area or based on other substantial evidence of a
known fault? Refer to Division of Mines and Geology
Special Publication 42.
X
ii) Strong seismic ground shaking? X
iii) Seismic- related ground failure, including
liquefaction?
X
iv) Landslides? X
b) Result in substantial soil erosion or the loss of topsoil? X c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project,
and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse?
X
d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code ( 1994), creating substantial direct or indirect risks to life or property?
X
e) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of
wastewater?
X
f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
X
NorCal Engineering, Inc. prepared a Geotechnical Engineering Investigation ( Geotechnical Investigation) for the proposed Project. The report is included in this Initial Study as Appendix D: Geotechnical Engineering Investigation and is summarized below.
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a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42.
No Impact. Alquist- Priolo Earthquake Fault Zones are regulatory zones surrounding active faults located within California that were created through the Alquist- Priolo Earthquake Fault Zoning Act.
If an active fault is found, a structure for human occupancy cannot be placed over the trace of the fault and must be set back from the fault (typically 50 feet). The project site is not located within an Alquist- Priolo Earthquake Fault Zone as designated by the California Geological Survey. The nearest Alquist- Priolo fault zone is approximately 5 miles to the northeast of the project site. 41 Therefore, the Project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death due to direct fault rupture. No impact would occur. ii) Strong seismic ground shaking?
Less Than Significant with Mitigation Incorporated. The City of Fullerton, similar to the rest of California, is located within a seismically active region as a result of being located near the active margin between the North American and Pacific tectonic plates. The local and regional faults that have the potential to affect the City are depicted in The Fullerton Plan Final Program EIR, Exhibit
5.7-1, Regional Faults, and described in Table 5.7-1, Descriptions of Regional Faults. The two faults that traverse Fullerton are the Norwalk Fault and Puente Hills Fault. As previously noted, the project site is not within a designated Alquist-Priolo Earthquake Fault Zone. The fault nearest to the project site is the El Modeno Fault, which is located approximately 1.8 miles to the southeast and is capable of producing a magnitude 6.8 earthquake.
Due to the numerous faults in the region, rupture of any of these faults or of an unknown fault in the region could cause seismic ground shaking at the project site. The intensity of ground shaking on the project site would depend on the earthquake’ s magnitude, distance to the epicenter, and geology of the area between the project site and the epicenter. Therefore, Project implementation could expose people and structures to potential adverse effects involving strong seismic ground shaking if not constructed in alignment with the regulatory framework identified below.
State laws and local ordinances require that, prior to construction, potential seismic hazards be identified and mitigated, as needed, to protect public health and safety from substantial risks through appropriate engineering practices. Project construction would be required to conform to CBC and California Health and Safety Code seismic design requirements ( or applicable adopted code at the time of plan submittal or grading and building permit issuance for construction). The building and safety standards established by these codes have been developed to address structural integrity during a seismic event. Chapter 14.03 – Building Code of the FMC adopts the 2022 California Building Code ( CBC), which outlines requirements and structural standards for 41 Department of Conservation California Geological Survey. ( N.D.). California Earthquake Hazards Zone Application. Retrieved from:
https:// maps.conservation. ca.gov/ cgs/ informationwarehouse/ eqzapp/. Accessed July 11, 2025.
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building in the City including design requirements to mitigate the effects of potential earthquake hazards.
The Geotechnical Investigation prepared for the Project evaluated various geologic and seismic hazards based on site-specific parameters, including a seismicity evaluation, and provides recommendations concerning seismic design parameters, foundations, slabs, and general earthwork and grading, among others ( see Appendix D). The Project would comply with SC GEO- 2, which would ensure the City would review all Project plans and all other relevant construction permits to verify compliance with the Geotechnical Engineering Investigation ( NorCal Engineering, Inc., 2023) recommendations and other applicable Code requirements. With the implementation of SC GEO- 2 and considering the Project would comply with applicable seismic design requirements, impacts associated with strong seismic ground shaking would be less than significant.
iii) Seismic- related ground failure, including liquefaction? Less Than Significant Impact. Liquefaction is a phenomenon where earthquake- induced ground vibrations increase the pore pressure in saturated, granular soils until it is equal to the confining, overburden pressure. When this occurs, the soil can completely lose its shear strength and enter a liquefied state. Liquefaction- related effects include loss of bearing strength, amplified ground oscillations, lateral spreading, and flow failures. The project site is not situated in an area of historic occurrence of liquefaction, within a CGS Liquefaction Zone, or local geological, geotechnical and groundwater conditions to indicate a potential for permanent ground displacement ( Appendix D).
Therefore, the Project would not cause potential substantial adverse effects involving liquefaction.
Impacts would be less than significant with mitigation. iv) Landslides?
No Impact. Landslides can occur if ground shaking and/ or heavy rainfall disturb areas of steep slopes consisting of unstable soils. As concluded in the Geotechnical Investigation, due to the relatively flat topography descending gradually from north to south, the site is not within a zone of possible earthquake- induced landslides. Additionally, the California Geological Survey’ s Landslide Inventory reports the project site is not within a landslide hazard zone. 42 Therefore, the proposed Project would not directly or indirectly cause potential substantial adverse effects, including the risks of loss or death, involving landslides, and no impact would occur. b) Result in substantial soil erosion or the loss of topsoil? Less than Significant Impact. Geotechnical Investigation indicated that the project site is relatively flat and is composed of fine to medium grained, silty sand with occasional gravel at a depth ranging from 1 to 1.5 feet below ground surface (bgs). An undisturbed natural soil classified as light brown, fine to medium grained, silty to slightly silty sand was encountered beneath the fill soils. Grading and earthwork activities during construction would expose soils to potential short-term erosion by wind and water. During construction, the proposed Project would be subject to compliance with erosion and siltation control measures and the National Pollutant Discharge Elimination System 42 California Department of Conservation. (2024). Landslide Inventory (Beta). https:// maps.conservation.ca.gov/ cgs/ lsi/app/, Accessed July 11, 2025.
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NPDES) General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities ( Order No. 2013- 0001- DWQ, and all subsequent amendments) Construction General Permit). The NPDES permit requires development and implementation of a Stormwater Pollution Prevention Plan (SWPPP) and monitoring plan, which must include erosioncontrol and sediment- control Best Management Practices ( BMPs) that would meet or exceed measures required by the Construction 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. Following compliance with NPDES and the Project would not result in substantial soil erosion or the loss of topsoil. Impacts are less than significant and no mitigation is required.
c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse?
Less Than Significant with Mitigation Incorporated.
Landslides. As noted in Threshold a)iv) above, the project site is not subject to landslides due to location and topography. In addition, the project site is not located in a zone identified as being susceptible to landslides by the California Geological Survey’ s Landslide Inventory. Therefore, given no landslides would occur due to project site and area location and topography, there would be no impact as a result of landslides and no mitigation is required.
Lateral Spreading. Lateral spreading is the finite, horizontal movement of material associated with pore pressure build-up or liquefaction. This process can occur in a shallow underlying deposit during an earthquake in areas susceptible to liquefaction. To occur, lateral spreading requires the existence of a continuous and laterally unconstrained liquefiable zone. Given the very low probability of liquefaction, impacts from lateral spreading would be less than significant and no mitigation is required.
Subsidence. Soil subsidence is characterized by sinking or descending soils that occur as the result of a heavy load being placed on underlying sediments and may be triggered by seismic events.
Seismically- induced settlement depends on the relative subsurface soil density. Settlements from collapsible soils can be relatively large and damaging to improvements. The Geotechnical Investigation determined on-site soils to consistent of fill and natural soil both generally classified as fine to medium grained silty sand and observed to be medium dense. As recommended in the Geotechnical Investigation all disturbed soil or fill shall be removed, and approved import soils would be placed and compacted as outlined in the report to comply with applicable standards to avoid instability due to subsidence. Compliance with SC GEO-2, would ensure the City would review all Project plans and all other relevant construction permits to verify compliance with the Geotechnical Engineering Investigation ( NorCal Engineering, Inc., 2023) recommendations.
Therefore, in this regard, the Project would have a less than significant impact with mitigation incorporated.
Liquefaction or collapse. As noted above in Threshold a)iii) the project site is not situated in an area of historic occurrence of liquefaction, within a CGS Liquefaction Zone, or local geological, geotechnical and groundwater conditions to indicate a potential for permanent ground AOO
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displacement. Therefore, the Project would not cause potential substantial adverse effects involving liquefaction. Impacts would be less than significant with mitigation. d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code ( 1994), creating substantial direct or indirect risks to life or property? Less Than Significant. Soils that expand and contract in volume (“ shrink- swell” pattern) are considered to be expansive and may cause damage to aboveground infrastructure as a result of density changes that shift overlying materials. Fine-grain silts and clay sediments are most likely to exhibit shrink- swell patterns in response to changing moisture levels. As outlined in the Geotechnical Investigation, testing of the upper soils indicated an expansion index of 0, classifying the on-site expansion potential as very low. Therefore, impacts from expansive soils would be less than significant and no mitigation is required.
e) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater? No Impact. There is existing sewer infrastructure in the vicinity of the project site that is available to serve the proposed Project. The Project would connect to the existing sanitary sewer system for wastewater disposal and would not include the use of septic tanks. Therefore, the proposed Project would not have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater. No impact would occur.
f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Less than Significant Impact With Mitigation Incorporated. Paleontological resources are found in geological deposits of sedimentary rock ( i.e., sandstone, siltstone, mudstone, claystone, or shale). The potential for the occurrence of a unique geologic feature depends on the rock type exposed at the surface in a given area and potential effects on paleontological resources would primarily be associated with ground-disturbing activities. A paleontological resources records search was requested from the Western Science Center in July 2025; see Appendix E. The records search identified Quaternary alluvial units on the project site that are considered to be fossiliferous and highly paleontologically sensitive. The Western Science Center record search indicates that no paleontological resources have been discovered within the project site or a one-mile radius; however, Quaternary alluvial units throughout Southern California have produced large quantities of fossils. Therefore, MM GEO- 1 is required to reduce the Project’ s potential impacts to a less than significant level. MM GEO-1 details the appropriate steps should paleontological resources be encountered during ground-disturbing activities. If paleontological resources are inadvertently unearthed during excavation and grading activities, all earth-disturbing activities within a 100-foot radius of the area of discovery would cease. Additionally, the Applicant would have to retain a qualified professional paleontologist to evaluate the significance of the finding and create an appropriate course of action. Following compliance with MM GEO-1, the Project’ s potential impacts to a unique paleontological resource/ site or geologic feature would be less than significant.
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Standard Conditions and Requirements
SC GEO-1 Project plans and designs shall comply with Fullerton Municipal Code Chapter 14.03 – Building Code, which incorporates the 2022 California Building Standards Code which contains all regulations for how buildings are designed and constructed, and are intended to ensure the maximum structural integrity and safety of private and public buildings.
SC GEO- 2 Prior to Grading Permit issuance, the City shall review all Project plans and all other relevant construction permits to verify compliance with the Geotechnical Engineering Investigation ( NorCal Engineering, Inc. 2023) recommendations and other applicable Code requirements.
Mitigation Measures
MM GEO- 1 Paleontological Resources. In the event that paleontological resources are inadvertently unearthed during excavation and grading activities, the contractor shall immediately cease all earth-disturbing activities within a 100-foot radius of the area of discovery. The Applicant shall retain a qualified professional paleontologist subject to approval by the City of Fullerton, to evaluate the significance of the finding and appropriate course of action. If avoidance of the resource( s) is not feasible, the Applicant shall follow salvage operation requirements pursuant to State CEQA Guidelines Section 15064.5. After the Applicant has appropriately avoided or mitigated the find, work in the area may resume.
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4.8 GREENHOUSE GAS EMISSIONS
ENVIRONMENTAL IMPACTS
Potentially
Significant
Issues
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
8. GREENHOUSE GAS EMISSIONS. Would the project:
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the
environment?
X
b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of
greenhouse gases?
X
The greenhouse gas ( GHG) modeling outputs and results are included in Appendix A: Air Quality and Greenhouse Gas Emissions Data and summarized below.
Background
The “ greenhouse effect” is the natural process that retains heat in the troposphere, the bottom layer of the atmosphere. Without the greenhouse effect, thermal energy would “ leak” into space, resulting in a much colder and inhospitable planet. With the greenhouse effect, the global average temperature is approximately 61 F (16 C). GHGs are the components of the atmosphere responsible for the greenhouse effect. The amount of heat retained is proportional to the concentration of GHGs in the atmosphere. As human activities and natural sources release more GHGs into the atmosphere, GHG concentrations increase, and the atmosphere retains more heat, increasing the effects of climate change. The Kyoto Protocol identified six gases for emission reduction targets: carbon dioxide ( CO2), methane ( CH4), nitrous oxide ( N2O), hydrofluorocarbons ( HFC), perfluorocarbons ( PFC), and sulfur hexafluoride ( SF6). When accounting for GHGs, all types of GHG emissions are expressed in terms of CO2 equivalents ( CO2e) and are typically quantified in metric tons (MT) or million metric tons (MMT).
CO2, CH4, and N2O cause approximately 80 percent of the total heat stored in the atmosphere. Human activities, as well as natural sources, emit these three gases. Each of the GHGs affects climate change at different rates and persists in the atmosphere for varying lengths of time. The GWP is the relative measure of the potential for a GHG to trap heat in the atmosphere. The GWP allows comparisons of the global warming impacts of different gases. Specifically, it is a measure of how much energy the emissions of one ton of a gas will absorb over a given period, relative to the emissions of one ton of CO2. The larger the GWP, the more that a given gas warms the Earth compared to CO2 over that period. GWPs provide a common unit of measure, which allows analysts to add up emissions estimates of different gases (e.g., to compile a national GHG inventory) and allows policymakers to compare emissions reduction opportunities across sectors and gases.
Stationary source combustion of natural gas in equipment such as water heaters, boilers, process heaters, and furnaces emits GHGs, primarily CO2, CH4, and N2O. GHGs are also emitted from mobile sources such as on-road vehicles and off-road construction equipment burning fuels such as gasoline, diesel, biodiesel, propane, or natural gas ( compressed or liquefied). Indirect GHG emissions result from electric power AOO
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generated elsewhere ( i.e., power plants) used to operate process equipment, lighting, and utilities at a facility. Included in GHG quantification is electric power, which is used to pump the water supply ( e.g., aqueducts, wells, pipelines) and the disposal and decomposition of municipal waste in landfills. 43 Regulations
Energy Independence and Security Act of 2007
The EISA of 2007, among other key measures, requires the following, which would aid in the reduction of national GHG emissions:
Increase the supply of alternative fuel sources by setting a mandatory Renewable Fuel Standard requiring fuel producers to use at least 36 billion gallons of biofuel in 2022.
Set a target of 35 mpg or the combined fleet of cars and light trucks by model year 2020 and direct the National Highway Traffic Safety Administration ( NHTSA) to establish a fuel economy program for medium- and heavy- duty trucks and create a separate fuel economy standard for work trucks.
Prescribe or revise standards affecting regional efficiency for heating and cooling products and procedures for new or amended standards, energy conservation, energy efficiency labeling for consumer electronic products, residential boiler efficiency, electric motor efficiency, and home appliances.
On April 9, 2025, President Trump signed an executive order calling for the sunset of various environmental regulations. The order affects pieces of several keystone energy and environmental legislation, including the EISA of 2007.
United States Environmental Protection Agency Endangerment Finding The U.S. EPA authority to regulate GHG emissions stems from the United States Supreme Court decision in Massachusetts v. EPA (2007). The Supreme Court ruled that GHGs meet the definition of air pollutants under the existing FCAA and must be regulated if these gases could be reasonably anticipated to endanger public health or welfare. Responding to the Court’ s ruling, the U.S. EPA finalized an endangerment finding in December 2009. Based on scientific evidence it found that six GHGs ( CO2, CH4, N2O, HFCs, PFCs, and SF6) constitute a threat to public health and welfare. Therefore, it is the Supreme Court’ s interpretation of the existing FCAA and the U.S. EPA’ s assessment of the scientific evidence that form the basis for the U.S. EPA’ s regulatory actions.
In response to President Trump’ s “ Unleashing American Energy” Executive Order, published on January 20, 2025, the U.S. EPA announced its intention to reconsider regulations and actions that rely on the 2009 Greenhouse Gas Endangerment Finding ( Endangerment Finding) on March 12, 2025. The March 12 announcement specifically targets the following which impact GHG emissions:
Advanced Clean Trucks Plan, including:
o Control of Air Pollution from New Motor Vehicles: Heavy- Duty Engine and Vehicle Standards o Multi-Pollutant Emissions Standards for Model Year 2027 and Later Light- and Medium- Duty Vehicles
o GHG Emissions Standards for Heavy- Duty Vehicles – Phase 3.
Corporate Average Fuel Economy ( CAFE) Standards
43 California Air Resources Board. (2008). Climate Change Scoping Plan.
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Federal Vehicle Standards
In response to the United States Supreme Court ruling discussed above, Executive Order 13432 was issued in 2007 directing the U.S. EPA, the Department of Transportation, and the Department of Energy to establish regulations that reduce GHG emissions from motor vehicles, non-road vehicles, and non-road engines by 2008. In 2009, the NHTSA issued a final rule regulating fuel efficiency and GHG emissions from cars and light-duty trucks for model year 2011, and in 2010, the U.S. EPA and NHTSA issued a final rule regulating cars and light-duty trucks for model years 2012 to 2016.
In 2010, an Executive Memorandum was issued directing the Department of Transportation, Department of Energy, U.S. EPA, and NHTSA to establish additional standards regarding fuel efficiency and GHG reduction, clean fuels, and advanced vehicle infrastructure. In response to this directive, the U.S. EPA and NHTSA proposed stringent, coordinated federal GHG and fuel economy standards for model years 2017 to 2025 light-duty vehicles. The proposed standards projected to achieve 163 grams per mile of CO2 in model year 2025, on an average industry fleet-wide basis, which is equivalent to 54.5 mpg if this level were achieved solely through fuel efficiency. The final rule was adopted in 2012 for model years 2017– 2021, and NHTSA intends to set standards for model years 2022–2025 in a future rulemaking. On January 12, 2017, the U.S. EPA finalized its decision to maintain the current GHG emissions standards for model years 2022–2025 cars and light trucks.
In addition to the regulations applicable to cars and light-duty trucks described above, in 2011, the U.S.
EPA and NHTSA announced fuel economy and GHG standards for medium- and heavy- duty trucks for model years 2014– 2018. The standards for CO2 emissions and fuel consumption are tailored to three main vehicle categories: combination tractors, heavy- duty pickup trucks and vans, and vocational vehicles.
According to the U.S. EPA, this regulatory program will reduce GHG emissions and fuel consumption for the affected vehicles by 6 to 23 percent over the 2010 baselines.
In August 2016, the U.S. EPA and NHTSA announced the adoption of the phase two program related to the fuel economy and GHG standards for medium- and heavy- duty trucks. The phase two program applies to vehicles with model year 2018– 2027 for certain trailers, and model years 2021–2027 for semi-trucks, large pickup trucks, vans, and all types and sizes of buses and work trucks. The final standards lower CO2 emissions by approximately 1.1 billion metric tons and reduce oil consumption by up to two billion barrels over the lifetime of the vehicles sold under the program.
On September 27, 2019, the U.S. EPA and the NHTSA published the “Safer Affordable Fuel-Efficient ( SAFE) Vehicles Rule Part One: One National Program” ( 84 Federal Regulation 51,310 (Sept. 27, 2019). The SAFE Rule ( Part One) revoked California’ s authority to set its own GHG emissions standards and set zeroemission vehicle mandates in California. On March 31, 2020, the U.S. EPA and NHTSA finalized rulemaking for SAFE Part Two, which sets CO2 emissions standards and CAFE standards for passenger vehicles and light duty trucks, covering model years 2021- 2026. The current U.S. EPA administration repealed SAFE Rule Part One, effective January 28, 2022, and is reconsidering Part Two.
On June 7, 2024, the NHTSA finalized their CAFE standards for model year 2030 to 2035. The final rule requires an industry-wide fuel average of approximately 50.4 mpg for passenger cars and light-duty trucks and an industry fleet-wide average for heavy- duty pickup trucks and vans of roughly 2.851 gallons per 100 miles.
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In response to President Trump’ s “ Unleashing American Energy” Executive Order, published on January 20, 2025, the U.S. EPA announced its intention to reconsider regulations and actions that rely on the Endangerment Finding on March 12, 2025. This includes the CAFE standards. On June 6, 2025, the NHTSA published an interpretive rule that establishes the NHTSA’ s authority to revise the CAFE standards without consideration of electric vehicles. Implementation of these standards remains uncertain.
California Air Resources Board
CARB is responsible for the coordination and oversight of State and local air pollution control programs in California. Various statewide and local initiatives to reduce California’ s contribution to GHG emissions have raised awareness about climate change and its potential for severe long- term adverse environmental, social, and economic effects. California is a significant emitter of CO2e in the world and produced 371.1gross MMTCO2e in 2022. 44 In California, the transportation sector is the largest emitter of GHGs, followed by industrial operations such as manufacturing and oil and gas extraction.
The State legislature has enacted a series of bills that constitute the most aggressive program to reduce GHGs of any state in the nation. Some legislation, such as the landmark AB 32, California Global Warming Solutions Act of 2006, was specifically enacted to address GHG emissions. Other legislation, such as Title 24 Building Energy Efficiency Standards and Title 20 Appliance Energy Standards, were originally adopted for other purposes such as energy and water conservation but also provide GHG reductions.
Assembly Bill 32
Assembly Bill (AB) 32, the California Global Warming Solutions Act of 2006, instructed CARB to develop and enforce regulations for the reporting and verification of statewide GHG emissions and established a State goal of reducing GHG emissions to 1990 levels by the year 2020. AB 32 additionally established a timeline for adopting a scoping plan for achieving GHG reductions in a technologically and economically feasible manner. The Scoping Plan was first approved by CARB in 2008 and is updated every five years.
California Air Resources Board Scoping Plan
Adopted December 15, 2022, CARB’ s 2022 Scoping Plan for Achieving Carbon Neutrality ( 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. To achieve the targets of AB 1279, the 2022 Scoping Plan relies on existing and emerging fossil fuel alternatives and clean technologies, as well as carbon capture and storage. Specifically, the 2022 Scoping Plan focuses on zero- emission transportation; phasing out use of fossil gas use for heating homes and buildings; reducing chemical and refrigerants with high GWP; providing communities with sustainable options for walking, biking, and public transit; displacement of fossil- fuel fired electrical generation through use of renewable energy alternatives ( e.g., solar arrays and wind turbines); and scaling up new options such as green hydrogen.
The 2022 Scoping Plan sets one of the most aggressive approaches to reach carbon neutrality in the world.
Unlike the 2017 Scoping Plan, CARB no longer includes a numeric per capita threshold and instead advocates for compliance with a local GHG reduction strategy (i.e., CAP) consistent with CEQA Guidelines Section 15183. 5.
The key elements of the 2022 CARB Scoping Plan focus on transportation. Specifically, the 2022 Scoping Plan aims to rapidly move towards zero-emission transportation ( i.e., electrifying cars, buses, trains, and 44 California Air Resources Board. ( 2024). Current California GHG Emissions Inventory Data. Retrieved from: https:// ww2.arb.ca.gov/ ghginventory- data. Accessed September 11, 2025.
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trucks), which constitutes California’ s single largest source of GHGs. The regulations that impact the transportation sector are adopted and enforced by CARB on vehicle manufacturers and are outside the jurisdiction and control of local governments. The 2022 Scoping Plan accelerates development of new regulations as well as amendments to strengthen regulations and programs already in place.
Included in the 2022 Scoping Plan is a set of Local Actions ( 2022 Scoping Plan Appendix D) aimed at providing local jurisdictions with tools to reduce GHGs and assist the State in meeting the ambitious targets set forth in the 2022 Scoping Plan. Appendix D to the 2022 Scoping Plan includes a section on evaluating plan-level and project-level alignment with the State’ s Climate Goals in CEQA GHG analyses. In this section, CARB identifies several recommendations and strategies that should be considered for new development in order to determine consistency with the 2022 Scoping Plan. Notably, this section is focused on Residential and Mixed- Use projects. 45 CARB specifically states that Appendix D does not address other land uses ( e.g., industrial) as contemplated by the Project. 46 However, CARB plans to explore new approaches for other land use types in the future. 47 As such, it would be inappropriate to apply the requirements contained in Appendix D of the 2022 Scoping Plan to any land use types other than residential or mixed-use residential development.
Senate Bill 32 (California Global Warming Solutions Act of 2006: Emissions Limit) Signed into law in September 2016, SB 32 codifies the 2030 GHG reduction target in Executive Order B30-15 (40 percent below 1990 levels by 2030). The bill authorizes CARB to adopt an interim GHG emissions level target to be achieved by 2030. CARB also must adopt rules and regulations in an open public process to achieve the maximum, technologically feasible, and cost- effective GHG reductions.
SB 100 and SB 1020 ( California Renewables Portfolio Standard Program: Emissions of Greenhouse Gases)
Signed into law in September 2018, SB 100 increased California’ s renewable electricity portfolio from 50 to 60 percent by 2030. SB 100 also established a further goal to have an electric grid that is entirely powered by clean energy by 2045. SB 1020 provides additional goals for the path to the 2045 goal of 100 percent clean electricity retail sales. It creates a target of 90 percent clean electricity retail sales by 2035 and 95 percent clean electricity retail sales by 2040.
AB 1279 (The California Climate Crisis Act)
AB 1279 establishes the policy of the State to achieve carbon neutrality as soon as possible, but no later than 2045; to maintain net negative GHG emissions thereafter; and to ensure that by 2045 statewide anthropogenic GHG emissions are reduced at least 85 percent below 1990 levels. The bill requires CARB to ensure that Scoping Plan updates identify and recommend measures to achieve carbon neutrality, and to identify and implement policies and strategies that enable CO2 removal solutions and carbon capture, utilization, and storage technologies.
Title 20 Appliance Efficiency Regulations
The appliance efficiency regulations ( CCR Title 20, Sections 1601-1608) include standards for new appliances. Twenty- three categories of appliances are included in the scope of these regulations. These 45 California Air Resources Board. (2022). 2022 Scoping Plan for Achieving Carbon Neutrality, Appendix D: Local Actions, Page 21 46 Ibid.
47 Ibid.
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standards include minimum levels of operating efficiency, and other cost-effective measures, to promote the use of energy- and water- efficient appliances.
Title 24 Building Energy Efficiency Standards
California’ s Energy Efficiency Standards for Residential and Nonresidential Buildings ( CCR Title 24, Part 6) was first adopted in 1978 in response to a legislative mandate to reduce California’ s energy consumption.
The standards are updated periodically to allow consideration and possible incorporation of new energy efficient technologies and methods. Energy efficient buildings require less electricity; therefore, increased energy efficiency reduces fossil fuel consumption and decreases GHG emissions.
In December 2024, the 2025 Title 24 Energy Code was approved by the California Building Standards Commission for inclusion into the California Building Standards Code. The 2025 Title 24 Energy Code encourages efficient electric heat pumps, establishes electric- ready requirements for new homes, expands solar photovoltaic and battery storage standards, strengthens ventilation standards, and more.
Buildings whose permit applications are applied for on or after January 1, 2026, must comply with the 2025 Title 24 Energy Code.
Title 24 California Green Building Standards Code
The California Green Building Standards Code ( CCR Title 24, Part 11 code) commonly referred to as the CALGreen Code, is a statewide mandatory construction code developed and adopted by the California Building Standards Commission and the Department of Housing and Community Development. The CALGreen Code requires new residential and commercial buildings to comply with mandatory measures under the topics of planning and design, energy efficiency, water efficiency/ conservation, material conservation and resource efficiency, and environmental quality. The CALGreen Code also provides voluntary tiers and measures that local governments may adopt that encourage or require additional measures in the five green building topics: planning and design; energy efficiency; water efficiency and conservation; material conservation and resource efficiency; and environmental quality. The CALGreen Code also provides voluntary tiers and measures that local governments may adopt that encourage or require additional measures in the five green building topics. The most recent update to the CALGreen Code was adopted in December 2024 (2025 CALGreen Code) and continues to improve upon the existing standards for new construction of, and additions and alterations to, residential and non-residential buildings. Buildings whose permit applications are applied for on or after January 1, 2026, must comply with the 2025 CALGreen Code.
South Coast Air Quality Management District
The SCAQMD is the air pollution control agency for Orange County and the urban portions of Los Angeles, Riverside, and San Bernardino counties. The agency’ s primary responsibility is to ensure that CAAQS and NAAQS are attained and maintained in the SCAB. The SCAQMD is also responsible for adopting and enforcing rules and regulations concerning air pollutant sources, issuing permits for stationary sources of air pollutants, inspecting stationary sources of air pollutants, responding to citizen complaints, monitoring ambient air quality and meteorological conditions, awarding grants to reduce motor vehicle emissions, conducting public education campaigns, and many other activities. All projects are subject to applicable SCAQMD rules and regulations in effect at the time of construction and operation. The following are SCAQMD rules relevant to GHG:
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Rule 1415 (Reduction of Refrigerant Emissions from Stationary Air Conditioning Systems) – The purpose of this rule is to reduce emissions of high-GWP refrigerants from stationary air conditioning systems by requiring projects to reclaim, recover, or recycle refrigerant and minimize leakage.
Rule 2305 (WAIRE Program) – The purpose of this rule is to reduce NOX and particulate matter emissions associated with warehouses and mobile sources attracted to warehouses. Rule 2305 would also reduce GHG emissions. This rule applies to all existing and proposed warehouses over 100,000 square feet located in the SCAQMD. Rule 2305 requires warehouse operators to track annual VMT associated with truck trips to and from the warehouse. These trip miles are used to calculate a warehouse’ s WAIRE Points Compliance Obligation. WAIRE Points are earned based on emission reduction measures and warehouse operators are required to submit an annual WAIRE Report which includes truck trip data and emission reduction measures. Reduction strategies listed in the WAIRE menu include acquire ZE or near zero emission NZE trucks; require ZE/ NZE truck visits; require ZE yard trucks; install on-site ZE charging/ fueling infrastructure; install on-site energy systems; and install filtration systems in residences, schools, and other buildings in the adjacent community. Warehouse operators that do not earn a sufficient number of WAIRE points to satisfy the WAIRE Points Compliance Obligation would be required to pay a mitigation fee.
Funds from the mitigation fee will be used to incentivize the purchase of cleaner trucks and charging/ fueling infrastructure in communities nearby.
Southern California Association of Governments
The SCAG updates Connect SoCal, the RTP/ SCS, every four years. The most recent Connect SoCal ( 2024- 2050 RTP/ SCS) is a long-range vision plan for a more resilient and equitable future and contains policies and strategies for achieving the region’ s shared goals through 2050. 48 The RTP/ SCS is a long- range vision plan that balances future mobility and housing needs with economic, environmental, and public health goals so that the region can grow smartly and sustainably. The strategy was prepared through a collaborative, continuous, and comprehensive process with input from local governments, county transportation commissions, tribal governments, non-profit organizations, businesses, and local stakeholders within the counties of Imperial, Los Angeles, Orange, Riverside, San Bernardino, and Ventura.
The SCAG region must achieve specific federal air quality standards and is required by State law to lower regional GHG emissions. Per SB 375, CARB has set GHG reduction targets at 8 percent below 2005 per capita emissions levels by 2020, and 19 percent below 2005 per capita emissions levels by 2035.
The Fullerton Plan
Adopted on May 1, 2012, Chapter 17: Air Quality and Climate Change of The Fullerton Plan establishes the following applicable goal and policies aimed at reducing GHG emissions:
GOAL 22: Participation in regional efforts to address climate change and its local impacts.
P22. 1 Motor Vehicle- related GHG Emissions Support regional and subregional efforts to reduce greenhouse gas emissions associated with transportation through land use strategies and policies, transportation system improvements, and transportation demand management programs.
48 Southern California Association of Governments. ( 2024). Connect SoCal ( 2024 – 2050 Regional Transportation Plan/ Sustainable Communities Strategy).
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