Agenda packet, first session — Garden Grove City Council, June 9, 2026 (part 2 of 4)

GARDEN GROVE CITY COUNCIL
RESOLUTION NO. ____

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF GARDEN GROVE, DECLARING ITS INTENTION TO

ORDER THE MAINTENANCE OF CERTAIN IMPROVEMENTS IN THE DOWNTOWN ASSESSMENT DISTRICT IN THE CITY OF GARDEN GROVE; DESCRIBING THE DISTRICT TO BE BENEFITED, AND DECLARING ITS INTENTION TO LEVY AN ASSESSMENT TO PAY THE COST AND EXPENSES THEREOF; AND SETTING THE

TIME AND PLACE FOR THE PUBLIC HEARING ON THE QUESTION OF THE LEVY OF THE PROPOSED

ASSESSMENT
WHEREAS, the City Council of the City of Garden Grove, adopted Resolution No. ____, which described existing and any proposed new improvements or substantial changes in existing improvements in the Downtown Assessment District, and ordered the City Engineer to prepare and file a report pursuant to the provisions of the Landscaping and Lighting Act of 1972, i.e., Division 15, Part 2 (commencing with Section 22500) of the California Streets and Highways Code (hereinafter "Act"); WHEREAS, the City Council formed an Assessment District to finance the maintenance of certain improvements under the Act;
WHEREAS, the proposed boundaries of such Assessment District are shown on a map thereof which indicates by a boundary line the extent of the territory included in such Assessment District, which map is designated "Assessment Diagram Downtown Assessment District" as part of the report of the City Engineer described more fully herein below and such map is on file in the City Clerk’s Office; WHEREAS, the City Engineer is competent to make and file with the City Council a report regarding maintenance of the improvements, which is required by the Act; WHEREAS, the City Council has directed the City Engineer to procure the required information and prepare and present to the City Council the written report of maintenance required by the Act; WHEREAS, the City Engineer has prepared the report, and filed it with the City Clerk and presented it to the City Council and the City Council has examined the report; WHEREAS, under the Act, before levying and collecting assessments in the Assessment District, the City Council is required to adopt a Resolution declaring its intention to do so; and WHEREAS, the City Council proposes no increase in assessment for a total of $19.92 per linear foot of frontage on Main Street and Garden Grove Boulevard.

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF GARDEN GROVE DOES HEREBY RESOLVE, DETERMINE, AND ORDER as follows:

SECTION 1. The City Council hereby finds and declares that the public interest and necessity require the maintenance of certain improvements in the streets and other public easements as hereinafter described, and the City Council hereby declares its intention to levy and collect assessments covering the real property benefited by the improvements, pursuant to the Act. 189
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Resolution No. _____

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SECTION 2. The City Council intends to order maintenance of improvements in certain streets, and other public easements, as follows: A portion of Main Street from Garden Grove Boulevard to Acacia Parkway and a portion of Garden Grove Boulevard between 150.16 feet west of the centerline of Main Street and 150.06 feet east of the centerline of Main Street, all being within the district, including on street parking, sidewalks, center gutter, street lights, street trees, and street furniture, including bollards, benches, trash receptacles, drinking fountains, miscellaneous planters, and related items.

SECTION 3. The District is designated Downtown Assessment District, and is generally located on Main Street between Acacia Parkway and Garden Grove Boulevard.

SECTION 4. The report of the City Engineer is hereby approved, and the City Clerk is directed to endorse the fact and date of approval on the report and to file the report in its office. Reference is hereby made to the report, on file with City Clerk, for a full and detailed description of the improvements to be maintained; the boundaries of the Assessment District; and the proposed assessments upon assessable lots and parcels of land within the District.

SECTION 5. An assessment will be levied pursuant to the Act upon all property in Downtown Assessment District subject to assessment under the Act to pay the balance of costs and expenses of the maintenance of the improvements.

SECTION 6. Notice is hereby given that as there is no increase in the assessment for the 2026-27 Fiscal Year for Downtown Assessment District, there will only be one Public Hearing, which will be held on June 6, 2026, at 6:30 p.m. (or as soon thereafter as the City Council may hear same), in the Community Meeting Center, 11300 Stanford Avenue, Garden Grove, California, which is hereby set as the time and place for the Public Hearing on the question of the levy of the proposed assessment. Any interested person may file a written protest with the City Clerk, in which each signer is interested, sufficient to identify the property, which must be delivered to the City Clerk prior to the conclusion of the Public Hearing. In addition, all interested persons shall be afforded the opportunity to be heard at the Public Hearing. The City Council shall consider all oral statements and all written protests or communications made or filed by any interested persons.

SECTION 7. The City Clerk shall cause this Resolution of Intention to be published once in a newspaper of general circulation in the city of Garden Grove, California, not less than ten (10) days prior to the date set for the Public Hearing.
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Item 218/2026
Final
City of Garden Grove

INTER-DEPARTMENT MEMORANDUM
To: Lisa L. Kim From: Samuel Kim
Dept: City Manager Dept: Public Works
Date: 6/9/2026
Subject: Approval of Final Tract Map No. 19129 and Subdivision Improvement Agreement with 8722 GG Development, LLC for the property located at 8722 Garden Grove Boulevard, Garden Grove. (Action Item)

OBJECTIVE
To receive City Council approval of Final Tract Map No. TR 19129 and a Subdivision Improvement Agreement with 8722 GG Development, LLC. (Applicant), for the property located at 8722 Garden Grove Boulevard, Garden Grove (Between Newland and Yockey Street).

BACKGROUND
On December 15, 2022, pursuant to Planning Commission Resolution No. 6053-22, the Applicant received approval of Site Plan No. SP-119-2022 and Tentative Tract Map No. TT19129. A copy of Planning Resolution No. 6053-22 is attached.

DISCUSSION
The Tract Map will accommodate twenty (20) three-story residential townhome units and associated site improvements on an approximately 0.85-acre site. This site is located at 8722 Garden Grove Boulevard, Garden Grove. Easements for public utility, vehicle access, domestic water, and appurtenances have been dedicated.

Pursuant to state law, a subdivision improvement agreement and security is required whenever required public improvements have not been completed. The Subdivision Improvement Agreement requires the posting of Subdivision Improvement Bonds (or a cash deposit or instrument of credit in lieu of bonds) to ensure completion of the improvement of street, sewer, water, drainage, related onsite improvements, and survey monumentation.

Staff has reviewed all the subdivision documentation mandated by City Ordinances and the Subdivision Map Act and finds this map to be in compliance. 191
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FINANCIAL IMPACT
There is no financial impact to approve Final Tract Map No. TR 19129 and a Subdivision Improvement Agreement with 8722 GG Development, LLC. (Applicant), for the property located at 8722 Garden Grove Boulevard, Garden Grove (Between Newland and Yockey Street).

RECOMMENDATION
It is recommended that the City Council:
 Approve Final Tract Map No. TR 19129 and the Subdivision Improvement Agreement with 8722 GG Development, LLC., for the property located at 8722 Garden Grove Boulevard, Garden Grove;
 Accept the Subdivision Improvement Bonds; and
 Authorize the City Manager, or designee, to execute the Agreement on behalf of the City and make minor modifications as appropriate.

By: Kamyar Dibaj, MS
Project Engineer

ATTACHMENT(S)

1. Attachment 1: Tract Map No. TR 19129

2. Attachment 2: Subdivision Improvement Agreement

3. Attachment 3: Planning Resolution No. 6053-22
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RESOLUTION NO. 6053-22
RESOLUTION OF THE PLANNING COMMISSION OF THE CIJ\ OF GARDEN GROVE APPROVING SITE PLAN NO. SP-119-2022 AND TENTATIVE TRACT MAP NO.

TT-19129-2022 FOR PROPERTY LOCATED ON THE SOUTH SIDE OF GARDEN GROVE BOULEVARD, BETWEEN NEWLAND STREET AND YOCKEY STREET, AT 8722 GARDEN, ASSESSOR'S PARCEL NO. 097-222-03.

BE IT RESOLVED that the Planning Commission of the City of Garden Grove, in a regular session assembled on November 17, 2022, and December 15, 2022, hereby approves Site Plan No. SP-119-2022 and Tentative Tract Map No. TT-19129 for a property located on the south side of Garden Grove Boulevard, between Newland Street and Yockey Street, at 8722 Garden Grove Boulevard, Assessor's Parcel No.097-222-03, subject to the conditions of approval attached hereto as Exhibit "A".

BE IT FURTHER RESOLVED in the matter of Site Plan No. SP-119-2022 and Tentative Tract Map No. TT-19129, the Planning Commission of the City of Garden Grove does hereby report as follows:

1. The subject case was initiated by NRI Portfolios, LLC.

2. The applicant is requesting Site Plan approval to construct a three-story, townhome residential project consisting of twenty (20) units, which includes one (1) affordable housing unit for "very low-income" households on a 36,945square foot (0.85 acres) site currently improved with an auto dealership.

Pursuant to the State Density Bonus law, the applicant is requesting one (1) concession and one (1) waiver from the GGMU-2 (Garden Grove Mixed Use 2)zone development standards: (1) a concession to allow the building to beconstructed within the 45-degree encroachment plane required for mixed usezoned properties abutting residentially-zoned lots along the side yard setback; and (2) a waiver to deviate from the requirement of a boulevard garden plaza for properties in the GGMU zones for properties abutting the Garden Grove Boulevard right-of-way. In accordance with the State Subdivision Map Act, the applicant is also requesting approval of a Tentative Tract Map to subdivide theexisting property into two (2) lots for the purpose of selling each townhome unit as a condominium.

3. The City of Garden Grove Planning Commission hereby determines that the proposed project is categorically exempt from review under the California Environmental Quality Act ("CEQA") pursuant to Section 15332 (In-FillDevelopment Projects) of the State CEQA Guidelines (14 Cal. Code Regs., Section 15303). As set forth in the Class 32 exemption, the proposed project is: (1) consistent with the applicable general plan designation and all applicable general plan policies as well as with applicable zoning designation and regulations; (2) the proposed development occurs within City limits on a project site of no more than five acres substantially surrounded by urban uses;(3) the project site has no value as habitat for endangered, rare or threatened 214
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species; (4) approval of the project would not result in any significant effects relating to traffic, noise, air quality or water quality; and (5) the site can be adequately served by all required utilities and public services. The project is therefore exempt from CEQA review.

4. The property has a General Plan Land Use designation of Residential/Commercial Mixed Use 2. The site is currently developed with an auto dealership.

5. Existing land use, zoning, and General Plan designation of property in the vicinity of the subject property have been reviewed.

6. Report submitted by the City staff was reviewed.7. Pursuant to a legal notice, a public hearing was held on November 17, 2022, and December 15, 2022, and all interested persons were given an opportunity to be heard.

8. The Planning Commission gave due and careful consideration to the matter during its meeting on November 17, 2022, and December 15, 2022.

BE IT FURTHER RESOLVED, FOUND AND DETERMINED that the facts and reasons supporting the conclusion of the Planning Commission, as required under MunicipalCode Section 9.04.030 are as follows:

FACTS:

The project site is approximately 36,945 square feet (0.85 acres) and is located on the south side of Garden Grove Boulevard, between Newland Street and Yockey Street, and is currently improved with a vacant auto dealership constructed in 1956,which operated under Conditional Use Permit No. CUP-124-91. The subject site hasa General Plan Land Use designation of Residential/Commercial Mixed Use 2 and iszoned GGMU-2 (Garden Grove Boulevard Mixed Use 2). The property abuts a GGMU-2zoned property to the east improved with a commercial center, R-3 (Multiple-Family Residential) zoned properties to the south, across an alley, improved withmulti-family units, a Planned Unit Development No. PUD-131-99 zoned property to the west improved with a small lot single-family subdivision development, and GGMU-2 zoned properties to the north across Garden Grove Boulevard improved withcommercial buildings.

The car dealership ceased operation in 2018 when the property was sold to the current owner, NRI Portfolios, LLC. The applicant is requesting Site Plan approval todemolish the existing car dealership to construct a three-story, townhome residentialproject consisting of twenty (20) for-sale condominium units, which includes one (1)affordable housing unit for "very low-income" households. With the exception of four (4) units, which are only improved with two-car garages, each unit is proposed to 215
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consist of a three-car garage, a kitchen, a dining area, a living room, four (4) bedrooms, three (3) bathrooms, a laundry room, a foyer, a front porch, and a second story balcony. The project will provide 16 three-car garages where two (2) parking spaces will be tandem, four (4) two-car garages, and six (6) open guest parking spaces. The site will also be improved with two (2) active recreation areas and a trash enclosure. In conjunction with the request for Site Plan approval, the applicant is requesting Tentative Tract Map approval to subdivide the subject property to facilitate the development of the project with condominium units.The project site has a General Plan land use designation of Residential/Commercial Mixed Use 2 (RC2). The RC2 land use designation is intended to allow for mixed useresidential and commercial development with higher residential densities up to 24dwelling units per acre. The RC2 land use designation is implemented by the GGMU-2 zone, which allows the development of residential projects without a commercial component.

The applicant is requesting State Density Bonus allowances for parking, one (1) concession, and one (1) waiver to deviate from the GGMU-2 zone development standards: (1) a concession to allow the building to be constructed within the 45-degree encroachment plane required for mixed use zoned properties abutting residentially-zoned lots along the side yard setback; and (2) a waiver to deviate from Section 9.18.090.020.F of the Municipal Code, which requires a boulevard garden plaza for properties in the GGMU zones for properties abutting the Garden GroveBoulevard right-of-way. An Affordable Housing Regulatory Agreement consistent with the State Density Bonus Law and the Garden Grove Municipal Code will be recordedto ensure affordability of the very low-income unit.

Note: The project application was filed prior to the adoption of objective development standards under Amendment No. A-035-2022, which became effective on November 10, 2022. Thus, the project was designed pursuant to the requirements of the GGMU-2 zone prior to the Code Amendment. In compliance with Cal Gov. Code § 65941.1, the applicant has provided the City's Housing Development Pre-Application prior to November 10, 2022, which allows applicants for housing developments to vest zoning regulations for 180 days.

FINDINGS AND REASONS:

SITE PLAN fHOUSING DEVELOPMENTS)

1. The proposed development project is consistent, in compliance, and in conformity with the applicable, objective standards, provisions, conditions or requirements of the General Plan, Title 9, or other applicable ordinances or policies of the City.

The applicant is requesting Site Plan approval to demolish the existing car dealership to construct a three-story, townhome residential project consisting 216
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of twenty (20) for-sale units, which includes one (1) affordable housing unit for "very low-income" households. In conjunction with the request for Site Plan approval, the applicant is requesting Tentative Tract Map approval to subdivide the subject property into (2) lots for the purpose of selling each unit as a condominium.

The subject site has a General Plan land use designation of Residential/Commercial Mixed Use 2 (RC2), and is zoned GGMU-2 (Garden Grove Boulevard Mixed Use 2), The RC2 land use designation is intended to allow for mixed use residential and commercial developments with higherresidential densities up to 24 dwelling units per acre. The RC2 land usedesignation is implemented by the GGMU-2 zone, which allows residentialdevelopments without a commercial component.

The project has been designed to comply with the development standards of the Municipal Code for the GGMU-2 zone and the State Density Bonus allowances and is within the density permitted under the General Plan. Inaddition, the proposed project is consistent with the goals and policies of the General Plan, including:
a. Goal LU-3: Higher-density residential development along major thoroughfares and in areas well served by public transit, retail and service businesses, public services, and public gathering places.

The project site has a General Plan land use designation of RC2, which is intended to allow higher residential densities up to 24 dwelling unitsper acre. The site fronts Garden Grove Boulevard, which is a major thoroughfare served by public transit, retail and service businesses, and public services.
b. Policy LU-3.2: Support development of multi-family housing that provides a diversity of densities, types, and prices that meet the needsof all household income levels.

The proposed project is a multi-family, twenty (20) unit for-sale townhome development designed at 24 dwelling units per acre. The proposed project has been designed under the State Density Bonus allowances for parking, one (1) concession, and one (1) waiver.

Therefore, the project includes one (1) for-sale affordable unit for "very low-income" households. Furthermore, the project will contribute tomeeting the City's Regional Housing Needs Allocation (RHNA), as wellas the Housing Element policies. c. Policy LU-3.3: Encourage developers to build housing projects at or maximum allowable densities.
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Under RC2 General Plan land use designation, the subject project isallowed a maximum density of 24 dwelling units per acre, which yields twenty (20) units. The project proposed is a twenty (20) unit townhome residential development that maximizes the allowable density.Furthermore, the Project will contribute to meeting the City's Regional Housing Needs Allocation (RHNA), as well as the Housing Elementpolicies. d. Goal LU-4: The City seeks to develop uses that are compatible with one another.

The project is located in a dense neighborhood that is improved with multi-family and commercial developments. The properties in the direct vicinity of the project site are zoned GGMU-2 or R-3 (Multiple-Family Residential), and have a RC2 or Medium Density Residential (MDR) land use designations, respectively. The properties directly to the south and west are developed with two-story multi-family residential buildings.

Thus, the proposed housing project is consistent with the development pattern of the surrounding residential uses.
e. LU-IHP-2B: New development shall be similar in scale to the adjoining residential neighborhood to preserve its character.

The proposed design is compatible with the physical scale of the immediate neighborhood, which is improved with multi-family developments ranging from one to two stories. Thus, the project issimilar both in land use intensity and physical scale of the adjoining residential neighborhood.
f. LU-IMP-3D: Front multi-family housing on local streets with appropriate setbacks to be consistent with neighborhood development patterns.

The project was reviewed by City staff and was determined to meet the required front, side, and rear setbacks, as set forth by the GGMU-2 zone development standards. The proposed buildings will maintain a 17-5"setback from the front property line along Garden Grove Boulevard, and 12'-3" from the rear property line. The proposed buildings located on the east side of the site are setback 10/-6" from the easterly property line, and the buildings located to the west of the site are setback ll'-6" from the westerly property line, which exceeds the setback standards ofthe GGMU-2 zone. Thus, the setbacks are consistent to the neighborhood development patterns.
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g. Policy LU-2.4: Assure that the type and intensity of land use shall be consistent with that of the immediate neighborhood.

The immediate area consists of both multiple-family dwellings and commercial developments. The proposed twenty (20) unit townhome project was reviewed and determined to be within the allowed density and in compliance with the GGMU-2 zone development standards as set forth by the Municipal Code. Thus, the development is consistent with the type and intensity of land use of the immediate neighborhood. h. Policy 2.3 of the Housing Element: Provide density bonuses and other financial and regulatory incentives to facilitate the development of affordable housing.

The proposed project includes one (1) for-sale affordable unit for "very low-income" households. To facilitate the development, the applicant is requesting State Density Bonus allowances for parking, one (1) concession, and one (1) waiver to deviate from the GGMU-2 zone development standards: (1) a concession to allow the building to beconstructed within the 45-degree encroachment plane required for mixed use zoned properties abutting residentially-zoned lots along the side yard setback; and (2) a waiver to deviate from Section9.18.090.020.F of the Municipal Code, which requires a boulevardgarden plaza for properties in the GGMU zones for properties abutting the Garden Grove Boulevard right-of-way. The granting of the concession and waiver is needed to facilitate the construction of the proposed development and to support the creation of more affordablehousing units in the City. Furthermore, the Project will contribute tomeeting the City's Regional Housing Needs Allocation (RHNA).

2. The provisions of the California Environmental Quality Act have been complied with.

The proposed development is exempt from the California Environmental Quality Act ("CEQA"), pursuant to Section 15332 (In-Fill Development Projects) of the CEQA Guidelines (14 Cal. Code Regs., Section 15303). As set forth in the Class 32 exemption, the proposed project is: (1) consistent withthe applicable general plan designation and all applicable general plan policies as well as with applicable zoning designation and regulations; (2) the proposed development occurs within City limits on a project site of no more than fiveacres substantially surrounded by urban uses; (3) the project site has no valueas habitat for endangered, rare or threatened species; (4) approval of the project would not result in any significant effects relating to traffic, noise, air quality or water quality; and (5) the site can be adequately served by all required utilities and public services. Therefore, the provisions of the California Environmental Quality Act have been complied with.
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3. The proposed development project does not have specific, adverse impacts, as defined in subdivision (j)(l)(A) of Government Code Section 65589.5, onpublic health and safety without any feasible method to satisfactorily mitigate or avoid the specific adverse impact, other than the disapproval of the proposed project.

The proposed twenty (20) unit townhome development will not have specific, adverse impacts on the public health and safety. The proposed project is within the maximum allowable density, is compatible with surrounding uses, is similar in scale to the adjoining neighborhood, and is consistent with the land use typeand intensity in the immediate neighborhood. Furthermore, the Project willcontribute to meeting the City's Regional Housing Needs Allocation (RHNA), aswell as the Housing Element policies.

TENTATIVE TRACT MAP

1. The proposed map is consistent with the General Plan.

The proposed map is consistent with the provisions of the General Plan. The applicant is requesting Tentative Tract Map No. TT-19129 approval to subdivide the subject property to facilitate the development of a three-story, townhome residential project consisting of twenty (20) for-sale condominium units, which includes one (1) affordable housing unit for "very low-income" households. The site has a land use designation of Residential/Commercial Mixed Use 2 (RC2), which is intended to allow for mixed use residential and commercial developments with higher residential densities at 24 dwelling units per acre. The RC2 land use designation is implemented by the GGMU-2 (Garden Grove Boulevard Mixed Use 2) zone, which allows residential developments without a commercial component. The proposed project willconsist of twenty (20) units, which is the maximum number of units allowed by the RC2 land use designation and the GGMU-2 zone, and is therefore consistent with the General Plan. Moreover, construction of the residential project will increase the number of available housing in the area, and further the goals of the Housing Element of the General Plan to meeting the City's Regional Housing Needs Allocation (RHNA).

In addition, the proposed map is consistent with the goals and policies of the General Plan, including:
a. Goal LU-3: Higher-density residential development along major thoroughfares and in areas well served by public transit, retail and service businesses, public services, and public gathering places.

The project site has a General Plan land use designation of RC2, which is intended to allow higher residential densities at 24 dwelling units per acre. The site fronts Garden Grove Boulevard, which is a major 220
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thoroughfare served by public transit, retail and service businesses, and public services.
b. Policy LU-3.2: Support development of multi-family housing that provides a diversity of densities, types, and prices that meet the needsof all household income levels.

The proposed project is a multi-family, twenty (20) unit for-sale townhome development designed at 24 dwelling units per acre. The proposed project has been designed under the State Density Bonusallowances for parking, one (1) concession, and one (1) waiver.

Under RC2 General Plan land use designation, the subject project is allowed a maximum density of 24 dwelling units per acre, which yields twenty (20) units. The project proposed is a twenty (20) unit townhome residential development that maximizes the allowable density.

Furthermore, the Project will contribute to meeting the City's Regional Housing Needs Allocation (RHNA), as well as the Housing Elementpolicies. d. Goal LU-4: The City seeks to develop uses that are compatible with one another.

Thus, the proposed housing project is consistent with the development pattern of the surrounding residential uses.
e. LU-IMP-2B: New development shall be similar in scale to the adjoining residential neighborhood to preserve its character.

The proposed density, which is twenty (20) townhome units for a 36,945 square foot (0.8 acres) lot, maximizes the allowable density for theGGMU-2 zoned site. The proposed project was reviewed by the City staffand deemed to be within the allowed density, as set forth by the Code. 221
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The proposed design is compatible with the physical scale of the immediate neighborhood, which is improved with multi-familydevelopments ranging from one to two stories. Thus, the project issimilar both in land use intensity and physical scale of the adjoining residential neighborhood.
f. LU-IMP-3D: Front multi-family housing on local streets with appropriate setbacks to be consistent with neighborhood development patterns.

The project was reviewed by City staff and was determined to meet the required front, side, and rear setbacks, as set forth by the GGMU-2 zone development standards. The proposed buildings will maintain a 17-5"setback from the front property line along Garden Grove Boulevard, and 12'-3" from the rear property line. The proposed buildings located on the east side of the site are setback 10'-6" from the easterly property line, and the buildings located to the west of the site are setback ll'-6" from the westerly property line, which exceeds the setback standards of the GGMU-2 zone. Thus, the setbacks are consistent to the neighborhood development patterns.
g. Policy LU-2.4: Assure that the type and intensity of land use shall be consistent with that of the immediate neighborhood.

The immediate area consists of both multiple-family dwellings and commercial developments. The proposed twenty (20) unit townhome project was reviewed and determined to be within the allowed densityand in compliance with the GGMU-2 zone development standards as set forth by the Municipal Code. Thus, the development is consistent withthe type and intensity of land use of the immediate neighborhood. h. Policy 2,3 of the Housing Element: Provide density bonuses and other financial and regulatory incentives to facilitate the development of affordable housing.

9.18.090.020.F of the Municipal Code, which requires a boulevard garden plaza for properties in the GGMU zones for properties abutting the Garden Grove Boulevard right-of-way. The granting of the concession and waiver is needed to facilitate the construction of the 222
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proposed development and to support the creation of more affordable housing units in the City. Furthermore, the Project will contribute tomeeting the City's Regional Housing Needs Allocation (R.HNA).

2. The design and improvement of the proposed subdivision are consistent with the General Plan.

The proposed map is consistent with the provisions of the General Plan. The applicant is requesting Tentative Tract Map No. TT-19129 approval to subdivide the subject property to facilitate the development of a three-story, townhome residential project consisting of twenty (20) for-sale condominium units, whichincludes one (1) affordable housing unit for "very low-income" households. Thesubject site has a General Plan Land Use Designation of RC2 which is intended to allow for mixed use residential and commercial developments with higher residential densities at 24 dwelling units per acre. The RC2 land usedesignation is implemented by the GGMU-2 zone which allows residential developments without a commercial component. In accordance with the State Subdivision Map Act, the applicant is requesting approval of Tentative Tract Map No. TT-19129 to subdivide the existing property into two (2) lots for the purpose of selling each townhome unit as a condominium. Lot 1 will be comprised of Units 1 thru 20, and Lot 2 will include all common areas, including the drive aisle, guest parking, trash enclosure, and active recreation areas.

The proposed Tentative Tract Map is in conformance with the City's General Plan, the City's Subdivision Ordinance, the GGMU-2 zone requirements, and the State's Subdivision Map Act.
3, The site is physically suitable for the type of development and complies with the spirit and intent of the Municipal Code.

The site is physically suitable for the type of development proposed by the developer and complies with the spirit and intent of the Municipal Code. The proposed project will consist of a stand-alone residential development, which is an allowed use by the Municipal Code for GGMU-2 zoned properties. The project has also been designed to comply with the development standards in the Municipal Code and the State Density Bonus allowances for parking, one (1) concession, and one (1) waiver to deviate from the GGMU-2 development standards: (1) a concession to allow the building to be constructed within the45-degree encroachment plane required for mixed use zoned properties abutting residentially-zoned lots along the side yard setback; and (2) a waiver to deviate from Section 9.18.090.020.F of the Municipal Code, which requires a boulevard garden plaza for properties in the GGMU zones for propertiesabutting the Garden Grove Boulevard right-of-way. As designed, the site isable to accommodate twenty (20) units, and the required parking, landscaping, private and common recreation areas, setbacks, and buildingheight. Therefore, the property is sufficient in size to accommodate the 223
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proposed development, and complies with all applicable provisions of the Cityof Garden Grove Municipal Code and the State Density Bonus Laws,

4. The design of the subdivision and the proposed improvements are not likely to cause substantial environmental damage or substantially and avoidably injure fish or wildlife or their habitat, and the requirements of the California Environmental Quality Act have been satisfied.Pursuant to the California Environmental Quality Act ("CEQA"), the City of Garden Grove Planning Commission has determined that the proposed project is categorically exempt from the CEQA pursuant to Section 15332 (In-Fill Development Projects) of the CEQA Guidelines (14 Cal. Code Regs., Section 15332). The proposed project is characterized as in-fill development meeting conditions described in Section 15332.

5. The site is physically suitable for the proposed density of the development.

The site is physically suitable for the density proposed by the developer. The General Plan land use designation of RC2 is intended to allow for mixed use residential and commercial developments with higher residential densities at24 dwelling units per acre. The RC2 land use designation is implemented by the GGMU-2 zone which allows residential developments without a commercial component. The proposed project will consist of twenty (20) units, which is the maximum number of units allowed by the General Plan land use designationand the GGMU-2 zone. The project has also been designed to comply with State Density Bonus allowances for parking, one (1) concession, and one (1) waiver to deviate from the GGMU-2 development standards: (1) a concessionto allow the building to be constructed within the 45-degree encroachment plane required for mixed use zoned properties abutting residentially-zoned lots along the side yard setback; and (2) a waiver to deviate from Section9.18.090.020.F of the Municipal Code, which requires a boulevard garden plaza for properties in the GGMU zones for properties abutting the Garden Grove Boulevard right-of-way. As designed, the site is able to accommodate twenty(20) units, and the required parking, landscaping, private and common recreation areas, setbacks, and building height. Therefore, the property is sufficient in size to accommodate the proposed development, and complieswith all applicable provisions of the City of Garden Grove Municipal Code and the State Density Bonus Laws.

6. The design of the subdivision and the proposed improvements are not likely to cause serious public health problems.

The design of the subdivision and the proposed improvements are not likely to cause serious public health problems since conditions of approval will be in place to safeguard the public health. The proposed subdivision has been designed to comply with the development standards of the GGMU-2 zone and 224
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the State Density Bonus Laws. City Departments, including the Traffic Division, Water Division, Engineering Division and the Planning Division, and the Orange County Fire Authority (OCFA) have reviewed the proposed development and have applied conditions of approval to minimize potential negative impacts that the project may have on the community. The conditionsof approval for on and off-site improvements will safeguard the public health.

7. The design of the project and the proposed improvements will not conflict with easements of record or easements established by court judgment acquired by the public at large for access through or use of property within the subdivision; or, if such easements exist, alternate easements for access or for use will be provided and these will be substantially equivalent to the ones previously acquired by the public.

The design of the subdivision and the proposed improvements will not conflict with easements of record or easements established by court judgment acquired by the public at large for access through or use of property within the proposed subdivision. The project has been designed to avoid development over existing easements.

8. The design and improvement of the proposed subdivision are suitable for the uses proposed and the subdivision can be developed in compliance with theapplicable zoning regulations.

The proposed subdivision has been specifically designed to accommodate the proposed twenty (20) unit residential townhome project on the property, whichhas been designed to comply with the GGMU-2 zone developments standards and State Density Bonus allowances for parking, concessions, and waivers:one (1) concession, and one (1) waiver to deviate from the GGMU-2development standards: (1) a concession to allow the building to beconstructed within the 45-degree encroachment plane required for mixed use zoned properties abutting residentially-zoned lots along the side yard setback; and (2) a waiver to deviate from Section 9.18.090.020.Fof the Municipal Code,which requires a boulevard garden plaza for properties in the GGMU zones for properties abutting the Garden Grove Boulevard right-of-way. As designed, the subdivision is able to accommodate twenty (20) units, and the required parking, landscaping, private and common recreation areas, setbacks, andbuilding height. Therefore, the design and improvement of the proposed subdivision is suitable for the proposed use and the subdivision can be developed in compliance with the applicable provisions of the City of GardenGrove Municipal Code and the State Density Bonus Laws.

9. The design of the subdivision provides, to the extent feasible, for future passive or natural heating and cooling opportunities in the subdivision. 225
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To the extent feasible, the project has been designed in accordance with Government Code Section 66473.1, such as to allow for passive or natural heating opportunities in the subdivision design, to encourage the orientation of structures to take advantage of shade and prevailing breezes, to allow solar access for passive heating and opportunities for placement of shade trees andother vegetation for cooling.

10. The design, density, and configuration of the subdivision strike a balance between the affect of the subdivision on the housing needs of the region andpublic service needs. The character of the subdivision is compatible with the design of existing structures, and the lot sizes of the subdivision are substantially compatible with the lot sizes within the general area.

The applicant is requesting approval of Tentative Tract Map No. TT-19129 to subdivide the existing property into two (2) lots for the purpose of selling each townhome unit as a condominium. Lot 1 will be comprised of Units 1 thru 20, and Lot 2 will include all common areas, including the drive aisle, guest parking, and active recreation areas. Approval of the map will allow construction of a three-story, townhome residential project consisting of twenty (20) units, which includes one (1) affordable housing unit for "very lowincome" households on a site currently improved with an auto dealership that has been out of business since 2018. The project has been reviewed in relation to the housing needs and goals of the City and is compatible with existing residential developments in the vicinity. The property is located in an area with existing multi-family and commercial uses. Per the maximum density allowed by the Residential/Commercial Mixed Use 2 land use designation, theproposal includes twenty (20) new multi-family residential townhomes that willincrease the number of available housing in the area, and further the goals of the Housing Element of the General Plan. The project complies with the density requirements of the General Plan, as well as the GGMU-2 zone development standards and allowances allowed by State Density Bonus laws.

11. The subject property is not located within a state responsibility area or a very high fire hazard severity zone, the proposed subdivision is served by local fire suppression services, and the proposed subdivision meets applicable design, location, and ingress-egress requirements.

12. The discharge of waste from the proposed subdivision into the existing sewer system will not result in violation of existing requirements prescribed by theCalifornia Regional Water Quality Control Board. The conditions of approval foron and off-site improvements will ensure permitted capacity of the public sewer system is not exceeded.
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NO NET LOSS fGOVERNMENT CODE SECTION 658631 FINDINGS

1. If approval of the proposed Project will result in development of the Site at a lower residential density, the reduction in residential density is consistent with the adopted general plan, including the housing element.

The project site is approximately 36,945 square feet (0.85 acres) and is located at 8722 Garden Grove Boulevard (APN #097-222-03). The subject site has a General Plan Land Use designation of Residential/Commercial Mixed Use 2 and is zoned GGMU-2 (Garden Grove Boulevard Mixed Use 2). The project site isidentified in the City's Housing Element sites inventory as having a realisticcapacity to accommodate a total of twenty (20) "moderate income" units. Theproject proposes a total of twenty (20) units consisting of nineteen (19)"above moderate income" units and one (1) "very low income" unit. The maximum allowable residential density for the site under the General Plan Land Use Element and Municipal Code is 24 units per acre, or twenty (20) units. Theapplicant is proposing to develop the site at the maximum permitted density.

The City cannot require the applicant to seek a larger density bonus.Therefore, even though the proposed project results in units with differing income categories than identified in the Housing Element site inventory, the twenty (20) units proposed is consistent with the density limits of the General Plan. The proposed project is also consistent with several goals and policies of the General Plan Land Use Element, as noted in the findings above.

2. The remaining sites identified in the housing element are adequate to meet the requirements of Government Code Section 65583.2 and to accommodate the City's share of the regional housing need pursuant to Government Code Section 65584; or, if not, the City has, or will within 180 days, identify and make available additional adequate sites to accommodate the City's share of the regional housing need by income level.

The City's 6th Cycle RHNA requires the City to plan for 19,168 housing units for all income levels. A component of preparing the City's Housing Element is the identification of vacant and underutilized sites suitable for residential development, and an evaluation of the housing development potential of these sites in fulfilling the City's RHNA. The project site is identified in the City's Housing Element sites inventory as having a realistic capacity to accommodate a total of nineteen (19) "moderate income" units. The project proposes a total of twenty (20) units consisting of nineteen (19) "above moderate income" units and one (1) "very low income" unit. Although the proposed project provides units in differing income categories than shown in the Housing Element sites inventory, the remaining Housing Element inventory sites have sufficientcapacity to accommodate the City's remaining unmet RHNA by income level if the project is approved as proposed.
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At the time the Housing Element was prepared and adopted, the City's unmet RHNA was calculated to be 18,208 units, broken down as follows: 6,567 low and very low-income units, 3,087 moderate-income units, and 8,554 above moderate-income units. The sites identified in the adopted Housing Element were determined adequate to accommodate a total of 18,291 units, including401 more units than the City's unmet RHNA in the low and very low-income categories and 240 more units than the City's unmet RHNA for themoderate-income category. Sites deemed adequate to accommodate the lower and moderate-income categories are also adequate to accommodateabove-moderate income units. Overall, the sites inventory in the adoptedHousing Element reflected a total capacity surplus of 83 units.

Excluding ADUs, single-family dwellings, and SB 9 units, Staff has identifiedrecently permitted or approved new housing units not accounted for in theHousing Element site capacity analysis. Some of these units were developed on sites not included in the Housing Element sites inventory. After accounting for these permitted and entitled units, and the twenty (20) units in the proposed project, the City's total remaining unmet RHNA would be 18,113 units1, broken down as follows: 6,561 low and very low-income units, 3,087 moderate-income units, and 8,465 above-moderate income units. Theremaining capacity of the sites identified in the Housing Element would be 18,196 units, resulting in a total capacity surplus of 83 units. The remaining sites are also adequate to accommodate a surplus of low and very low-income units (407) and moderate-income units (221), and such sites are also adequate to accommodate the City's remaining unmet above moderateincome RHNA. Due to this surplus, the overall residential capacity on sitesidentified in the Housing Element will still be sufficient to accommodate theCity's total remaining unmet RHNA if the proposed project is approved.

INCORPORATION OF FACTS AND FINDINGS SET FORTH IN STAFF REPORTIn addition to the foregoing, the Planning Commission incorporates herein by this reference, the facts and findings set forth in the staff report.BE IT FURTHER RESOLVED that the Planning Commission does conclude:

1. The Site Plan and Tentative Tract Map possess characteristics that would justify the request in accordance with Municipal Code Section No. 9.32.030.3 (Site Plan) and Section 9.40.060 (Tentative Maps).

2. In order to fulfill the purpose and intent of the Municipal Code and thereby promote the health, safety, and general welfare, the attached Conditions of Approval (Exhibit "A") shall apply to Site Plan No. SP-119-2022 and Tentative Tract Map No. TT-19129.
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Adopted this 15th day of December 2022ATTEST: /s/ JOHN RAMIREZ CHAIR
/S/ JUDITH MOORE

RECORDING SECRETARY
STATE OF CALIFORNIA )COUNTY OF ORANGE ) SS:

CIJ\ OF GARDEN GROVE )
I/ JUDITH MOORE, Secretary of the City of Garden Grove Planning Commission,do hereby certify that the foregoing Resolution was duly adopted by the Planning Commission of the City of Garden Grove, California, at a meeting held on December 15, 2022, by the following vote:

AYES: COMMISSIONERS: (4) ARESTEGUI, LEHMAN, LINDSAY, RAMIREZ NOES: COMMISSIONERS: (0) NONE
ABSENT: COMMISSIONERS: (2) CUNNINGHAM, PEREZ
/s/ JUDITH MOORE

RECORDING SECRETARY
PLEASE NOTE: Any request for court review of this decision must be filed within 90 days of the date this decision was final (See Code of Civil Procedure Section 1094.6).

A decision becomes final if it is not timely appealed to the City Council. Appeal deadline is January 5, 2023.
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EXHIBIT "A"
Site Plan No. SP-119-2022
Tentative Tract Map No. 19129
8722 Garden Grove Boulevard

CONDITIONS OF APPROVAL
General Conditions

1. The applicant and each owner of the property shall execute, and the applicant shall record a "Notice of Agreement with Conditions of Approval and Discretionary Permit of Approval," as prepared by the City Attorney's Office, on the property. Proof of such recordation is required prior to issuance of building permits.

2. All Conditions of Approval set forth herein shall be binding on and enforceable against each of the following, and whenever used herein, the term "applicant"shall mean and refer to each of the following: the project applicant, owner anddeveloper of the project, NRI Portfolios, LLC, and the future owner(s) and tenants(s) of the property, and each of their respective successors and assigns.

All conditions of approval are required to be adhered to for the life of the project, regardless of property ownership. Except for minor modificationsauthorized to be approved by the Community and Economic Development Director pursuant to Condition No. 4, any changes of the Conditions of Approval require approval by the appropriate City hearing body.

3. Site Plan No. SP-119-2022 only authorizes approval to a three-story, townhome residential project consisting of twenty (20) units, which includes one (1) affordable housing unit for "very low-income" households on a 36,945square-foot (0.85 acres) lot located on the south side of Garden Grove Boulevard, between Newland Street and Yockey Street, at 8722 Garden Grove Boulevard (APN: 097-222-03), as depicted on the plans submitted by the applicant and made part of the record of the November 17, 2022, PlanningCommission proceedings. Approval of this Site Plan shall not be construed to mean any waiver of applicable and appropriate zoning and other regulations; and wherein not otherwise specified, all requirements of the City of GardenGrove Municipal Code shall apply.

4. The approved site plan and floor plan are an integral part of the decision approving this Site Plan. There shall be no additional changes in the design of the site plan and floor plan without the approval of the City. Minor modifications to the Site Plan and/or these Conditions of Approval, which donot materially change the scope or intensity of the project and which will notresult in impacts that have not previously been addressed, may be approvedby the Community and Economic Development Director, in his or her FINAL
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Exhibit "A" Page 2
Site Plan No. SP-119-2022 and Tentative Tract Map No. 19129Conditions of Approval discretion. Proposed modifications to the project and/or these Conditions of Approval determined by the Community and Economic Development Director not to be minor in nature shall be subject to approval of new and/or amended land use entitlements by the applicable City hearing body.

5. All conditions of approval shall be implemented at the applicant's expense, except where specified in the individual condition.

Public Works Engineering Division
Project Design

6. A geotechnical study prepared by a registered geotechnical engineer is required. The report shall analyze the liquefaction potential of the site and make recommendations. The report shall analyze sub-surface issues related to the past uses of the site, including sub-surface tanks and basement and septic facilities. Any soil or groundwater contamination shall be remediated prior to the issuance of a building permit per the requirements of the Orange County Health Department and the mitigation requirements of governingregulatory requirements. The report shall make recommendations for foundations and pavement structural section design of interior streets and parking spaces. The report shall also test and analyze soil conditions for LID (Low Impact Development) principles and the implementation of water quality for storm water run-off, including potential infiltration alternatives, soil compaction, saturation, permeability and groundwater levels.

7. Prior to the issuance of any grading or building permits, the applicant shall submit to the City for review and approval a final design Water Quality Management Plan that:
a. Addresses required mitigation Site Design Best Management Practices (BMPs) based upon the latest Santa Ana Regional Water Quality ControlBoard (SARWQCB) approved Drainage Area Management Plan (DAMP) asidentified in the geotechnical report recommendations and findings,including, but not limited to, infiltration minimizing impervious areas, maximizing permeability, minimizing directly connected impervious areas, creating reduced or "zero discharge" areas, and conserving natural areas as required by the latest adopted County of Orange TechnicalGuidance Document (TGD). b. BMP's shall be sized per the requirements of the latest Technical Guidance Documents.
c. Incorporates the applicable Routine Source Control BMPs as defined in the DAMP.

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Site Plan No. SP-119-2022 and Tentative Tract Map No. 19129Conditions of Approval d. Incorporates structural and Treatment Control BMPs as defined in the DAMP.
e. Generally describes the long-term operation and maintenance requirements for the Treatment Control BMPs.
f. Identifies the entity that will be responsible for long-term operation and maintenance of the Treatment Control BMPs.
g. Describes the mechanism for funding the long-term operation and maintenance of the Treatment Control BMPs.
h. Provides a hydrological analysis with scaled map as well as hydrologic and hydraulic calculations to size storm drains per the Orange County RDMD standards.

8. Parkway culverts shall be designed per City of Garden Grove Standard Plan B-209. Storm drain lateral pipe connections to City maintained storm drains within City right-of-way shall be RCP with a minimum diameter of 18-inches.

9. Grading plans prepared by a registered Civil Engineer are required. As required under Section 107 of the California Building Code (CBC), the grading plan shallbe based on a current survey of the site, including a boundary survey, topography on adjacent properties up to 30/-0" outside the boundary, and designed to preclude cross lot drainage. Minimum grades shall be 0.50% for concrete flow lines and 1.25% for asphalt. The grading plan shall also includewater and sewer improvements. The grading plan shall include a coordinated utility plan showing all existing utility facilities, easements and proposed utility facilities. All on-site improvements shall be tied by horizontal dimensional control to the property boundary as established by survey. A minimum uninterrupted 20-foot wide throat access to the site is required from the street for the multi residential projects and shall meet the requirements of the California Fire Code throughout the site. Vehicle maneuvering, as demonstrated by Auto Turn along private streets and access ways, shall bedemonstrated on the grading plan. Street improvement plans shall conform toall format and design requirements of the City Standard Drawings &.

Specifications.

10. All vehicular access drives to the site shall be provided in locations approved by the City Traffic Engineer (Policies and Procedures - TE-17).

11. The applicant shall coordinate with Planning Services Division and Orange County Fire Authority to identify proper emergency vehicle access to the site and shall provide the Engineering Division a copy of the approval letters upon first submittal of the grading and street improvement plans.

12. The applicant shall complete the following for the tract map:

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Exhibit "A" Page 4
Site Plan No. SP-119-2022 and Tentative Tract Map No. 19129Conditions of Approval a. Prior to recordation of a final parcel or tract map, the surveyor/engineer preparing the map shall tie the boundary of the map into the Horizontal Control System established by the County Surveyor in a manner described in Sections 7-9-330 and 7-9-337 of the Orange County Subdivision Codeand Orange County Subdivision Manual, Subarticle 18. The surveyor/engineer shall submit record information to the City on Auto Cad DWG format.
b. Prior to recordation of a final parcel or tract map, the surveyor/engineer preparing the map shall submit to the County Surveyor a digital graphics file of said map in a manner described in Sections 7-9-330 and 7-9-337 of the Orange County Subdivision Code and Orange County Subdivision Manual, Subarticle 18. The surveyor/engineer shall submit recordinformation to the City on Auto Cad DWG format. c. Prior to issuance of a grading permit, the applicant shall submit to the Planning Services Division an updated title report along with copies of therecorded instruments listed in the title report, reference maps used toprepare legal description and the plat for review and approval of the parcel map.
d. All subdivision mapping shall be concurrently reviewed by the City Engineering Division and the County of Orange Survey Department. The applicant shall forward all plan check comments received from the County of Orange Survey Department to the City of Garden Grove's Engineering Division upon receipt from the county.

13. Prior to the issuance of the street improvement encroachment permit and grading permit, provide subdivision completion bonds for all work constructed under the street improvements and grading permit for review and approval by the City Engineer, City Attorney, and City Finance Department (Risk Management). Alternate forms of security may be considered, solely at the discretion of the City Engineer and with the concurrence of the City Attorneyand City Finance Department (Risk Management).

14. Any new drive approaches to the site shall be constructed in accordance with Garden Grove Standard B-120 (Option #2) as they conform to land use and roadway designation.

15. The grading plan shall depict an accessibility route for the ADA pathway in conformance with the requirements of the Department of Justice standards, latest edition and section 1110A of the California Building Code (CBC).

16. All trash container areas shall meet the following requirements per City of Garden Grove Standard B-502 and State mandated commercial organic recycling Law, including AB 1826, SB 1383, and any other applicable Staterecycling laws related to refuse, recyclables, and/or organics; FINAL
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Exhibit "A" Page 5
Site Plan No. SP-119-2022 and Tentative Tract Map No. 19129Conditions of Approval a. Paved with an impervious surface, designed not to allow run-on mixing of drainage from adjoining areas, designed to divert drainage from adjoining roofs and pavements to be directed around the area for trash roll out, and screened or walled to prevent off-site transport of trash by water or wind. b. Provide solid roof or awning to prevent direct precipitation into the enclosure.
c. Connection of trash area drains to the municipal storm drain system is prohibited. Drainage from the enclosure may be directed to a conforming grease or contaminant interceptor.
d. Potential conflicts with fire code access requirements and garbage pickup routing for access activities shall be considered in implementation of design and source control. See CASQA Storm Water Handbook Section

3.2.9 and BMP Fact Sheet SD-32 for additional information. e. The trash enclosure and containers shall be located to allow pick-up and maneuvering, including turn-arounds, in the area of enclosures, and concrete aprons for roll-out areas.
f. Pursuant to state mandated commercial organic recycling Law-AB 1826 and SB 1383, the applicant is required to coordinate storage and removalof the organics waste with local recycling/trash company. g. Pursuant to applicable state mandated laws, the applicant is required to contact and coordinate with the operations manager of the local recycling/trash company (Republic Services, 800-700-8610) to ensure the trash enclosure includes the appropriate size and number of containers for the disposal of items such as, but may not limited to, municipal solid waste (MSW), recyclables, and organic green waste. h. Based on the amount of waste disposed, per week, the applicant shall coordinate with the local recycling/trash company to ensure the adequate frequency of trash pick-up is serviced to the site for municipal solid waste (MSW), recyclables, organic and green waste, and any other type of waste.
i. The applicant shall ensure large bulk items, intended for coordinated and scheduled pick-up by the local recycling/trash company, are not placed in areas that encroach into drive aisles, parking spaces, pedestrianpathways, or areas in the front of the property including areas publicright-of-way (e.g., street, sidewalk), during and after construction. Anylarge bulk items shall be out of public vantage points. j. The requirements for the trash enclosure and design criteria are bound and coordinated with the Water Quality Management Plan (WQMP), when FINAL
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Exhibit "A" Page 6
Site Plan No. SP-119-2022 and Tentative Tract Map No. 19129 Conditions of Approval
required, as depicted on the project grading plan, which shall beincorporated into the WQMP by narrative description, exhibits and an Operation and Maintenance Plan (O&M).

17. Any new or required block walls and/or retaining walls shall be shown on the grading plans, both in plan-view and cross sections. Cross sections shall show vertical and horizontal relations of improvements (existing and proposed) on both sides of property lines. Required wall heights shall be measured vertically from the highest adjacent finished grade. Block walls shall be designed in accordance to City of Garden Grove Standard B-504, B-505, B-506 and B-508 or designed by a professional registered engineer. In addition, the followingshall apply:
a. Any block walls shall be decorative and utilize stucco finish, slump stone or split-face block, and shall include trailing vines, hedges planted along the base of the exterior face, or other landscaping treatments that deter graffiti.
b. Openings for drainage through walls shall be shown in section details and approved by the City Engineer. Cross-lot drainage is not allowed.

18. The applicant shall remove any existing substandard driveway approaches, curbs, sidewalks, ADA ramps, pavement sections, tree well and landscaping, and construct Garden Grove Boulevard frontage improvements as identified below. All landscape, irrigation, sidewalk, and lighting improvements installed within the public rights-of-way shall be maintained by the applicant and shall require the approval of the City Engineer, Street Division, and PlanningDivision, and shall be maintained by the applicant for the life of the project. a. Existing substandard driveways on Garden Grove Boulevard shall be removed and replaced with new curb, gutter, landscape, and sidewalk per City standards and specifications.
b. The new driveway approach to the site on Garden Grove Boulevard shall be constructed in accordance with Garden Grove Standard B-120 (Option #3).
c. The applicant shall remove the existing damaged sidewalk panels fronting the project on Garden Grove Boulevard and replace it with new sidewalk panels in accordance with City of Garden Grove Standard B-106. The owner/contractor shall verify the removal and replacement sections of the sidewalk concrete panels with Public Works inspector prior to start ofconstruction. d. The new tree wells fronting the project on Garden Grove Boulevard shall be constructed in accordance with Garden Grove Standard B-123 and B-127.

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Exhibit "A" Page 7
Site Plan No. SP-119-2022 and Tentative Tract Map No. 19129 Conditions of Approval
e. The applicant shall plant total of four Columbia Sycamore tree (36-inch box). The applicant shall coordinate with City's Public Works Departmentprior to order and placement of trees on Garden Grove Boulevard. f. Construct curb and gutter when replacing any existing driveway approach along the property frontage on Garden Grove Boulevard in accordancewith City Standard Plan B-113. g. The applicant shall locate all existing public utilities across the property frontage and within the property boundary of the project prior to commencement of grading operation and mobilization.
h. The applicant shall coordinate with the Planning Services Division and Public Works Street Division before placing any type of tree within publicright-of-way and proposed landscape area.

I. Street signs shall be installed as required and approved by the City Traffic Engineer.

19. Any proposed new landscaping in public right-of-way shall be approved by the Planning Services Division and maintained by the owner for the life of theproject.

20. Driveway widths shall be in accordance with City's Traffic Engineering Policy TE-8 (Driveway Opening Policy).

21. Sight Distance Standards shall be in accordance with City's Traffic Engineering Policy TE-13. All structures and walls shall be designed to ensure proper vision clearance for cars entering or leaving the driveway and parking areas. Nostructure, wall or fence shall cause an exceedance of the applicable sitedistance standards set forth in City Traffic Engineering Policy TE 13.

22. The Site Plan shall comply with the completed Development Review and Comment Sheet prepared pursuant to City's Traffic Engineering Policy TE-17and provided to the applicant.

23. Private Property Tow Away Sign Design shall be in accordance with City's Traffic Engineering Policy TE-19.

24. No Parking Fire Lane Sign Design shall be in accordance with City's Traffic Engineering Policy TE-20.

25. Parking lot layout shall be in accordance with City Standard B-311 and B-312.

26. Off-street parking requirements for residential uses shall be in accordance with the City of Garden Grove's Traffic Engineering Policy TE-17.

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Exhibit "A" Page 8
Site Plan No. SP-119-2022 and Tentative Tract Map No. 19129Conditions of Approval

27. A minimum five-foot-by-five-foot-wide maneuvering area shall be provided at the end of a dead-end parking aisle and shall consists of a ten-foot-bynineteen-foot-wjde turn-around space.

Permit Issuance

28. The applicant shall be subject to Traffic Mitigation Fees (Garden Grove City Council Resolution 9401-16), In-Lieu Park Fees Drainage Facilities Fees, Water Assessment Fees, and other applicable mitigation fees identified in Chapter

9.44 of the Garden Grove Municipal Code, along with all other applicable feesduly adopted by the City. The amount of said fees shall be calculated based on the City's current fee schedule at the time of permit issuance.

29. A separate street permit is required for work performed within the public right-of-way.

30. Grading fees shall be calculated based on the current fee schedule at the time of permit issuance.

31. The applicant shall identify a temporary parking site(s) for construction crew and construction trailers office staff prior to issuance of a grading permit. Noconstruction parking is allowed on local streets. Construction vehicles should be parked off traveled roadways in a designated parking area. Parking areas, whether on-site or off-site, shall be included and covered by the erosion control plans.

32. Prior to issuance of a grading permit, the applicant shall submit and obtain approval of a work-site traffic control plan for all the proposed improvementswithin public right-of-way, and shall be subject to the review and approval of the City Traffic Engineer.

33. In accordance to City of Garden Grove Municipal Code (Chapter 9.48.030), the applicant is required to underground all existing and proposed on-site andoff-site utility facilities fronting the project which the developer is developingor redeveloping. All existing improvements and utilities shall be shown as partof the grading submittal package in the topography section.

Project Construction/Operation34. The applicant shall coordinate with City's Public Works Department (Engineering, Water Services and Streets Division) and setup appointments forpre-construction inspections for all the on-site and off-site improvements prior to commencement of grading operation and mobilization.

35. In accordance with the Orange County Storm Water Program manual, the applicant and/or its contractors shall provide dumpsters on-site during FINAL
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Exhibit "A" Page 9
Site Plan No. SP-119-2022 and Tentative Tract Map No. 19129Conditions of Approval construction unless an Encroachment Permit is obtained for placement instreet.

36. The applicant and his contractor shall be responsible for protecting all existing horizontal and vertical survey controls, monuments, ties (centerline andcomer) and benchmarks located within the limits of the project. If any of theabove require removal; relocation or resetting, the Contractor shall, prior to any construction work, and under the supervision of a California licensed LandSurveyor, establish sufficient temporary ties and benchmarks to enable the points to be re-set after completion of construction. Any ties, monuments and bench marks disturbed during construction shall be re-set per Orange CountySurveyor Standards after construction. Applicant and his contractor shall also re-set the tie monuments where curb or curb ramps are removed and replaced or new ramps are installed. The Applicant and his contractor shall be liable for, at his expense, any resurvey required due to his negligence in protecting existing ties, monuments, benchmarks or any such horizontal and verticalcontrols. Temporary Benchmarks shall not be used for Vertical control.

Benchmarks shall be to the National Geodetic Vertical Datum (NGVD).

37. Heavy construction truck traffic and hauling trips, and any required lane closures shall occur outside peak travel periods. Peak travel periods areconsidered to be from 7:00 a.m. to 9:00 a.m. and 4:00 p.m. to 6:00 p.m.

38. Prior to grading or building permit closeout and/or the issuance of a certificate of use or a certificate of occupancy, the applicant shall:
a. Demonstrate that all structural best management practices (BMPs) described in the Project WQMP have been constructed and installed in conformance with approved plans and specifications.
b. Demonstrate that the applicant is prepared to implement and maintain all non-structural BMPs described in the Project WQMP.
c. Demonstrate that an adequate number of copies of the approved Project WQMP are available on-site.
d. Submit for review and approval by the City an Operations and Maintenance (O&M) Plan for all structural BMPs.

Public Works Water Serv i ces Division39. New water service installations 2" and smaller, shall be installed by the City of Garden Grove at owner's/developer's expense. Installation shall be scheduled upon payment of applicable fees, unless otherwise noted. Fire services andlarger water services 3" and larger, shall be installed by developer/owner's contractor per City Standards.

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Exhibit "A" Page 10
Site Plan No. SP-119-2022 and Tentative Tract Map No. 19129Conditions of Approval

40. Water meters shall be located within the City right-of-way. Fire services and large water services 3" and larger, shall be installed by contractor with Class A or C-34 license, per City water standards and inspected by approved Public Works inspection.

41. A Reduced Pressure Principle Device (RPPD) backflow prevention device shall be installed the landscape system. Installation shall be per City Standards and shall be tested by a certified backflow device tester immediately after installation. Cross connection inspector shall be notified for inspection after the installation is completed. Owner shall have RPPD device tested once a year thereafter by a certified backflow device tester and the test results to be submitted to Public Works, Water Services Division. Property owner must opena water account upon installation of RPPD device.

42. It shall be the responsibility of owner/developer to abandon any existing private water well(s) per Orange County Health Department requirements.

Abandonment(s) shall be inspected by Orange County Health Department inspector after permits have been obtained.

43. A composite utility site plan shall be part of the water plan approval.44. New utilities shall have a minimum 5-foot horizontal and a minimum 1-foot vertical clearance from water main and appurtenances.

45. Any new or existing water valve located within new concrete driveway or sidewalk construction shall be reconstructed per City Standard B-753.

46. If fire sprinkler system is required, and a separate fire service is not proposed, the meter and service for the new lot shall be installed per City Standard B-719, which specifies a residential fire sprinkler connection (RFSC) on thebackside of the meter.

47. If required, fire service and any private fire hydrant laterals shall have above-ground backflow device with a double check-valve assembly. Device shall be tested immediately after installation and once a year thereafter by acertified backflow device tester and the results to be submitted to Public Works, Water Services Division. Device shall be on private property and is the responsibility of the property owner. The above-ground assembly shall be screened from public view as required by the Planning Division.

48. Water meters and boxes shall be installed by City forces upon payment of applicable fees and after new water system (including water services) pass all bacteriological and pressure tests.

49. Location and number of fire hydrants shall be as required by Water Services Division and the Orange County Fire Authority.

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Exhibit "A" Page 11
Site Plan No. SP-119-2022 and Tentative Tract Map No. 19129 Conditions of Approval

50. Owner shall install new sewer lateral with clean out at right-of-way line.

Lateral in public right-of-way shall be 6" min. dia., extra strength VCP with wedgelock joints. Lateral shall connect to the 18" sewer main in Garden Grove Blvd through a new manhole.

51. Contractor shall abandon any existing sewer lateral(s) at street right-of-way on the property owner's side. The sewer pipe shall be capped with anexpansion sewer plug and encased in concrete. Only one sewer connection per lot is allowed.

52. All perpendicular crossings of the sewer, including laterals, shall maintain a vertical separation of min. 12" below the water main, outer diameter to outer diameter. All exceptions to the above require a variance from the State Water Resources Control Board.

53. If water main is exposed during installation of sewer lateral, a 20-foot section of the water main shall be replaced with 20ft PVC C-900 DR-14 Class 305 waterpipe, size in kind and centered at the crossing.

Orange County Fire Authority

54. The applicant shall comply with all applicable Orange County Fire Authority (OCFA) requirements, including but not limited to the Fire Master Plan.

Building and Safety Division

55. All work shall comply with the latest edition of the California (CA) Building Standards Code (CBC) at time of permit application.

56. A soils report per the latest edition of CBC Chapter 18 is required and shall be submitted at time of building permit application.

57. A fire sprinkler system shall be provided per the latest edition of CBC Chapter 9.

58. Fire and sound rated constructions shall be provided between the units and shall comply with the latest edition of CBC Chapter 7.

59. Common use areas shall comply with the latest edition of CBC Chapter 11A.

60. A minimum 10% of the total units shall comply with the latest edition of CBC Section 1102A.3.

61. Complete mechanical, plumbing and electrical plans shall be required.

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Site Plan No. SP-119-2022 and Tentative Tract Map No. 19129Conditions of Approval

62. HVAC systems shall be designed to comply with the latest edition of California Green Building Standards Code Section 4.507.

63. Each dwelling unit shall be equipped with a future ready EV charger.

64. Each dwelling shall be provided with a minimum 250 square foot solar ready zone.

65. All rooms and spaces on the primary level shall be on an accessible route.66. A path of travel to the trash enclosure shall be provided.

Planning Services Division67. The applicant shall submit detailed plans showing the proposed location of utilities and mechanical equipment to the Community and Economic Development Department, Planning Services Division for review and approval prior to submitting plans into the Building and Safety Division Plan Check process. The project shall also be subject to the following:

68. The applicant shall submit detailed plans showing the proposed location of utilities and mechanical equipment to the Community and Economic Development Department, Planning Services Division for review and approval prior to submitting plans into the Building and Safety Division Plan Checkprocess. The project shall also be subject to the following:
a. All on-site and off-site utilities (off-site refers to the areas within public right-of-way to the center line of the streets adjacent to the subject property) within the perimeter of the site and to the centerline of the adjacent streets shall be installed or relocated underground. All on-siteand off-site utilities pertaining to the improvements proposed under thisSite Plan shall be installed or relocated underground. b. All above-ground utility equipment (e.g. electrical, gas, telephone, cable TV) shall not be located in the street setback, within the common areas, or any parking areas, and shall be screened by densely planted and maintained landscaped hedges or a fence or wall. Ground-mounted equipment shall not exceed the maximum allowable height for a wall, fence, or hedge.
c. Clinging vines shall be installed within the landscape planters along the perimeter block walls to deter graffiti.
d. Roof-mounted mechanical equipment shall be screened by parapet walls, rooftop architectural features such as a tower equal to the heightof the equipment, or low walls surrounding the equipment and shall be painted to match the color of the building materials.

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Exhibit "A" Page 13
Site Plan No. SP-119-2022 and Tentative Tract Map No. 19129 Conditions of Approval
e. No exterior piping, plumbing, or mechanical ductwork shall be permitted on any exterior facade and/or be visible from any public right-of-way oradjoining property. Roof rain gutters are permitted. The rain guttersshall follow the natural architecture lines of the building.

69. All landscaping shall be consistent with the landscape requirements of Title 9 of the Municipal Code. The developer shall submit a complete landscape plan governing the entire development. The landscape irrigation plans shall include type, size, location and quantity of all plant material. The landscape plan shall include irrigation plans and staking and planting specifications. All landscapeirrigation shall comply with the City's Landscape Ordinance and associated Water Efficiency Guidelines. The landscape plan is also subject to thefollowing:
a. A complete, permanent, automatic remote control irrigation system shall be provided for all landscaping areas shown on the plan. Thesprinklers shall be of drip or micro-spray system sprinkler heads forwater conservation. b. Forty percent of the trees on a site shall consist of minimum size 24-inch box, and the remaining 60 percent shall be of minimum size 15 gallons.

These trees shall be incorporated into the landscaped frontages of all streets. Where clinging vines are considered for covering walls, Boston Ivy shall be used.
c. The applicant or the property owner shall be responsible for installing and maintaining the landscaping.
d. No trees shall be planted closer than five feet (5'-0") from any public right-of-way. Trees planted within ten feet (10'-0") of any public rightof-way shall be planted in a root barrier shield. All landscaping along street frontages adjacent to driveways shall be of the low-height variety to ensure safe sight clearance. All trees planted on the subject property, whether for screening the project from the neighboring lots or foraesthetic or selling/marketing purposes, shall have an irrigation system installed in order maintain the trees.
e. All trees shall be double-staked in accordance with City standards.f. Landscaping along Garden Grove Boulevard shall comply with the landscape requirements of the Garden Grove Mixed Use Zones. Off-sitelandscaping shall include planters with canopy trees spaced 30'-0" apart on center with an under planting of shrubs and flowering ground cover.

Plant materials within the public rights-of-ways shall be determined by the City's Public Work's Department. On-site landscaping shall include both columnar and canopy trees. Columnar trees (minimum height at maturity of 45"-0") shall be planted within lO'-O of the public FINAL
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Exhibit "A" Page 14
Site Plan No. SP-119-2022 and Tentative Tract Map No. 19129Conditions of Approval right-of-way and shall be placed at regular intervals and no more than 40'-0" on center. On-site canopy trees shall be planted at a ratio of at least one tree for every 50'-0" of the Garden Grove Boulevard street frontage. The on-site front yard landscape area shall also include shrubs and flowering ground covers. All on- and off-site canopy trees shall bea minimum size of 24-inch box. Columnar trees shall be a minimum of 25'-0" tall. Should palm trees be proposed, the brown trunk height of the palm trees shall be 25'-0".
g. All landscape areas, including the areas located within the public rights-of-ways along Garden Grove Boulevard that abuts the subjectproperty, are the responsibility of the applicant/property owner(s). h. Fifty percent (50%) of all required shrubs shall be a minimum size of five (5) gallons at time of planting.
j. Live groundcover shall be planted and maintained where shrubbery is not sufficient to cover exposed soil. Mulch may be used in place of groundcover where groundcover will not grow or where groundcover will cause harm to other plants, but not more than 30% of the groundcoverarea shall have the mulch substitute. j. Groundcover plants shall be planted at a density and spacing necessary for them to become well established and provide surface coverage within 18 months of planting.
k. The landscape plan shall incorporate and maintain for the life of the project those means and methods to address water run-off alsoidentified as Low Impact Development provisions, which address water run-off. This is to also to be inclusive of any application of Water QualityManagement Plans (WQMP), Drainage Area Management Plans (DAMP) and any other water conservation measures applicable to this type ofdevelopment.

I. At the time of irrigation installation, the irrigation system shall comply with all applicable provisions of the City's Water Conservation Ordinance, the City's Municipal Code landscape provisions, and allapplicable state regulations. m. All above-ground utilities (e.g. water backflow devices, electrical transformers, irrigation equipment) shall be shown on the landscaping plan in order to ensure landscape screening will be provided.

70. Hours and days of construction and grading shall be as set forth in the City of Garden Grove Municipal Code Chapter 8.47 as adopted, except that:

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Exhibit "A" Page 15
Site Plan No. SP-119-2022 and Tentative Tract Map No. 19129Conditions of Approval a. Monday through Friday - not before 7:00 a.m. and not after 5:00 p.m. b. Saturday - not before 8:00 a.m. and not after 5:00 p.m. All construction activity on Saturday shall be limited to interior construction only.
c. Sunday and Federal Holidays - no construction shall occur.

71. Construction activities shall adhere to SCAQMD Rule 403 (Fugitive Dust) that includes dust minimization measures, the use of electricity from power poles rather than diesel or gasoline powered generators, and the use methanol, natural gas, propane or butane vehicles instead of gasoline or diesel powered equipment, where feasible. Also, use of solar, low emission water heaters, and low sodium parking lot lights, shall be required to ensure compliance with Title 24.

72. The applicant shall prepare Covenants, Conditions, and Restrictions (CC&R's) for review and approval by the City Attorney's office and Community and Economic Development Department prior to final map approval. The approved CC&R's shall be recorded at the same time that the subdivision map is recordedand two copies (a hard copy and an electronic copy) of the recorded CC&R'sshall be provided to the Planning Division. The CC&R's shall include thefollowing stipulations and/or provisions:
a. Units 1-4, 7-14, and 17-20 shall maintain the ability to park three (3) vehicles at all times, or two (2) vehicles for Units 5, 6, 15 and 16.

Garages shall not be converted to any other use.
b. There shall be no business activities, day care, or garage sales conducted within or from the garages.
c. Parking spaces in the garages shall be made available to the occupants of the unit at all times.
d. Residents shall not park or store vehicles anywhere on the site except within the designated parking spaces in the garages for their dwelling unit. However, the six (6) unassigned open, guest parking spaces,located throughout the development, may be utilized by residents or guests for temporary parking. Any issues arising from the use,application, or restriction of such open parking spaces shall be at the resolve of the Homeowner's Association.
e. All graffiti vandalism shall be abated within the premises. Best management practices shall be implemented to prevent and abate graffiti vandalism within the premises throughout the life of the project,including, but not limited to, timely removal of all graffiti, the use ofgraffiti resistant coatings and surfaces, the installation of vegetation FINAL
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Exhibit "A" Page 16
Site Plan No. SP-119-2022 and Tentative Tract Map No. 19129 Conditions of Approval
screening of frequent graffiti sites, and the installation of signage, lighting, and/or security cameras, an necessary. Graffiti shall be removed/eliminated as soon as reasonably possible after it is discovered, but not later than 72 hours after discovery. f. Each residence shall be utilized as one (1) dwelling unit. No portion of any residence shall be utilized or rented as a separate dwelling unit. g. The CC&R's shall include provisions providing the owners or tenants a means of contacting persons responsible for site maintenance, repairs, trash pick-up, and other related matters for a development of this type.

This shall also include scheduling of maintenance of such items as the recreation area, landscape area maintenance, etc. This also includes ensuring tree overhangs do not block or hinder any vehicles such asstreet sweepers, trash trucks, fire trucks, etc., from maneuvering around the cul-de-sac.
h. Storage of boats, recreational vehicles, or commercial vehicles on the property is prohibited.
i. The CC&R's shall include stipulations that maintenance of the private drive aisles, storm drain, sewer system, open space areas within the interior of the development, and the common landscaped areas, are theresponsibility of the Homeowner's Association. j. Each unit shall have a minimum of 300 cubic feet of storage space, which may be provided in the garage parking areas, and typical closetspace within the unit shall not count toward this requirement. k. The Standards of Development and Conditions of Approval for Site Plan No. SP-119-2022 and Tentative Tract Map No. TT-19129, shall be incorporated into the CC&Rs, and provisions corresponding to any applicable Conditions of Approval shall be included in the CC&Rs.

I. The following provisions shall be included within the CC&R's (in substantially the same form as below or as otherwise approved by the City Attorney):
i. Compliance with Stormwater Quality Regulations: The
Homeowner's Association shall implement, and fund
implementation of, the Operation and Maintenance ("O&M") Plan for the Property, which was approved by the City as part of the Water Quality Management Plan ("WQMP") required fordevelopment of the Property, and shall operate and maintain the Best Management Practices ("BMPs") described in the O&M Plan for the Property, which includes:

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Exhibit "A" Page 17
Site Plan No. SP-119-2022 and Tentative Tract Map No. 19129Conditions of Approval

1. Description of all post-construction BMPs (non-structural and structural),

2. Description of the Property owner's(s') responsibilities and required training of persons performing BMPimplementation, operation and maintenance,

3. Implementation frequency and operating schedule,

4. Inspection/majntenance frequency and schedule,

5. Specific maintenance activities,

6. Required permits from resource agencies, if any,

7. Forms to be used in documenting implementation,
operation and maintenance activities,

8. Recordkeeping requirements.

A copy of the approved O&M Plan is described in the current WQMP forthe Project, as it may be amended from time to time according to its terms, which is on file with the City of Garden Grove Community and Economic Development Department, and is incorporated herein by this reference. The Committee shall maintain a copy of the current WQMP at a location on the Property.

The Property shall be, and the Homeowner's Association shall ensure, that the Property is used and maintained in full compliance with the provisions of the O&M Plan and Chapter 6.40 (Stormwater Quality) of the Garden Grove Municipal Code, as it may be amended. The City shall have the right to inspect the Property for the purpose of verifying compliance with this provision. The City of Garden Grove shall be an intended third-party beneficiary to this provision. The City shall have the right and authority, but not the obligation, to enforce this provision by any legal or equitable means, or by any method available to the Property owners as provided elsewhere in the Declaration, against the Declarant, Homeowner's Association, Owners, their successors and assigns, or other persons in possession of the Property. This provisionshall not be amended or terminated without the written approval of the City of Garden Grove Community and Economic Development Department.
ii. Enforcement: The City is hereby made a party to this Declaration solely for purposes of enforcing its provisions and the Standards of Development and Conditions of Approval of Site Plan
No. SP-119-2022 and Tentative Tract Map No. TT-19129. The FINAL
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Exhibit "A" Page 18
Site Plan No. SP-119-2022 and Tentative Tract Map No. 19129Conditions of Approval City, its agents, departments and employees shall have the unrestricted right and authority, but not the obligation, to enforce the provisions of this Declaration and the Standards of Development and Conditions of Approval of Site PlanNo. SP-119-2022 and Tentative Tract Map No. TT-19129. In the enforcement of this Declaration, the City shall not be limited to the procedures or processes described in this Declaration and may use any remedy provided under law or equity, including the City's Municipal Code. The City, its agents, departments andemployees may further refuse to issue any building, electrical or plumbing permit that may be in violation of these Declarations or Site Plan No. SP-119-2022 and Tentative Tract Map No. TT-19129 approvals. However, the City shall not be liable for failing or refusing to enforce the provisions of these Declarations or the Standards of Development and Conditions of Approval of Site Plan No. SP-119-2022 and Tentative Tract Map No. TT-19129. The alternative dispute resolution provisions set forth in Section / Article [SECTION] of this Declaration shall not apply to or legally bind the City.
iii. Assessments: The City may levy special assessments against the properties in connection with its actions to enforce the conditions of this Declaration or Site Plan No. SP-119-2022 and Tentative Tract Map No. TT-19129 approvals, or to abate the violation thereof. The City shall have the same power as the Association to levy special assessments pursuant to the provisions of [SECTION] of this Declaration in the event that it incurs expenses in the enforcement of the conditions of these Declarations or Site Plan No. SP-119-2022 and Tentative Tract Map No. TT-19129 approvals. Notice of intention to make such assessment shall be mailed by the City to the Owner of each affected [LOT/UNIT] affording the Owner thirty (30) days' notice to satisfy or reimburse the City's expenditure. In the event of the failure of any Owner of any affected [LOT/UNIT] to reimburse the Citywithin thirty (30) days, notice of such assessment shall be mailed by the City to said Owner, and said assessment shall thereafterbe due as a separate debt to the City within thirty (30) days following the mailing of such notice. Any such delinquentassessment may be and may become a lien upon the interest of the defaulting Owner in the Lot upon the execution by the City and the recording in the Orange County Recorder's office of a notice of delinquent assessment under the same conditions that the Association could record the same pursuant to the provisions of [SECTION]. The City may foreclose on such notice ofdelinquent assessment in the same manner and with the same power as the Association could foreclose on such notice pursuant to the provisions of [SECTION]. It is the intent of Declarant, FINAL
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Exhibit "A" Page 19
Site Plan No. SP-119-2022 and Tentative Tract Map No. 19129Conditions of Approval which intent shall be binding upon all of Declarant's successors in interest in the Properties, that the City shall be deemed an interest holder pursuant to the provisions of these Declarations in order to enforce the rights which have been given to the City generally in these Declarations and specifically pursuant to thisSection. iv. Attorney Fees: The City shall be entitled to recover its attorney's fees incurred in connection with its actions to enforce the conditions of these Declarations or Site Plan No. SP-119-2022and Tentative Tract Map No. TT-19129 approvals, or to abate theviolation thereof. v. Public Safety Access: The Police and Orange County Fire Authority personnel may enter upon any part of the common area for thepurpose of enforcing State and Local laws. vi. Mod\f\cat\on/Jerrn\r\at{or\'. This Declaration shall not be terminated or substantially amended without the prior written approval of the City of Garden Grove Community and Economic Development Department.

73. All lighting structures shall be placed so as to confine direct rays to the subject property. All exterior lights shall be reviewed and approved by the Planning Services Division. Lighting adjacent to residential properties shall be restricted to low decorative type wall-mounted lights, or a ground lighting system.

Lighting shall be provided throughout all private drive aisles and entrances to the development per City standards for street lighting. Lighting in the common areas shall be directed, positioned, or shielded in such manner so as not to unreasonably illuminate the window area of nearby residences.

74. Per the approved site plan, Units 1-4, 7-14, and 17-20 shall maintain the ability to park three (3) vehicles at all times, or two (2) vehicles for Units 5, 6, 15 and 16. Unless otherwise required to be permitted by state law, garages shall not be converted to any other use. There shall be no business activities, day care, or garage sales conducted within or from the garages. Parking spaces in the garages shall be made available to the occupants of the unit at all times.

The applicant/property owner shall ensure that this condition is complied with at all times by tenants of the units and shall include notice of this requirement in all lease agreements.

75. The main drive aisle serves the entire project for vehicular circulation. The applicant shall utilize effective signage, and/or other acceptable means (i.e., a painted/marked red fire lane), to communicate to residents and guests that there shall be no parking in front of garages or anywhere within the drive aisle, except for within the designated guest parking spaces. Additionally, applicant shall ensure and enforce lease or other restrictions providing that there will be FINAL
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Exhibit "A" Page 20
Site Plan No. SP-119-2022 and Tentative Tract Map No. 19129Conditions of Approval no long term parking of vehicles in the guest parking spaces and that guest parking spaces shall not be reserved for any particular units.

76. The applicant/property owner shall abate all graffiti vandalism within the premises. The property owner shall implement best management practices toprevent and abate graffiti vandalism within the premises throughout the life of the project, including, but not limited to, timely removal of all graffiti, the use of graffiti resistant coatings and surfaces, the installation of vegetationscreening of frequent graffiti sites, and the installation of signage, lighting, and/or security cameras, as necessary. Graffiti shall be removed/eliminated by the property owner as soon as reasonably possible after it is discovered, but not later than 72 hours after discovery.

77. The trash enclosure shall have unifying colors and exterior finishes that match, the development. The proposed roof design of the trash enclosure shall be architecturally compatible with the design of the existing development. The proposed roof and materials shall also comply with the building coderequirements.

78. Each unit shall have a separate area for storage having a minimum of three hundred (300) cubic feet of private and secure space. This storage may belocated within the enclosed garages, provided that it does not interfere with automobile parking.

79. Decorative stamped concrete or pavers shall be provided within the front 20-feet for the driveway along Garden Grove Boulevard. The final design and configuration shall be shown on the final site plan, grading plan, and landscape plans.

80. Storage of boats, recreational vehicles, or commercial vehicles on the property shall be prohibited. The applicant/property owner shall ensure that thiscondition is complied with at all times by tenants of the units and shall include notice of this requirement in all lease agreements.

81. All new block walls, and/or retaining wall(s), including existing block walls to remain, if any, shall be shown on the grading plans. Block walls shall be developed to City Standards or designed by a Registered Engineer and shall be measured from on-site finished grade. The applicant shall provide the following:
a. Decorative masonry walls are required along the south, east, and west property lines and shall be constructed to a minimum height of 6'-0", as measured from highest point of finished grade. The block walls shall be decorative and utilize stucco finish, slump stone or split-face block, andshall include trailing vines, hedges planted along the base of the exterior face, or other landscaping treatments that deter graffiti.

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Exhibit "A" Page 21
Site Plan No. SP-119-2022 and Tentative Tract Map No. 19129Conditions of Approval b. The applicant shall work with the existing property owners along the project perimeter in designing, constructing, and maintaining therequired perimeter block walls. This requirement is to avoid having double walls and to minimize any impact that it might cause to theexisting landscaping on the neighbor's side as much as possible. The perimeter block wall shall be constructed and situated entirely within the subject property. In the event that the applicant cannot obtain approval from the property owners, the applicant shall construct the new wall with a decorative cap to be placed between the new and existing walls. In the event the location of a new wall adjacent to anexisting wall or fence has the potential to affect the landscape planter, then the applicant shall work with City Staff to address this situation.The Community and Economic Development Director shall be authorized to approve minor alterations the size and/or location of the landscape planter to accommodate the placement of such wall.

82. All recreation areas, landscaping along the interior project street and entryway, landscaped areas in all common areas, and any landscaping within the public right-of-way shall be maintained for the life of the project and such maintenance provisions shall be included in the CC&R's.

83. Both common recreation areas, as identified on the approved site plan, shall be equipped with outdoor furniture and table tennis equipment, subject toreview by the Planning Services Division, and Building and Safety Division.

84. During construction, if paleontological or archaeological resources are found, all attempts will be made to preserve in place or leave in an undisturbed statein compliance with applicable law. In the event that fossil specimens or cultural resources are encountered on the site during construction and cannot bepreserved in place, the applicant shall contact and retain, at applicant's expense, a qualified paleontologist or archaeologist, as applicable, acceptable to the City to evaluate and determine appropriate treatment for the specimen or resource, and work in the vicinity of the discovery shall halt until appropriateassessment and treatment of the specimen or resource is determined by the paleontologist or archeologist (work can continue elsewhere on the project site). Any mitigation, monitoring, collection, and specimen/resource treatment measures recommended by the paleontologist/archaeologist shall be implemented by the applicant at its own cost.

85. The applicant shall comply with the Migratory Bird Treaty Act (MBTA), and Sections 3503, 3503.5 and 3515 of the California Fish and Game regulations, which require the protection of active nests of all bird species, prior to the removal of any on-site landscaping, including the removal of existing trees.

86. The proposed development will consist of the construction of twenty (20) townhome units, and one (1) unit shall be reserved for very low-income households.

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Exhibit "A" Page 22
Site Plan No. SP-119-2022 and Tentative Tract Map No. 19129Conditions of Approval87. The vehicular gate at the alley shall be of automatic type.

88. There shall be no parking allowed along any drive-aisle, except within the designated parking areas. All curbs not designated as parking areas shall be painted red. The applicant shall post "No Parking" signs along the drive aisle.

89. Each residence shall be utilized as one (1) dwelling unit. No portion of any residence shall be utilized or rented as a separate dwelling unit.

90. All balconies shall remain open and shall not be enclosed at any time. There shall be no storage allowed in the balconies at any time.

91. The maintenance of the drive aisles, storm drains, sewer system, and open space areas is the responsibility of the applicant and property owner, including the common recreation areas, and the common landscape areas.

92. Each unit shall be provided with an air conditioning condensing unit and/or system so that there are no wall-mounted, or window mounted units. If units are located on the roof, an architectural design of the roof areas shall be done to effectively screen such units from adjacent properties and the public right-of-way.

93. Mailboxes shall be provided and installed by the applicant. The local postmaster shall approve the design and location.

94. Each unit shall be provided with washer and dryer hook-ups.95. At applicant's request, applicant has been granted State Density Bonus allowances for parking, one (1) concession, and one (1) waiver in exchange for the applicant's agreement to reserve one (1) dwelling unit in the project for occupancy by very low-income households for a period of 45 years commencing with the issuance of the certificate of occupancy for the project.

The applicant shall at all times during the term of the affordability period comply with the requirement to sell the target unit to very low-income households at an affordable price as required by the Garden Grove Municipal Code and State Law. Pursuant to State law, the Garden Grove Municipal Code, and the City's Density Bonus Agreement Guidelines, the record owner orowners of the subject property shall enter into an affordable housing regulatory agreement with the City pursuant to Garden Grove Municipal Code Section9.60.050, which satisfies the criteria set forth in subdivision (c) of GovernmentCode Section 65915. The regulatory agreement shall be prepared by the Cityat the applicant/owner's expense, and the applicant and/or owner shall payapplicable fees pursuant to GGMC Section 9.60.050.G and reimburse the City for the actual fees and costs charged for the services of attorneys and/or other professional thjrd-party consultants engaged by the City for the purposes set forth in GGMC Section 9.60.050.F. Prior to preparation of the regulatory agreement, applicant and/or property owner shall execute a reimbursement FINAL
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Exhibit "A" Page 23
Site Plan No. SP-119-2022 and Tentative Tract Map No. 19129Conditions of Approval agreement with the City, in a form approved by the City Attorney, and providea deposit to the City in an amount sufficient to cover the estimated professional fees and costs to be incurred by the City, as determined by the Department Director, in his or her reasonable discretion. The regulatory agreement shallbe approved by the City and recorded prior to final map approval. The regulatory agreement shall remain a senior, non-subordinate covenant and as an encumbrance running with the land for the full term thereof. In no event shall the regulatory agreement be made junior or subordinate to any deed of trust or other documents providing financing for the construction or operation of the project, or any other lien or encumbrance whatsoever for the entire termof the required covenants.

96. Final Tentative Tract Map No. TT-19129 shall be approved by the City and recorded by the applicant prior to issuance of building permits for the proposed development.

97. A copy of the resolution approving Site Plan No. SP-119-2022 and Tentative Tract Map No. TT-19129, including these Conditions of Approval, shall be kept on the premises at all times.

98. The applicant shall submit a signed letter acknowledging receipt of the decision approving Site Plan No. SP-119-2022 and Tentative Tract Map No. TT-19129and his/her agreement with all conditions of the approval.

99. The applicant shall, as a condition of Project approval, at its sole expense, defend, indemnify and hold harmless the City, its officers, employees, agentsand consultants from any claim, action, or proceeding against the City, itsofficers, agents, employees and/or consultants, which action seeks to setaside, void, annul or otherwise challenge any approval by the City Council, Planning Commission, or other City decision-making body, or City staff action concerning Site Plan No. SP-119-2022 and Tentative Tract Map No. TT-19129.

The applicant shall pay the City's defense costs, including attorney fees and all other litigation related expenses, and shall reimburse the City for court costs,which the City may be required to pay as a result of such defense. The applicant shall further pay any adverse financial award, which may issueagainst the City including but not limited to any award of attorney fees to a party challenging such project approval. The City shall retain the right to selectits counsel of choice in any action referred to herein. 100. In accordance with Garden Grove Municipal Code Sections 9.32.160 and

9.40.070.A, respectively, the rights granted pursuant to Site Plan No.

SP-119-2022 and Tentative Tract Map No. TT-19129 shall be valid for a periodof two years from the effective date of this approval. Unless a time extensionis granted pursuant to Section 9.32.030.D.9 of the Municipal Code, the rightsconferred by Site Plan No. SP-119-2022 and Tentative Tract Map No. TT-19129 shall become null and void if the subject development and construction necessary and incidental thereto is not commenced within two (2) years of the FINAL
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Exhibit "A" Page 24
Site Plan No. SP-119-2022 and Tentative Tract Map No. 19129 Conditions of Approval
expiration of the appeal period and thereafter diligently advanced until completion of the project. In the event construction of the project iscommenced but not diligently advanced until completion, the rights granted pursuant to Site Plan No. SP-119-2022 and Tentative Tract Map No. TT-19129 shall expire if the building permits for the project expire. 101. Consistent with Sight Distance Standards in accordance with City's Traffic Engineering Policy TE-13, IQ'-O" of wrought iron fencing shall be provided at each side of the vehicular gate to provide clear and unobstructed visibility of the alley. The wrought iron fencing shall not be improved with any clinging vines or materials that limit visibility to the alley from motorists.
102. A speed hump shall be installed between the ground sensor and vehicular gate. The speed hump shall not encroach into any portions of the public alley.

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Item 211/2026
Final
City of Garden Grove

INTER-DEPARTMENT MEMORANDUM
To: Lisa L. Kim From: Samuel Kim
Dept: City Manager Dept: Public Works
Date: 6/9/2026
Subject: Approval of the exoneration of the Improvement Bonds for Tract Map No. 19273 for the property located at 13252 Brookhurst Street, Garden Grove. (Action Item)

OBJECTIVE
To request City Council approval to exonerate the improvement bonds for Tract Map No. 19273, located at 13252 Brookhurst Street, Garden Grove (Southeast corner of Brookhurst Street and Central Avenue).

BACKGROUND
The subject subdivision was approved by City Council on June 11, 2024, and it comprises 30-unit townhomes on Brookhurst Street. Easements for a public utility, vehicle access, domestic water, and appurtenances have been dedicated.

DISCUSSION
The Subdivision Improvement Agreement requires the posting of improvement bonds to ensure completion of the improvement of street, sewer, water, drainage, and related onsite improvements for the subject development. With the work completed, the following improvement bonds are ready for exoneration:

Public Improvement Amount
Faithful Performance $912,086.00
Labor and Material $456,043.00
Monument $5,000

FINANCIAL IMPACT
There is no financial impact to exonerate the improvement bonds for Tract Map No. 19273, located at 13252 Brookhurst Street, Garden Grove (Southeast corner of Brookhurst Street and Central Avenue).
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Item 211/2026

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RECOMMENDATION
It is recommended that the City Council:
 Approve the exoneration of the improvement bonds listed above for Tract Map No. 19273, located at 13252 Brookhurst Street, Garden Grove (Southeast corner of Brookhurst Street and Central Avenue).

By: Kamyar Dibaj, MS
Project Engineer
255
Item 199/2026
Final
City of Garden Grove

INTER-DEPARTMENT MEMORANDUM
To: Lisa L. Kim From: Ursula Luna-Reynosa
Dept: City Manager Dept: Economic Development and
Housing
Date: 6/9/2026
Subject: Approval of the Second Amendment to the Lease Agreements with Orange County Asian and Pacific Islander Community Alliance, Inc., for office space located at 12966 Euclid Street, Garden Grove. (Action Item)

OBJECTIVE
For the City Council to consider the Second Amendment to the lease agreements between Orange County Asian and Pacific Islander Community Alliance, Inc. and the City of Garden Grove for the lease of office space in the Garden Office Plaza located at 12966 Euclid Street, Garden Grove.

BACKGROUND
On November 30, 2023, the City acquired the office building and surface parking lot located at 12966 Euclid Street (the “Property”) from LT Properties Company (the “Previous Owner”).

The Property is improved with a five-story office building containing 64,402 rentable square feet. The office building was constructed in 1985, and at the time of acquisition, the building was configured with 25 tenant suites, of which 8 were unoccupied, resulting in a vacancy rate of 32%. Since acquisition, the City, as successor in interest to the Previous Owner (the “Lessor”), has renewed certain leases and secured new tenants to occupy the Property. The current vacancy rate is 19% (see Attachment 1).

Orange County Asian and Pacific Islander Community Alliance, Inc. (the “Lessee”) entered into a lease agreement with the Previous Owner on June 7, 2023 (the “Suite 495 Agreement”) to lease Suite 495, consisting of approximately 7,859 rentable square feet. The Lessee entered into another lease agreement with the Previous Owner on September 28, 2023 (the “Suite 425 Agreement”) to lease Suite 425, consisting of approximately 1,905 rentable square feet. As part of the Suite 425 Agreement, the demising wall between Suites 425 and 495 was removed, combining the suites into one connected office space totaling approximately 9,764 rentable square feet. Amendments to both lease agreements were executed on October 21, 2024, aligning the expiration dates for Suites 425 and 495 to June 30, 2026 (collectively, the “First Amendment”). The Lessee is currently the second-largest tenant in the building, occupying approximately 15 percent of the Property.
256
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DISCUSSION
The Lessee desires to enter into additional amendments to extend the lease terms for Suites 425 and 495 by twelve (12) months beyond the current expiration date of June 30, 2026, resulting in a new expiration date of June 30, 2027 (collectively, the “Second Amendment”).

According to the City’s retained leasing agent, the proposed rental rates are consistent with current market rates. The Lessee will renew the leases in an as-is condition, with no Lessor or tenant improvement allowance provided.

Lease Amendment Details
 Premises: Suite Nos. 425 and 495, 12966 Euclid Street, Garden Grove, CA 92840.  Lease Term: Twelve (12) months, commencing on July 1, 2026, and expiring on June 30, 2027.
 Suite 495 Base Rent: $16,661.08 per month.
 Suite 425 Base Rent: $4,038.60 per month.
 Brokerage: CBRE (the City’s leasing agent) commission is $14,903.77.

FINANCIAL IMPACT
The City will receive monthly lease revenue of $20,699.68 through June 30, 2027. The Lessee’s annual proportionate share of the building’s operating expenses will be 15 percent.

RECOMMENDATION
It is recommended that the City Council:
 Approve the Second Amendment to the lease agreements with Orange County Asian and Pacific Islander Community Alliance, Inc. (Lessee), for office space located at 12966 Euclid Street, Garden Grove; and
 Authorize the City Manager, or designee, to execute the Second Amendment, including any minor modifications or amendments as appropriate, and any other pertinent documents necessary to effectuate and/or implement the Second Amendment on behalf of the City.

By: Henry Surjono, Administrative Analyst

ATTACHMENT(S)

1. Leasing Chart

2. Second Amendment to the Agreement for Suite 495

3. Second Amendment to the Agreement for Suite 425
257
Prepared by:

Peter Wells 714.371.9220 [email protected]
Taylor Friend 714.371.9241 [email protected]
Garden Grove Plaza
Stacking Plan – March 2026
12966 Euclid Street
Garden Grove, CA
VACANT
Suite 500
Lease 3,337 SF
CA Medical
Evaluators
Suite 508
Lease 1,888 SF
Exp: 2/26/26
Start: 1/1/22
Golden Era
Promotions/Babylon
Suite 550
Lease 1,712 SF
Exp: 6/30/27
Start: 5/1/25
VACANT
Suite 530
Lease 803 SF
Tony H. Vu
Suite 520
Lease 1,615 SF
Exp: 11/30/26
Start: 9/1/23
VACANT
Suite 510
BOMA 1,550 SF
VACANT
Suite 525
BOMA 554 SF
EasyFlex
Suite 515
Lease 2,371 SF
Exp: 11/30/29
Start: 12/1/24
13,830 SF
Law Offices of Choi & Choi
Suite 400
Lease 2,008 SF
Exp: 5/31/27
Start: 4/1/12
VACANT
Suite 450
BOMA 920 SF
T&T Group
Suite 445
Lease 580 SF
Exp: 11/30/26
Start: 10/1/23
Orange County Asian Pacific Islander Community Alliance, Inc. (OCAPICA) Suite 495
Lease 7,859 SF
Exp. 8/31/26
Start: 7/1/23

OCAPICA
Suite 425
Lease 1,905 SF
Exp: 8/31/26
Start: 10/16/23
13,272 SF
Investel Resorts Management, LLC
Suite 300/320
Lease 13,272 SF
Exp: 1/31/2029
Start: 6/1/17
13,272 SF
Paul Joo
Suite 210 (250
E&F)
Lease 1,820 SF
Exp: 4/30/28
Start: 12/01/12
Mgmt.
250C
326 SF
James Nguyen
250D
Lease 203 SF
Exp: MTM
Start: 4/1/18
Kitchen
CC
73 SF
Hung Nguyen
250A/B
Lease 700 SF
Exp: MTM
Start: 1/1/15
Western
International
Real Estate
Suite 270
Lease 761 SF
Exp: MTM
Start: 4/1/17
Andrew Pham
and Toan Tran
Suite 275
Lease 702 SF
Exp: MTM
Start: 4/1/14
Investel Resorts
Suite 240
Lease 1,074 SF
Exp: 1/31/2029
Start: 12/1/25
Pathways Community
Services, LLC
Suite 220
Lease 2,742 SF
Exp: 6/30/28
Start: 7/1/213
Pathways Community
Services LLC
Suite 200/280
Lease 3,930 SF
Exp: 6/30/28
Start: 7/1/23
12,331 SF
VACANT
Suite 100
BOMA 3,291 SF
Lucky Team
Escrow, Inc.

Suite 110
Lease 1,035 SF
Exp: 4/30/28
Start: 1/3/25
VACANT
Suite 130
BOMA 2,041 SF
Farmers & Merchants Bank of Long Beach
Suite 150
Lease 5,332 SF
Exp: 6/1/36
Start: 6/1/25
11,699 SF
Total Rentable Square Footage (“RSF”) per Stevenson Systems report dated 10/02/2019 – 64,404 RSF Vacant 19% (12,496 sf)
MTM 3.7% (2,366 sf)
2026 21.5% (13,847 sf)
2027 5.8% (3,720 sf)
2028 14.8% (9,527 sf)
2029 26% (16,717 sf)
2036 8.3% (5,332 sf)
Bldg Mgmt 0.6% (399 sf)
258
THIS AMENDMENT TO LEASE is made and entered into as of April 10, 2026 , by and between The City of Garden Grove ("Lessor") and Orange County Asian and Pacific Islander Community Alliance (OCAPICA) ("Lessee").

WHEREAS, on or about September 28, 2023 a Lease was entered into by and between Lessor and Lessee relaƟng to certain real property commonly known as (street address, city, state, zip): 12966 Euclid Street, Suite 495, Garden Grove, CA 92840 (the "Premises"), and
WHEREAS, Lessor and Lessee have have not previously amended said Lease, and WHEREAS, the Lessor and Lessee now desire to amend said Lease, NOW, THEREFORE, for payment of TEN DOLLARS and other good and valuable consideraƟon to Lessor, the receipt and sufficiency of which is hereby acknowledged, the parƟes mutually agree to make the following addiƟons and modificaƟons to the Lease:

TERM: The ExpiraƟon Date is hereby advanced extended to June 30, 2027 .

AGREED USE: The Agreed Use is hereby modified to: .

BASE RENT ADJUSTMENT: Monthly Base Rent shall be asfollows: July 1, 2026-June 30, 2027: $16,661.08 .

OTHER: Condition of Premises: Lessee shall accept the space in "As-Is" condition. Any necessary repairs, improvements, or maintenance required to be performed by the Lessor will be addressed prior to the commencement of the renewed lease term as outlined in the original Lease Agreement or as mutually agreed upon.

Taxes: Lessor is a municipality exempt from property taxation. However, Revenue and Taxation Code 107 and 107.6 create a possessory tax assessed upon tenants based on the leasehold interest in Lessor’s property. Lessor will endeavor to have all tax bills delivered to Lessor and Lessor will pay tax bills assessed upon Tenant’s leasehold interest. In the event that the County Assessor delivers the tax bill to Tenant, Tenant agrees to remit the tax bill to Lessor for payment. .

This Amendment shall not be construed against the party preparing it, but shall be construed as if all parƟes jointly prepared this Amendment and any uncertainty and ambiguity shall not be interpreted against any one party. Signatures to this Amendment accomplished by means of electronic signature or similar technology shall be legal and binding.

All other terms and condiƟons of this Lease shall remain unchanged and shall conƟnue in full force and effect except as specifically amended herein.

EXECUTED as of the day and year first above wriƩen.

By Lessor:

The City of Garden Grove
By:

Name Printed:

Title:

Phone:

Fax:

Email:

By:
2nd AMENDMENT TO LEASE
By Lessee:

Orange County Asian and Pacific Islander
Community Alliance (OCAPICA)
By:

Name Printed:

Title:

Phone:

Fax:

Email:

By:

Name Printed:

Title:

Phone:

Fax:

Email:

INITIALS INITIALS
© 2017 AIR CRE. All Rights Reserved.

ATL-1.02, Revised 10-22-2020
Last Edited: 4/10/2026 3:08 PM

Page 1 of 2 ends

Mary Anne Foo
259
Name Printed:

Title:

Phone:

Fax:

Email:

Address:

Federal ID No.:

Address:

Federal ID No.:

AIR CRE * hƩps://www.aircre.com * 213-687-8777 * [email protected] NOTICE: No part of these works may be reproduced in any form without permission in wriƟng.

INITIALS INITIALS
© 2017 AIR CRE. All Rights Reserved.

ATL-1.02, Revised 10-22-2020
Last Edited: 4/10/2026 3:08 PM

Page 2 of 2 ends

260
THIS AMENDMENT TO LEASE is made and entered into as of April 10, 2026 , by and between The City of Garden Grove ("Lessor") and Orange County Asian and Pacific Islander Community Alliance (OCAPICA) ("Lessee").

WHEREAS, on or about September 28, 2023 a Lease was entered into by and between Lessor and Lessee relaƟng to certain real property commonly known as (street address, city, state, zip): 12966 Euclid Street, Suite 425, Garden Grove, CA 92840 (the "Premises"), and
WHEREAS, Lessor and Lessee have have not previously amended said Lease, and WHEREAS, the Lessor and Lessee now desire to amend said Lease, NOW, THEREFORE, for payment of TEN DOLLARS and other good and valuable consideraƟon to Lessor, the receipt and sufficiency of which is hereby acknowledged, the parƟes mutually agree to make the following addiƟons and modificaƟons to the Lease:

TERM: The ExpiraƟon Date is hereby advanced extended to June 30, 2027 .

AGREED USE: The Agreed Use is hereby modified to: .

BASE RENT ADJUSTMENT: Monthly Base Rent shall be asfollows: July 1, 2026-June 30, 2027: $4,038.60 .

All other terms and condiƟons of this Lease shall remain unchanged and shall conƟnue in full force and effect except as specifically amended herein.

EXECUTED as of the day and year first above wriƩen.

By Lessor:

The City of Garden Grove
By:

Name Printed:

Title:

Phone:

Fax:

Email:

By:
2nd AMENDMENT TO LEASE
By Lessee:

Orange County Asian and Pacific Islander
Community Alliance (OCAPICA)
By:

Name Printed:

Title:

Phone:

Fax:

Email:

By:

Name Printed:

Title:

Phone:

Fax:

Email:

INITIALS INITIALS
© 2017 AIR CRE. All Rights Reserved.

ATL-1.02, Revised 10-22-2020
Last Edited: 4/10/2026 3:04 PM

Page 1 of 2 ends

Mary Anne Foo
261
Name Printed:

Title:

Phone:

Fax:

Email:

Address:

Federal ID No.:

Address:

Federal ID No.:

AIR CRE * hƩps://www.aircre.com * 213-687-8777 * [email protected] NOTICE: No part of these works may be reproduced in any form without permission in wriƟng.

INITIALS INITIALS
© 2017 AIR CRE. All Rights Reserved.

ATL-1.02, Revised 10-22-2020
Last Edited: 4/10/2026 3:04 PM

Page 2 of 2 ends

262
Item 229/2026
Final
City of Garden Grove

INTER-DEPARTMENT MEMORANDUM
To: Lisa L. Kim From: John Montanchez
Dept: City Manager Dept: Community Services
Date: 6/9/2026
Subject: Approval of Amendment No. 2 to the Agreement with OCY Management, LLC for transportation services for the Senior Mobility Program at the H. Louis Lake Senior Center. (Action Item)

OBJECTIVE
To request City Council approval of Amendment No. 2 to the Agreement with OCY Management, LLC, for transportation services for the H. Louis Lake Senior Center Senior Mobility Program (SMP).

BACKGROUND
In June 2024, City Council approved a two-year Agreement with Cabco Yellow, Inc., dba California Yellow, to provide transportation services for the SMP at the H. Louis Lake Senior Center. The transportation services were split funded through the Orange County Transportation Authority (OCTA), Meals on Wheels OC (MoWOC), and the City of Garden Grove for two twelve-month periods beginning July 1, 2024, and ending June 30, 2026. The Agreement provided the City the option to extend the agreement for an additional three years, one year at a time. Amendment No. 1 was executed on May 29, 2025 to reassign the agreement from Cabco Yellow Inc, dba California Yellow, to OCY Management, LLC.

The current agreement will expire on June 30, 2026, which needs to be extended for the first option year, and amended to increase the total compensation amount for the current year and subsequent annual extensions.

DISCUSSION
Staff is requesting that City Council approve Amendment No. 2 to the Agreement, which will extend the term of the agreement for the first option year, beginning July 1, 2026 through June 30, 2027, and increase the total compensation amount for both the current agreement expiring on June 30, 2026 and for the remaining option years, from $240,000 to $293,000, an increase of $53,000.
263
Item 229/2026

Page 2 of 2 ends

FINANCIAL IMPACT
Funding for the City’s SMP will continue to be split funded by the City, OCTA and MoWOC.

OCTA will provide funding through June 2027. The annual grant allocation for Fiscal Year 2026/27 is $278,000, based on available M2 tax funds allocated for this program. MoWOC will provide annual grant funding in the amount of $15,000. The total available funding for the City’s SMP for Fiscal Year 2026-27 and remaining fiscal years is $293,000. The City is required to provide a twenty (20) percent match of the grant amount as part of the agreement with OCTA, which is an estimated total amount of $55,600 for Fiscal Year 2026-27 that can be an in-kind or financial match. The City’s match will consist of in-kind staff services for the coordination and management of the City’s SMP, and is currently budgeted in the General Fund. There will be no additional appropriation necessary to approve Amendment No. 2 to the Agreement with OCY Management, LLC, for transportation services for the H. Louis Lake Senior Center Senior Mobility Program.

RECOMMENDATION
It is recommended that the City Council:
 Approve Amendment No. 2 to the Agreement with OCY Management, LLC, to:
1) Increase the current compensation amount of the contract, which expires on June 30, 2026, to $293,000, an increase of $53,000, and 2) Exercise the first option year of the contract, for the term of July 1, 2026 through June 30, 2027, and increase the compensation amount to $293,000 annually, an increase of $53,000, for transportation services for the City's Senior Mobility Program at the H. Louis Lake Senior Center; and
 Authorize the City Manager, or designee, to execute Amendment No. 2 on behalf of the City, including making minor modifications as appropriate and necessary; and
 Authorize the City Manager, or designee, to exercise and execute remaining option years on behalf of the City, including making minor modifications as appropriate and necessary thereto.

By: Janet Pelayo, Deputy Director

ATTACHMENT(S)

1. Amendment No. 2 Agreement with OCY Management LLC
264
265
266
Item 244/2026
Final
City of Garden Grove

INTER-DEPARTMENT MEMORANDUM
To: Lisa L. Kim From: Patricia Song
Dept: City Manager Dept: Finance
Date: 6/9/2026
Subject: Approval of Writing Off Certain Delinquent Obligations Owed to the City as Uncollectible Debt. (Action Item)

OBJECTIVE
To request City Council approval to write off certain delinquent obligations owed to the City, totaling $164,535.70, as uncollectible debt for Fiscal Year 2025-26.

BACKGROUND
The City maintains a billing system to record and track amounts owed to the City (receivables). On occasion, obligors fail to remit payment and the receivables become delinquent. Resolution No. 9666-20 authorizes the Finance Director to utilize all lawful and reasonable means to pursue prompt and full recovery of amounts owed to the City and establishes procedures for the write-off of uncollectible debt. Under the Resolution, delinquent receivables in excess of $10,000 may be written off as uncollectible upon approval by the City Council.

After reasonable and good faith collection efforts have been exhausted, a delinquent receivable may be deemed uncollectible if one or more of the following conditions exist:
• The debtor is deceased;
• The debtor cannot be identified;
• The debtor cannot be located;
• The debtor has no recoverable assets; or
• The statute of limitations for pursuing legal remedies has expired.

The write-off of uncollectible receivables is a standard financial management practice necessary to maintain accurate accounting records and financial reporting. The practice is also consistent with applicable accounting principles and auditing standards. 267
Item 244/2026

Page 2 of 2 ends

DISCUSSION
The following delinquent accounts with balances over $10,000 are considered uncollectible for Fiscal Year 2025-26:

Account Name Amount Owed Description of Debt

1. Medrano, Vivian Mercedez $ 10,319.20 Subrogation – Traffic collision

2. Bragg, Mary Jane $ 11,177.20 Subrogation - Traffic collision

3. Bardere, Lessarae Charlotte $ 17,645.63 Subrogation - Traffic collision

4. Giang, Chan Tham $ 20,122.61 Subrogation – Felony/ Traffic collision

5. Ramos, Ceferino Ascencion $ 22,596.40 Subrogation - DUI

6. Cabrerasegura, Joshua Alfredo $ 23,497.98 Subrogation - Traffic collision

7. Miller, Austin Bo $ 24,009.40 Subrogation – DUI

8. Zavala, Christopher Yareb $ 35,167.28 Subrogation - Traffic collision All eight uncollectible receivables resulted from the City’s subrogation proceedings involving DUI incidents and traffic collisions. These incidents required the use of various City resources, including personnel time and repairs to City property. Consistent with City policy, staff pursued cost recovery efforts for each case. The City utilizes a third-party administrator to assist with the administration and collection of subrogation claims.

Collection efforts for the above cases have been exhausted, and the delinquent receivables are more than six months old. Pursuant to Resolution No. 9666-20, Article II, Collection of Delinquent Obligations Owing to the City, staff is requesting City Council approval to write off these delinquent receivables as uncollectible debt.

FINANCIAL IMPACT
The total amount requested to be written off in Fiscal Year 2025-26 is $164,535.70. These receivables were previously recorded in the City’s accounting records as an Allowance for Doubtful Accounts, and the related revenue reductions were recognized at the time the receivables were deemed uncollectible for financial reporting purposes. Accordingly, approval of the proposed write-offs will not result in any additional financial impact to the City.

The related account records, including the write-offs, will continue to be maintained within the City’s billing system for recordkeeping and reference purposes.

RECOMMENDATION
It is recommended that the City Council:
 Approve the write-off of the above eight delinquent accounts with a total amount of $164,535.70 as uncollectible debt in Fiscal Year 2025-26. 268
Item 219/2026
Final
City of Garden Grove

INTER-DEPARTMENT MEMORANDUM
To: Lisa L. Kim From: Samuel Kim
Dept: City Manager Dept: Public Works
Date: 6/9/2026
Subject: Acceptance of Project No. CP-1414000 - Lampson Avenue and Knott Street Storm Drain Improvements Project, as complete. (Action Item)

OBJECTIVE
For the City Council to accept the above project as complete and authorize the City Manager to execute the Notice of Completion of Public Improvement and Work.

BACKGROUND
On March 10, 2026, the City entered into a contract with Duffy General Engineering Inc., a general contractor to complete the Lampson Avenue and Knott Street Storm Drain Improvements Project (Project). Specifically, the Project addressed removal of existing two 48-inch diameter corroded corrugated metal pipes (CMPs) and concrete junction structure; installation of 48-inch diameter of reinforced concrete pipe (RCP) and adjustment of utility covers to finish grade.

DISCUSSION
The contractor, Duffy General Engineering, Inc., has completed the improvements in accordance with the plans, specifications, and other contract documents. Therefore, the City moves to close out the project and file a Notice of Completion of Public Improvement Work.

FINANCIAL IMPACT
There is no impact to accept the above project as complete. These improvements were included in the Fiscal Year 2026-27 Capital Improvement Plan budget and are funded by Gas Tax SB1 funds.

RECOMMENDATION
It is recommended that the City Council:
 Accept Project No. CP 1414000 – Lampson Avenue and Knott Street Storm Drain Improvements Project, as complete;
269
Item 219/2026

Page 2 of 2 ends

 Authorize the City Manager, or designee, to execute the Notice of Completion of Public Improvement and Work; and
 Authorize the Finance Director to release the retention payment when appropriate to do so.

By: Navin Maru, Project Manager

ATTACHMENT(S)

1. Notice of Completion
270

RECORDING REQUESTED BY
When Recorded Mail To:City ClerkCity of Garden Grove
P. 0. Box 3070Garden Grove, CA 92842

NOTICE OF COMPLETION

OF PUBLIC IMPROVEMENT AND WORK
NOTICE IS HEREBY GIVEN that the City of Garden Grove, Orange County, California, has caused a public improvement, to wit:

PROJECT NO. CP-1414000

LAMPSON AVE AND KNOTT ST STORM DRAIN IMPROVEMENTS
to be constructed upon the property hereinafter described. The contract for furnishing of all plant, labor, services, materials, and equipment, and all utilities and transportation,including power, fuel, and water, and performing all work necessary to construct arid complete, in a good and workmanlike manner in strict accordance with the specifications, plans, and drawings therefore on file in the office of the City Clerk of the City of Garden Grove, for the construction, installation and completion of the above-described public improvement and work, was heretofore made and entered into with Duffy General Engineering, Inc., on the 10th of March 2026, and filed for record in the office of the City Clerk of the City of Garden Grove; that the work upon said public improvement has beencompleted, and that the City Engineer has notified the City Council that he has made andcompleted a final inspection of the materials furnished and installed and the work performed in the construction, installation, and completion of said public improvement hereinabove more particularly described and set forth, and has certified in writing to the City Council that all the provisions of the contract and contract documents for the furnishing of all plant, labor, services, materials, and equipment, and the performing of all work necessary for the construction, installation, and completion of said public improvement above described have been fully complied with to his satisfaction as required by the contract document; that final acceptance of the construction, installation, and completion of said public improvementabove described was made on the 23rd of June 2026 that the nature of the title to said property of said City of Garden Grove is as follows: That is to say, it owns said publicimprovement in fee except the right-of-way upon which it is constructed, and that it owns an easement upon, over, and along said right-of-way for the purpose of the construction, installation, and completion of said public improvement hereinabove described and the use thereof after said completion; that the property hereinabove referred to and on which said public improvement is situated is described as follows, to wit:

PROJECT NO. CP-1414000

LAMPSON AVE AND KNOTT ST STORM DRAIN IMPROVEMENTS
271
NAME OF SURETY on
Labor and Material Bond is: RLI Insurance Company
4675 MACARTHUR COURT, SUITE 750
NEWPORT BEACH, CA 92660
Tel No,(949) 461-7000
DATED this day of 20
CWy OF GARDEN GROVE
By
City Manager of the City of
Garden Grove
ATTEST:

City Clerk of the City of GardenGroveSTATE OF CALIFORNIACOUNTS OF ORANGEI am the City Engineer of the City of Garden Grove,I have read the foregoing Notice of Completion of Public Improvement and Work, and know the contents thereof; and I certify that the same is true of my own knowledge, except as tothose matters, which are therein stated upon my information or belief, and as to those matters I believe to be true.

I certify (or declare), under penalty of perjury, that the foregoing is true and correct.

Executed on June 23, 2026 / Garden Grove , California
272
Item 230/2026
Final
City of Garden Grove

INTER-DEPARTMENT MEMORANDUM
To: Lisa L. Kim From: Samuel Kim
Dept: City Manager Dept: Public Works
Date: 6/9/2026
Subject: Acceptance of Project No. CP-1446000 - 2025 Residential Streets Improvements Project, as complete. (Action Item)

OBJECTIVE
For the City Council to accept the above project as complete and authorize the City Manager, or designee, to execute the Notice of Completion of Public Improvement and Work.

BACKGROUND
On June 24, 2025, the City entered into a contract with Hardy & Harper, Inc., a general contractor to complete the 2025 Residential Streets Improvements Project (Project).

Specifically, the Project addressed each street segment with different rehabilitation measures to properly manage their unique circumstances. This involved the following elements: removal and replacement of failed pavement areas; cold milling and asphalt paving; installation of slurry seal; repair of damaged concrete; adjustment of utility covers to finish grade; installation of catch basin inlet screens; restoration of traffic striping and signing; and reestablishment of centerline ties and monuments.

Street segments and site location included in the Project were: Safford Street from Chester Avenue to Lampson Avenue; Chester Avenue from Safford Street to Glen Street; George Street from southerly end to Chester Avenue; Glen Street from Dorada Avenue to Chester Avenue; College Avenue from 9th Street to George Street; and Lemonwood Lane from Garden Grove Blvd to Homestead Place.

DISCUSSION
The contractor, Hardy & Harper, Inc., has completed the improvements in accordance with the plans, specifications, and other contract documents. Therefore, the City moves to close out the project and file a Notice of Completion of Public Improvement Work. 273
Item 230/2026

Page 2 of 2 ends

FINANCIAL IMPACT
There is no financial impact associated with the City Council accepting the above project as complete and authorizing the City Manager, or designee, to execute the Notice of Completion of Public Improvement and Work for Project No. CP-1446000 – 2025 Residential Streets Improvements Project.

RECOMMENDATION
It is recommended that the City Council:
 Accept Project No. CP 1446000 – 2025 Residential Streets Improvements Project as complete;
 Authorize the City Manager, or designee, to execute the Notice of Completion of Public Improvement and Work; and
 Authorize the Finance Director to release the retention payment when appropriate to do so.

By: Lesly Cantarero, Associate Engineer

ATTACHMENT(S)

1. Notice of Completion
274

RECORDING REQUESTED BY
When Recorded Mail To:

City ClerkCity of Garden Grove
P. 0. Box 3070
Garden Grove, CA 92842

NOTICE OF COMPLETION
_gfPUBU^^^^^^^^^^ AND WORK
NOTICE IS HEREBY GIVEN that the City of Garden Grove, Orange County, California, has caused a public improvement, to wit:

PROJECT NO. CP1446000
2025 Residential Streets Improvements Project
to be constructed upon the property hereinafter described. The contract for furnishing of all labor, services, materials, and equipment, and all utilities and transportation, including power, fuel, and water, and performing all work necessary to construct and complete, in a good and workmanlike manner in strict accordance with the specifications, plans, anddrawings therefore on file in the office of the City Clerk of the City of Garden Grove, for the construction, installation and completion of the above-described public improvement and work, was heretofore made and entered into with Hardy & Harper, Inc. on the 24thday of June 2025, and filed for record in the office of the City Clerk of the City of GardenGrove; that the work upon said public improvement has been completed, and that the City Engineer has notified the City Council that he has made and completed a final inspection of the materials furnished and installed and the work performed in the construction, installation, and completion of said public improvement hereinabove more particularly described and set forth, and has certified in writing to the City Council that all the provisions of the contract and contract documents for the furnishing of all labor, services, materials, and equipment, and the performing of all work necessary for the construction,installation, and completion of said public improvement above described have been fully complied with to his satisfaction as required by the contract document; that finalacceptance of the construction, installation, and completion of said public improvement above described was made on the 26th day of May 2026 that the nature of the title to said property of said City of Garden Grove is as follows: That is to say, it owns said publicimprovement in fee except the right-of-way upon which it is constructed, and that it owns an easement upon, over, and along said right-of-way for the purpose of the construction, installation, and completion of said public improvement hereinabove described and theuse thereof after said completion; that the property hereinabove referred to and on which said public improvement is situated is described as follows, to wit:

PROJECT NO. CP1446000
2025 Residential Streets Improvement Project
275
NAME OF SURETY on Labor and Material Bond is:

DATED this
ATTEST:

Fidelity and Deposit Company of Maryland777 South Figueroa Street, Suite 3900 Los Angeles, CA 90017
Tel No.(213) 270-0600
By
day of 20

CITY OF GARDEN GROVE
City Manager of the City of Garden
Grove
City Clerk of the City of Garden GroveSTATE OF CALIFORNIACOUNTY OF ORANGEI am the City Engineer of the City of Garden Grove.I have read the foregoing Notice of Completion of Public Improvement and Work, and know the contents thereof; and I certify that the same is true of my own knowledge, except as to those matters, which are therein stated upon my information or belief, and as to those matters I believe to be true.

I certify (or declare), under penalty of perjury, that the foregoing is true and correct.

Executed on , California
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276
Item 188/2026
Final
City of Garden Grove

INTER-DEPARTMENT MEMORANDUM
To: Lisa L. Kim From: Lizabeth Vasquez
Dept: City Manager Dept: City Clerk
Date: 6/9/2026
Subject: Receive and file the minutes from the meeting held on March 10, 2026. (Action Item)

OBJECTIVE
For the City Council to receive and file the minutes from the meeting held on March 10, 2026.

BACKGROUND/DISCUSSION
Attached are the minutes from the meeting held on March 10, 2026, recommended to be received and filed as submitted or amended.

FINANCIAL IMPACT
There is no financial impact.

RECOMMENDATION
It is recommended that the City Council:
 Receive and file the minutes from the meeting held on March 10, 2026.

ATTACHMENT(S)

1. Minutes – City Council 3/10/26
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MINUTES

GARDEN GROVE CITY COUNCIL
Regular Meeting
March 10, 2026
Community Meeting Center
11300 Stanford Avenue, Garden Grove, CA 92840

CONVENE CLOSED SESSION
At 5:36 p.m., Mayor Klopfenstein convened closed session.

ROLL CALL PRESENT: (7) Council Members Nguyen, Tran, DoVinh, Aresetgui, Muñeton, Mayor Pro Tem
Brietigam, Mayor Klopfenstein
ABSENT: (0) None

ORAL COMMUNICATIONS FOR CLOSED SESSION
Speakers: None.

CONFERENCE WITH LEGAL COUNSEL - ANTICIPATED LITIGATION
Significant exposure to litigation per Government Code Section 54956.9(d)(2):

One potential case relating to Caltrans decommissioning of portion of vacated Brady Way.

CONFERENCE WITH LEGAL COUNSEL – EXISTING LITIGATION
Pursuant to Government Code Section 54956.9(d)(1):

Van Wortel v. City of Garden Grove, OCSC Case No. 30-2020-01175793

ADJOURN CLOSED SESSION
At 6:19 p.m., Mayor Klopfenstein adjourned closed session.

CONVENE REGULAR MEETING
At 6:31 p.m., Mayor Klopfenstein convened the meeting in the Council Chamber with all Council Members present.
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INVOCATION

PLEDGE OF ALLEGIANCE TO THE FLAG OF THE UNITED STATES OF AMERICA

COMMUNITY SPOTLIGHT IN RECOGNITION OF THE SISTER CITY ASSOCIATION OF

GARDEN GROVE EXCHANGE STUDENT AMBASSADORS VISITING ANYANG,

REPUBLIC OF KOREA
Certificates of Recognition were presented to Garden Grove Unified School District students: Audry Dinh, Kathleen Quach, Kimberly Tran, Julie Ngo, Kevin Cao, Pablo Alba, Yvonne Tran, Jenny Ta, Nathan Nguyen, Julie Tran.

Arely Flores, Sister City Board Member; Julie Ngo, Pacifica High School student; and, GGUSD Board of Education President Lan Nguyen shared a few remarks.

COMMUNITY SPOTLIGHT IN RECOGNITION OF COMMUNITY MEMBERS FOR THEIR PARTICIPATION IN THE 2025 GARDEN GROVE HOLIDAY LIGHTS
Certificates of Recognition were presented to: Sherry and Randy Williams; Shana Vodhanel and Mike Vodhanel; Jesus and Antonia Vega; Raymond and Susana Martinez; Heriberto Ruelas; The Estrada Family; Ruta Vaesau-LenWai and Jimmy Falealili; Bill and Bonnie Crawford; Mike and Noelle Kuhl; Tammy Erenler; Danny and Alma Valdivia.

ADOPTION OF A PROCLAMATION RECOGNIZING APRIL AS FAIR HOUSING MONTH (F:83.1-2026)
Aftern the matter was pulled from the Consent Calendar by Mayor Klopfenstein, it was moved by Council Member Muñeton, seconded by Council Member Tran that:

A Proclamation recognizing April as Fair Housing Month in Garden Grove, be adopted.

The motion carried by a 7-0 vote as follows:

Ayes: (7) Nguyen, Tran, DoVinh, Muñeton,
Arestegui, Brietigam, Klopfenstein
Noes: (0) None
Martha Torres, Community Engagement Liaison for the Fair Housing Foundation, was present to receive the framed proclamation.

RECESS
At 6:53 p.m. Mayor Klopfenstein recessed the meeting.
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RECONVENE
At 7:08 p.m., Mayor Klopfenstein reconvened the meeting with all Council Members present.

ORAL COMMUNICATIONS
Speakers: Pedro Reyes, Cindy Tran, Martha Romero, Ralph G. Baker, Nicholas Dibs, Nicole Jaimes
Written Communications: Sam Giahi, Nicholas Dibs
RECESS
At 7:23 p.m., Mayor Klopfenstein recessed the meeting.

RECONVENE
At 7:27 p.m., Mayor Klopfenstein reconvened the meeting with all Council Members present.

ADOPTION OF A PROCLAMATION RECOGNIZING APRIL AS DONATE LIFE MONTH (F:83.1-2026)
It was moved by Mayor Pro Tem Brietigam, seconded by Council Member DoVinh that:

A Proclamation recognizing April as Donate Life Month in Garden Grove, be adopted.

The motion carried by a 7-0 vote as follows:

Ayes: (7) Nguyen, Tran, DoVinh, Muñeton,
Arestegui, Brietigam, Klopfenstein
Noes: (0) None

ADOPTION OF A PROCLAMATION RECOGNIZING APRIL AS FAIR HOUSING MONTH (F:83.1-2026)
The matter was considered earlier in the meeting.

ADOPTION OF A PROCLAMATION RECOGNIZING APRIL AS NATIONAL CHILD ABUSE PREVENTION MONTH (F:83.1-2026)
It was moved by Mayor Pro Tem Brietigam, seconded by Council Member DoVinh that:
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A Proclamation recognizing April as National Child Abuse Prevention Month in Garden Grove, be adopted.

The motion carried by a 7-0 vote as follows:

Ayes: (7) Nguyen, Tran, DoVinh, Muñeton,
Arestegui, Brietigam, Klopfenstein
Noes: (0) None
APPROVAL OF THE PROPOSED FISCAL YEAR 2026-27 WEST ORANGE COUNTY WATER BOARD COST SHARING BUDGET (F: 112.9)
It was moved by Mayor Pro Tem Brietigam, seconded by Council Member DoVinh that:

The West Orange County Water Board Fiscal Year 2026-27 proposed cost sharing budget for operational expenses, be approved.

The motion carried by a 7-0 vote as follows:

Ayes: (7) Nguyen, Tran, DoVinh, Muñeton,
Arestegui, Brietigam, Klopfenstein
Noes: (0) None
RECEIVE AND FILE THE 2025 ANNUAL PROGRESS REPORT ON THE STATUS OF THE GENERAL PLAN AND HOUSING ELEMENT (F: 20.2)
It was moved by Mayor Pro Tem Brietigam, seconded by Council Member DoVinh that:

The 2025 Annual Progress Report on the Status of the General Plan, be received and filed; and
Staff be authorized to transmit the 2025 Annual Progress Report on the Status of the General Plan to the Governor's Office of Planning and Research, and the California Department of Housing and Community Development.

The motion carried by a 7-0 vote as follows:

Ayes: (7) Nguyen, Tran, DoVinh, Muñeton,
Arestegui, Brietigam, Klopfenstein
Noes: (0) None

WARRANTS
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It was moved by Mayor Pro Tem Brietigam, seconded by Council Member DoVinh that:

Demands EFT numbers 00069880 through 00070561 and check numbers 00186512 through 00186526 inclusive as listed on the register and have been verified by the Finance Division as properly issued and bear all proper signatures, be received and filed.

The motion carried by a 7-0 vote as follows:

Ayes: (7) Nguyen, Tran, DoVinh, Muñeton,
Arestegui, Brietigam, Klopfenstein
Noes: (0) None
WAIVER
It was moved by Mayor Pro Tem Brietigam, seconded by Council Member DoVinh that:

Full reading of ordinances listed be waived.

The motion carried by a 7-0 vote as follows:

Ayes: (7) Nguyen, Tran, DoVinh, Muñeton,
Arestegui, Brietigam, Klopfenstein
Noes: (0) None
PUBLIC HEARING - ADOPTION OF RESOLUTIONS CONFIRMING AMENDMENT NO. 1 TO THE FISCAL YEAR 2025-2026 ADVISORY BOARD REPORT, APPROVING MODIFICATIONS TO THE ACTIVITIES FOR FISCAL YEAR 2025-26, AND CONFIRMING THE FISCAL YEAR 2026-27 ANNUAL REPORT, AND LEVYING ASSESSMENTS FOR THE GARDEN GROVE TOURISM IMPROVEMENT DISTRICT (F: 32.1)
Following Assistant City Manager Ursula Luna-Reynosa’s introduction, Deputy Director Greg Blodgett provided a presentation with key highlights and summary of actions that included:
• Approval of Amendment No. 1 to the Fiscal Year 2025-26 Advisory Board Report for modifications to the activities due to ART Transit shuttle service termination as of March 31, 2026;
• Approval of Garden Grove Tourism Improvement Distroct (GGTID) Fiscal Year 2026-2027 budget of $1,766,924
o Includes $600,000 to support a portion of the new resort-area shuttle system; Guests pay $7.00 per person for shuttle service o Budget allocations have been increased for maintenance, utilities and repairs, as well as budget increases for private security 282
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o Budget for other line items increased by 2% from previous year • Approval of Visit Anaheim GGTID budget of $1,987,000
Christina Dawson, Chief Operating Officer, accompanied by Ronnie Collins, Chief Sales Officer with Visit Anaheim, provided a presentation with an overview of economic and program results for Garden Grove for the period of July 2024 through June 2025. Key highlights included:
• $2.5 million marketing campaign
• Tradeshow booth
• Shift of international funding to domestic
• Meeting Mementum Program
• Confirmed industry events
Mayor Pro Tem Brietigam inquired about Visit Anaheim’s marketing tracking methods.

Christina Dawson with Visit Anaheim stated that every marketing effort is traced through tracking mechanisms with affliate companies and website.

Next, Mayor Pro Tem Brietigam inquiried about the forecasted number of trips provided by the new resort-area shuttle system.

Aaron Chavez, Vice President of Operations with Parking Companies of America (PCA), the transit system operator, stated that they project approximately 286,000 passangers per year; the needed number to break-even to provide the service. It is a three route system with shuttle service from the resorts to Disneyland Park only; no other destinations.

Council Member Tran inquired about the Hospitality Career Development Program.

Christina Dawson with Visit Anaheim shared that they work with the Garden Grove Unified School District and school faculty to identify students that have expressed interest in participating and pursue careers in hospitality and tourism. These students are trained under the certified Tourism Ambassador Program.

Council Member Muñeton inquired whether tourism trends were tracked year-toyear and whether there has been a increase or decrease in tourism this year.

Christina Dawson with Visit Anaheim confirmed that tourism trends are tracked year-to-year with the previous year trending flat, but noted growth indicators in room nights and economic impact.

Mayor Klopfenstein inquired about upcoming events like FIFA and the 2028 Olympics and what Visit Anaheim is doing in those respects. 283
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Christina Dawson with Visit Anaheim shared that they are engaged in early conversations with the Orange County Sports Commission.

Ronnie Collins, Chief Sales Officer with Visit Anaheim stated that they do not aniticipate large volume local tourism for World Cup; however Visit Anaheim is trying to plan some watch party events to draw up revenues for local communities.

In terms of the Olympics, volleyball events will be hosed at the Honda Center in in the City of Anaheim, therefore there will be focused programming for that.

Additionally, the host committee for the LA Olympics has committed to filling about three thousand rooms locally. Lastly, Mr. Collins shared that they are working on strategies to attract toursim from the Los Angeles area, highlighting advantages to staying outside of event epicenter with local attractions and other desitinations.

Council Member Nguyen inquired about the hospitality workforce numbers in a post-Covid era.

Christina Dawson shared their workforce numbers have rebounded with higher wages and benefits, and efforts through their certified Tourism Ambassador trainings are geared to cultivate future hospitality workforce pools.

Council Member Arestegui inquired about why the Workforce Development Program was ended.

Christina Dawson explained that due to budget constraints and elimination of a position that was formally dedicated to the program, they had to sunset the Workforce Development Program; however, efforts to engage and train students continues through the certified Tourism Ambassador program.

With no questions from the City Council, Mayor Klopfenstein declared the public hearing open.

Speakers: Nicholas Dibs
With no further testimony from the audience, Mayor Klopfenstein closed the public hearing.

The City Clerk announced that no protests were received; therefore, there was not a majority protest.

It was moved by Mayor Pro Tem Brietigam, seconded by Council Member Nguyen that:

Resolution 9957-26 entitled: A Resolution of the City Council of the City of Garden Grove confirming Amendment No. 1 to the Fiscal Year 2025-26 Annual Report of the Garden Grove Tourism Improvement District Advisory Board and approving modifications to the activities for Fiscal Year 2025-26, be adopted; and
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Resolution 9958-26 entitled: A Resolution of the City Council of the City of Garden Grove confirming the Annual Report of the Garden Grove Tourism Improvement District Advisory Board and levy assessments for Fiscal Year 2026-27 for the Garden Grove Tourism Improvement District, be adopted.

The motion carried by a 7-0 vote as follows:

Ayes: (7) Nguyen, Tran, DoVinh, Muñeton,
Arestegui, Brietigam, Klopfenstein
Noes: (0) None
AWARD A CONTRACT TO DUFFY GENERAL ENGINEERING INC., FOR THE LAMPSON

AVENUE AND KNOTT STREET STORM DRAIN IMPROVEMENTS PROJECT, CITY PROJECT NO. CP1414000 (F: 92.PROJ.CP1414000)
Following staff’s introducation, it was moved by Mayor Pro Tem Brietigam, seconded by Council Member Tran that:

A contract in the amount of $787,400, be awarded to Duffy General Engineering Inc., for the Lampson Avenue and Knott Street Storm Drain Improvements Project, City Project No. CP-1414000;
The Finance Director, or designee, be authorized to appropriate a total of $787,400 from the Gas Tax SB1 fund (208); and
The City Manager, or designee, be authorized to execute an agreement with Duffy General Engineering Inc., and make minor modifications as appropriate thereto, on behalf of the City.

The motion carried by a 7-0 vote as follows:

Ayes: (7) Nguyen, Tran, DoVinh, Muñeton,
Arestegui, Brietigam, Klopfenstein
Noes: (0) None
SECOND READING AND ADOPTION OF ORDINANCE NO. 2974 ADDING CHAPTER 6.50 TO TITLE 6 OF THE GARDEN GROVE MUNICIPAL CODE RESTRICTING THE SALE AND DISTRIBUTION OF NITROUS OXIDE PRODUCTS (F:50.1)
(It was moved earlier in the meeting by Mayor Pro Tem Brietigam, seconded by Council Member DoVinh and approved unanimously that full reading of the ordinances listed be waived.)
Following the reading of the Ordinance title by the City Clerk, it was moved by Mayor Pro Tem Brietigam, seconded by Council Member Nguyen that:
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Ordinance No. 2974, entitled: An Ordinance of the City Council of the City of Garden Grove adding Chapter 6.50 to Title 6 of the Garden Grove Municipal Code restricting the sale and distribution of nitrous oxide products, be adopted.

The motion carried by a 7-0 vote as follows:

Ayes: (7) Nguyen, Tran, DoVinh, Muñeton,
Arestegui, Brietigam, Klopfenstein
Noes: (0) None

MATTERS FROM THE MAYOR, CITY COUNCIL MEMBERS, AND CITY MANAGER

E-BIKE SAFETY AND ENFORCEMENT UPDATE AS PRESENTED BY THE GARDEN GROVE

POLICE DEPARTMENT
Police Officer Gomez provided a PowerPoint presentation on E-bike safety.

Presentation included information on:

• Electric bicycles: Class 1; Class 2; Class 3
• Electric motorcycle uses and violations
• Traumatic e-bike injuries and medical costs
• Applicable traffic laws and new e-bike laws effective January 1, 2026 • GGPD Goal: Reduce crashes, prevent injuries, and save lives Following the presentation, Mayor Klopfenstein asked staff to post the presentation on the City’s website, as well as to the City’s social media platforms to help educate the community. She also asked if minors had higher incidences with being issued citations.

Officer Gomez confirmed that minors have higher incidences of violating the vehicle code because they are not educated in those laws.

Mayor Pro Tem Brietigam commended Police Officer Gomez for a great presentation and requested for City staff to provide Councilmembers with a condensed segment of the recorded presentation, so that they can share with the community on their social media pages.

Council Member DoVinh asked whether the Police Department would benefit from additional City regulation to mitigate e-bike incidents.

Officer Gomez shared that they are working with the City of Huntington Beach and learning about their current diversion program that requires the parent and rider to complete a mandatory e-bike safety course to forego a fine. Additionally, the Huntington Beach School District has a program that requires students to get a 286
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permit, which is issued after completing an e-bike safety course, before students are allowed to take their bikes to campus.

Council Member DoVinh expressed interest in exploring and implementing similar programs.

Council Member Muñeton asked about the number of reported injuries related to stunts on e-bikes.

Officer Gomez shared that there have been a few incidents of cars being rear-ended as a result of riders doing stunts and taking over the roadways.

Council Member Muñeton expressed support in implementing e-bike safety training programs.

Council Member Arestegui requested that more research into ways to mitigate e-bike accidents be conducted. She also expressed the need for more educational opportunities for the adult community, in addition to student education, at City resource fairs and events.

Mayor Klopfenstein shared that the Orange County Transportation Authority has a robust roundtable with more information and there are other good takeaways from other cities that already have programs in place. Lastly, she thanked the Garden Grove Police Department for their efforts and update.

MATTERS FROM THE MAYOR, CITY COUNCIL MEMBERS, AND CITY MANAGER (CONTINUED)
Council Member Arestegui congratulated Gayle Knight with H.O.P.E. as they recently received donations from the Oversees Taiwan Care United Association. She highlighted the organization’s significant impact in the local community. Council Member Arestegui also commended Majeda Germany, Founder and President of the Orange County Women’s Business Chamber (OCWBC), and Rubi Garcia, Director of Non-Profits, for their successful first event adding that OCWBC is a non-profit that seeks to bring women leaders and entrepreneurs together across all Orange County.

Next, she congratulated the Santiago High School Cheer Team for their CIF Championship title and placement at Nationals, for which she requested a Community Spotlight for an opportunity to recognize their achievements. Lastly, Council Member Arestegui also shared that she attended the Islamic Society of Orange County’s (ISOC) 50th anniversary celebration and also requested a Community Spotlight noting that ISOC is one of the oldest mosque on the west coast.

Council Member Muñeton shared that she attended the Violet Elementary School musical production of Finding Nemo; a truly inspiring performance by cast and crew.

She also attend the Santiago High School LXG Talent Show which showcased talented high school students. Lastly, Council Member Muñeton shared that she attended the 287
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Northeast Little League opening day which was a great experience and wished them luck in their season.

Council Member DoVinh highlighted the Garden Grove Tourism Improvement District and the partnership with Visit Anaheim noting the significant revenue creation through tourism and hospitality. Next, Council Member DoVinh expressed support newly appointed Public Works Director Samuel Kim and for public work projects. He congratulated the new political party announced by a speaker earlier in the meeting.

Lastly, Council Member DoVinh wished Council Member Tran and his daughter a happy birthday.

Council Member Tran thanked the community for participating in the Holiday Lights contest and thanked local businesses and Servite High School’s robotics team for donating prizes. She also thanked Council Member Brietigam for his donation and support. Next, she shared that in response to community complaints of blight and trash in the area of Chapman Avenue from Brookhurst Street to Gilbert Street, she along with Mayor Klopfenstein and Assistant City Manager Matt West, toured the Southland Integrated Services, Inc. building and learned that there are plans to upgrade the facility in the future. She thanked City Manager Lisa Kim and Assistant City Manager Matt West for accompanying her on previous visits to businesses in the area, and for the outreach to those business to foster communications on possible solutions to improve the area. Next, she shared that she, along with Mayor Klopfenstein and Council Member Phillip Nguyen, attended the Garden Grove Unified School District’s 48th annual First Impressions Art Student Exhibit and Awards which was a great event. Next, she thanked Central Garden Grove Little League Baseball for the invitation and looks forward to learning more about their program. Council Member Tran also commended H.O.P.E. for their continued dedication to the community. She also attended the SteelCraft Lunar New Year event which was a fun event. In honor of Earth Day, clean-up events will be hosted in District 5 on April 11th and in District 3 on April 19th. Next, Council Member Tran shared that she will be providing a District 3 update at the Chamber of Commerce meeting held at Coastline College and invited the community to attend. Lastly, she thanked Council Members and City staff for the birthday celebration.

Council Member Nguyen wished Council Member Tran a happy birthday. He also shared that his niece, Laura Tran, a student at Garvin Intermediate School, won the 7th and 8th Grade Best in Show at the Garden Grove Unified School District’s First Impressions Art Student Exhibit and Awards. He thanked Mayor Klopfenstein for bringing back the Mayor’s Prayer Breakfast that was well attended and brought residents together. Next, he shared that he was honored to present a Certificate of Recognition to Ms. Shirley Sutherland, a teacher at Wakeham Elementary School, who for over 30 years, has made a positive impact by helping students evolve into community leaders and business owners.

Mayor Pro Tem Brietigam invited the community to attend the Orange County Fire Authority Open House event scheduled for Saturday, March 14, 2026 from 10 a.m. 288
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to 3 p.m. Next, he requested City staff follow up on a complaint presented by a resident earlier in the meeting about a possible business operating from a residence.

He also wished Council Member Tran a happy birthday. Lastly, he noted the upcoming completion of the new Police Department facility and requested support to bring back a City Council action item to name the new Police Department building in honor of former Mayor and Police Lieutenant William Dalton, for which he received unanimous consensus from Council Members.

Mayor Klopfenstein shared that the Mayor’s Prayer Breakfast had close to 200 attendees with key note speaker Police Chaplain, Pastor James Scheller, who delivered a beautiful message of unity. She also shared that she presented a Spirit Award to the family of Pastor Eric Williams, who was a dedicated and beloved community member that tragically passed in a cycling accident the previous year.

Next, she congratulated Cooper Johnson on becoming an Eagle Scout; it was a wonderful ceremony. Lastly, she reminded the community of the upcoming Eggscavation event scheduled for Saturday, April 4, 2026, from 1:00 pm to 4:00 pm at Atlantis Play Center. Tickets can be purchased on the City’s website.

City Manager Lisa Kim congratulated Mayor Klopfenstein for being selected by Senator Strickland as the Senate District 36 Woman of the Year.

City Attorney Sandoval announced that there was no reportable action on either of the Closed Session items.

ADJOURNMENT
At 9:13 p.m., Mayor Klopfenstein adjourned the Regular meeting. The next Regular City Council Meeting will be held on Tuesday, March 24, 2026, at 5:30 p.m. at the Community Meeting Center, 11300 Stanford Avenue, Garden Grove, California.

Lizabeth Vasquez
City Clerk
289
Item 250/2026
Final
City of Garden Grove

INTER-DEPARTMENT MEMORANDUM
To: Lisa L. Kim From: Patricia Song
Dept: City Manager Dept: Finance
Date: 6/9/2026
Subject: Receive and file warrants. (Action Item)

OBJECTIVE
For the City Council to receive and file the warrants.

BACKGROUND/DISCUSSION
Attached are the warrants recommended to be received and filed.

FINANCIAL IMPACT
Items listed in the warrants are budgeted.

RECOMMENDATION
It is recommended that the City Council:
 Receive and file the warrants.

ATTACHMENT(S)

1. Warrants
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Item 178/2026
Final
City of Garden Grove

INTER-DEPARTMENT MEMORANDUM
To: Lisa L. Kim From: Niki Wetzel
Dept: City Manager Dept: Community Development
Date: 6/9/2026
Subject: Adoption of a Resolution certifying the Supplemental Environmental Impact Report, adopting a Supplemental Mitigation Monitoring and Reporting Program, and adopting Findings of Fact, including a Statement of Overriding Considerations; Adoption of a Resolution approving modifications to the Conditions of Approval for Site Plan No. SP-107-2022; and Introduction and First Reading of an Ordinance Reapproving Planned Unit Development No. PUD 141- 01(A). (Action Item)

OBJECTIVE
Pursuant to a Stipulated Writ of Mandate issued by the Orange County Superior Court in Marlene Perez, et al. v. City of Garden Grove, et al., O.C.S.C. Case No. 30-2022-01281816- CU-WM-CXC, the City Council will consider a recommendation to: (1) certify a Supplemental Environmental Impact Report (SEIR), adopt a Supplemental Mitigation Monitoring and Reporting Program, and adopt Findings of Fact, including a Statement of Overriding Considerations; (2) approve revisions to the Conditions of Approval for Site Plan No.

SP-107-2022 (Rev. 2026) contingent upon the City Council’s action on PUD-141-01(A); and (3) reapprove Planned Unit Development No. PUD-141-01(A) with modifications limited to the Planned Unit Development Provisions and Development and Performance Standards to incorporate the mitigation measures and project design features identified in the SEIR for the previously approved Site B2 Project on 3.72 acres (Nickelodeon Hotel Resort).

BACKGROUND
The project site consists of 3.72 acres located on the northwest corner of Harbor Boulevard and Twintree Avenue. In total, the site is comprised of nineteen (19) parcels, the entirety of Thackery Drive, and a public alley. Thackery Drive and the alley have previously been vacated by City Council, and are integrated into the project site. The project site has a General Plan Land Use designation of International West Mixed Use (IW). The entirety of the project site is currently zoned Planned Unit Development No. PUD-141-01(A) pursuant to Ordinance No. 2938 (adopted September 13, 2022). Collectively, the project is referred to as the Site B2 Project. At this time, the project site is largely vacant. 468
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The Garden Grove Agency for Community Development and Palm Court Lodging, LLC, a California limited liability company entered into a Disposition and Development Agreement (DDA) on June 26, 2001 pursuant to which Palm Court was to acquire land from the Former Agency and develop two hotels. One hotel was completed. The subject applicant is the assignee of Palm Court with regard to the development of the second hotel under the DDA.

On September 13, 2022, the City Council approved a DDA to convey to the subject applicant approximately 1.5 acres of property owned by the City, including the vacated alley and Thackery Drive. Due to the pending litigation, the property has not been transferred to the applicant.

Entitlement History
In 2022, the applicant requested approval to develop the hotel resort. Approvals requested by the applicant included: (1) an amendment to Planned Unit Development No. PUD-141-01 to create a new sub-area, PUD-141-01(A); (2) Site Plan No. SP-107-2022 to authorize the construction of the proposed 500-room hotel resort; (3) Street Vacation No. SV-002-2022 to vacate the entirety of Thackery Drive and the alley; and (4) an Initial Study / Mitigated Negative Declaration (IS/MND) and Mitigation Monitoring and Reporting Program to comply with the California Environmental Quality Act (CEQA).

On July 7, 2022, the Planning Commission adopted Resolution Nos. 6044-22 and 6045-22, which: (1) recommended that the City Council adopt the IS/MND and Mitigation Monitoring and Reporting Program for the Project and approve Planned Unit Development No.

PUD-141-01(A); and (2) approved Site Plan No. SP-107-2022, subject to and contingent upon the effectiveness of a City Council resolution approving Street Vacation No. SV-002-2022 and an ordinance approving Planned Unit Development No. PUD-141-01(A).

On July 27, 2022, the Planning Commission’s actions were appealed to the City Council by Unite Here Local 11 on environmental grounds including the greenhouse gas (GHG) emissions and vehicle miles traveled (VMT) in the IS/MND. The appellant argued that an Environmental Impact Report (EIR) was required.

On August 23, 2022, the City Council (1) adopted (a) Resolution No. 9767-22 denying Unite Here Local 11’s appeal and upholding the Planning Commission’s approvals; (b) Resolution No. 9768-22 adopting the IS/MND and Mitigation Monitoring and Reporting Program for the Project; (c) Resolution No. 9769-22 for the approval of Site Plan No. SP-107-2022; and (d) Resolution No. 9766-22 to initiate Street Vacation No. SV-002-2022; and (2) conducted the first reading of Ordinance No. 2938 to approve Planned Unit Development No.

PUD-141-01(A).

On September 13, 2022, City Council adopted Resolution No. 9772-22 approving Street Vacation No. SV-002-2022, and adopted Ordinance No. 2938 to approve Planned Unit Development No. PUD-141-01(A).

On September 22, 2022, Marlene Perez, Maria Guadalupe Ortiz, and Unite Here Local 11 (collectively, “Petitioners”) filed a Petition for Writ of Mandate, Complaint for Invalidation, Injunctive and Declaratory Relief in the Superior Court for the State of California, County of Orange, challenging the City Council’s actions on CEQA and other grounds (the “Petition”). 469
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Petitioner VietRise later joined the litigation. Prior to trial, the parties reached a settlement, which the Court entered as a Stipulated Writ of Mandate on February 13, 2024 (the “Stipulated Writ”).

Pursuant to Public Resources Code Section 21168.9(c), the Stipulated Writ left the City’s 2022 approvals in place, and did not direct the City to exercise its discretion in any particular way.

Instead, the Stipulated Writ requires the City, if it and the Real Parties in Interest decide to proceed with the Project, to: (a) prepare a focused CEQA review of the Project’s potentially significant VMT and GHG impacts; (b) assess whether modifications are needed to the prior approvals, including mitigation measures and conditions of approval, in light of that focused CEQA analysis; and (c) approve, approve with modifications, or deny the PUD at a publicly agendized City Council meeting. All other claims were waived, released, and dismissed with prejudice. Pending discharge of the Stipulated Writ, no physical changes to the project site may be made.

To comply with the Stipulated Writ, the City has prepared an SEIR providing the focused CEQA review of the Project’s VMT and GHG impacts. The City Council is now considering recommendations on certification of the SEIR, approval of revisions to the Conditions of Approval attached to Site Plan No. SP-107-2022 (now stylized as SP-107-2022 (Rev. 2026)) to incorporate the mitigation measures identified in the SEIR, and administrative updates, and reapproval of PUD-141-01(A) with modifications limited to the Planned Unit Development Provisions and Development and Performance Standards to incorporate the Mitigation Measures and Project Design Features identified in the SEIR. The City is required to file a return to the Stipulated Writ in court summarizing the actions taken by the City to comply with the Stipulated Writ no later than ninety (90) days after taking those actions The subject item was scheduled for a Planning Commission hearing on May 7th, 2026. Ninetyfour (94) public comment letters were received opposing the project, and one (1) public comment letter was received in favor of the project. During the hearing, twelve (12) speakers from the public, in addition to the project applicant, came forward to speak on the item.

By a vote of 7-0, the Planning Commission adopted Resolution Nos. 6133-26, 6134-26, and 6135-26 recommending that the City Council adopt: (i) a Resolution certifying the SEIR, adopting a Supplemental Mitigation Monitoring and Reporting Program, and adopting Findings of Fact, including a Statement of Overriding Considerations, pursuant to Paragraph 1(a) of the Stipulated Writ of Mandate; (ii) a Resolution approving revisions to the Conditions of Approval for Site Plan No. SP-107-2022, contingent upon the City Council’s action on Planned Unit Development No. PUD-141-01(A) pursuant to Paragraph 1(b) of the Stipulated Writ of Mandate; and (iii) an Ordinance reapproving Planned Unit Development No. PUD-141-01(A) with modifications limited to the Planned Unit Development Provisions and Development and Performance Standards to incorporate the mitigation measures and project design features identified in the SEIR pursuant to Paragraph 1(c) of the Stipulated Writ of Mandate.

DISCUSSION
Site Plan No. SP-107-2022 (Rev. 2026):
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The envisioned build-out of the project site is based on the submitted project plan and environmental document. All construction plans for the hotel resort would be consistent with the PUD standards, the associated plans, environmental documentation, and conditions of approval. A summary of the project is provided below:
 Primary vehicular access to the site would be from Harbor Boulevard, while secondary vehicular access would be from Twintree Avenue  The hotel would include multiple entertainment areas, restaurants, a pool with water slides, and ballrooms.
 A total of 528 parking spaces would be provided across a five (5) level parking garage.
 The first six (6) stories would be reserved for programming, levels seven (7) to twenty-two (22) would include the hotel rooms, and the top floor would house a restaurant.
 The street frontages along Twintree Avenue and Harbor Boulevard would include a streetscape design consistent with the Grove District.  The building would be designed in a unique serpentine shape, up to a maximum height of 335’-8” to the top of the parapet.
 The building façade would be primarily clad in glass.

The approved project design is not changing. The building footprint, height, layout, parking configuration, and architectural design remain as previously approved in 2022. The narrow scope of the current Site Plan action recommended to the City Council is to update the Conditions of Approval to incorporate the revised PUD Performance Standards reflecting the mitigation measures identified in the SEIR and to include administrative updates. The stylization “SP-107-2022 (Rev. 2026)” refers to this Conditions-of-Approval update only, and does not reflect any change to the approved site plan drawings.

Planned Unit Development No. PUD-141-01(A):

The PUD is being returned to the City Council pursuant to Paragraph 1(c) of the Stipulated Writ of Mandate, which requires the Council to "approve, approve with modifications, or deny" the PUD in open session at a publicly agendized meeting after considering the focused VMT and GHG analysis set forth in the SEIR. The modifications recommended for City Council consideration are limited to revisions to the PUD Development Provisions and Development and Performance Standards to incorporate the mitigation measures and project design features identified in the SEIR. No other changes to PUD-141-01(A) are proposed.

ENVIRONMENTAL REVIEW
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In 2022, an Initial Study and Mitigated Negative Declaration (IS/MND) was prepared for the proposed project pursuant to CEQA, Public Resources Code Section 21000 et seq. and the CEQA Guidelines (California Code of Regulations, Title 14, Sections 15000 et seq.).

Subsequently in 2022, an action was filed in Orange County Superior Court challenging the IS/MND's vehicle miles traveled (VMT) and greenhouse gas (GHG) impact analyses, among other claims.

The parties reached a settlement resulting in a Stipulated Writ of Mandate entered by the Court on February 13, 2024. To comply with the Stipulated Writ's requirement to prepare a focused CEQA review of the Project's VMT and GHG impacts, the City has prepared the SEIR.

A 45-day public comment period on the SEIR occurred from September 22, 2025 to November 6, 2025. Three (3) comment letters were received during the public comment period. These letters were from the Law Office of Jordan R. Sisson on behalf of Unite Here Local 11, Lozeau Drury LLP on behalf of the Supporters Alliance for Environmental Responsibility (“SAFER”), and the California Department of Transportation (Caltrans). The City's responses to these letters are included in the Final SEIR for the Project. The City received further written comments after the close of the public comment period on the Draft SEIR on November 26, 2025. These comments included a letter from the Channel Law Group on behalf of Unite Here Local 11 dated May 7, 2026 that was submitted hours before the Planning Commission hearing on the Project (the “May 7th Letter”), attached.

As disclosed in the Final SEIR, the Project would result in less than significant VMT impacts with the incorporation of mitigation and a significant and unavoidable GHG emissions impact.

A Supplemental Mitigation Monitoring and Reporting Program has been prepared for the Project.

The significant and unavoidable impact finding does not preclude approval of the Project. In this situation, CEQA requires the City Council to balance the Project's benefits against its unavoidable environmental risks. If the economic, legal, social, technological or other benefits of the Project outweigh the Project’s unavoidable environmental impacts, those impacts may be considered acceptable for CEQA purposes. In doing so, the City Council must adopt a Statement of Overriding Considerations identifying the specific reasons that support its actions. The Statement of Overriding Considerations prepared for the proposed Project identifies multiple independent bases for approval, including fiscal and economic benefits, job creation, General Plan and International West designation consistency, support for increased tourism, and VMT reduction benefits from the Project's location near transit and major visitor destinations. In support of the fiscal and economic findings, Tierra West Advisors prepared an Updated Economic Development Report and Analysis (April 2026) evaluating projected TOT, sales tax, and property tax revenues, as well as direct and indirect employment and total economic output.

FINANCIAL IMPACT
None.
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RECOMMENDATION
It is recommended that the City Council:
 Conduct a Public Hearing;
 Adopt a Resolution certifying the Supplemental Environmental Impact Report (SEIR), adopting a Supplemental Mitigation Monitoring and Reporting Program, and adopting Findings of Fact, including a Statement of Overriding Considerations, pursuant to Paragraph 1(a) of the Stipulated Writ of Mandate;  Adopt a Resolution approving revisions to the Conditions of Approval for Site Plan No. SP-107-2022, contingent upon the City Council’s action on Planned Unit Development No. PUD-141-01(A) pursuant to Paragraph 1(b) of the Stipulated Writ of Mandate; and
 Introduce and conduct the first reading of an Ordinance reapproving Planned Unit Development No. PUD-141-01(A) with modifications limited to the Planned Unit Development Provisions and Development and Performance Standards to incorporate the mitigation measures and project design features identified in the SEIR pursuant to Paragraph 1(c) of the Stipulated Writ of Mandate.

By: Priit Kaskla, Senior Planner

ATTACHMENT(S)

1. Draft City Council Resolution certifying the Supplemental Environmental Impact Report, adopting a Supplemental Mitigation Monitoring and Reporting Program, and adoption of Findings of Fact, including a Statement of Overriding Considerations

2. Draft City Council Resolution approving revisions to the Conditions of Approval for Site Plan No. SP-107-2022, with "Exhibit A" - Conditions of Approval

3. Draft City Council Ordinance reapproving Planned Unit Development No. PUD-141-01(A) with modifications limited to the Planned Unit Development Provisions and Development and Performance Standards

4. Planning Commission Staff Report dated May 7, 2026, with associated Resolutions and Minute Excerpt

5. May 7, 2026 Letter From Channel Law Group, LLP, on Behalf of Unite Here Local 11, to the Planning Commission

6. Project Plans
473

GARDEN GROVE CITY COUNCIL
RESOLUTION NO. ____-26

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF GARDEN GROVE

CERTIFYING A SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT (SEIR),

ADOPTING A SUPPLEMENTAL MITIGATION MONITORING AND REPORTING

PROGRAM, AND ADOPTING FINDINGS OF FACT, INCLUDING A STATEMENT OF OVERRIDING CONSIDERATIONS, FOR THE SITE B2 PROJECT (NICKELODEON HOTEL

RESORT) ON PROPERTIES LOCATED AT THE NORTHWEST CORNER OF HARBOR BOULEVARD AND TWINTREE AVENUE, EAST OF TAMERLANE DRIVE, AT 12241, 12261, 12271, 12291, 12311, 12321, AND 12323 HARBOR BOULEVARD, 12246, 12252, 12262, 12282, 12292, 12312, 12322, 12251, 12261, 12281, 12291, 12311, AND 12321 THACKERY DRIVE, THE VACATED THACKERY DRIVE, AND THE VACATED ALLEY, ASSESSOR’S PARCEL NOS. 231-471-06, 07, 08, 09, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, AND 54.

WHEREAS, the Project consists of the development of a full-service, high-rise hotel resort on 3.72 acres in the Grove District resort area, on the northwest corner of Harbor Boulevard and Twintree Avenue; and
WHEREAS, in 2022, the City adopted an Initial Study/Mitigated Negative Declaration (IS/MND) and Mitigation Monitoring and Reporting Program for the Project, approved Planned Unit Development No. PUD-141-01(A) pursuant to Ordinance No. 2938, approved Site Plan No. SP-107-2022, and approved Street Vacation No. SV-002-2022 (collectively, the “2022 Approvals”); and WHEREAS, on September 22, 2022, Marlene Perez, Maria Guadalupe Ortiz, and Unite Here Local 11 filed a Petition for Writ of Mandate in the Orange County Superior Court challenging the 2022 Approvals on CEQA and other grounds, and Petitioner VietRISE later joined the litigation (OCSC Case No. 30-2022-01281816-CU-WM-CXC) (the “Petition”); and
WHEREAS, the parties reached a settlement agreement and, as a result, the Court entered a Stipulated Writ of Mandate on February 13, 2024 (the “Stipulated Writ”). Pursuant to Public Resources Code Section 21168.9(c), the Stipulated Writ left the 2022 Approvals in place. The Stipulated Writ requires the City, if it and the Real Parties in Interest decide to proceed with the Project, to: (a) prepare a focused CEQA review of the Project’s potentially significant VMT and GHG impacts; (b) assess whether modifications are needed to the 2022 Approvals, including mitigation measures and conditions of approval, in light of that focused CEQA analysis; and (c) approve, approve with modifications, or deny the PUD at a publicly agendized City Council meeting. All other claims in the Petition were waived, released, and dismissed with prejudice; and
WHEREAS, in compliance with the Stipulated Writ and the California Environmental Quality Act, California Public Resources Code Section 21000 et seq. (“CEQA”) and CEQA’s implementing guidelines, California Code of Regulations, Title 474
Garden Grove City Council
Resolution No. ____-26

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14, Section 15000 et seq., a Supplemental Environmental Impact Report (“SEIR”) was prepared for the Project to provide a focused review of the Project’s potentially significant Vehicle Miles Traveled (VMT) and Greenhouse Gas (GHG) impacts; and WHEREAS, in compliance with CEQA and the CEQA Guidelines, the City of Garden Grove distributed a Notice of Preparation (NOP) to local, county, and state agencies along with interested private organizations and individuals. The NOP was delivered to the State Clearinghouse and the CEQA-required 30-day review period began on April 18, 2025 and ended on May 18, 2025. On April 30, 2025, the City conducted a public scoping meeting to provide an opportunity to receive feedback on potential environmental issues related to the project; and WHEREAS, in accordance with CEQA and the CEQA Guidelines, a Notice of Availability, along with the Draft SEIR, was circulated to the public, responsible agencies, and other interested persons for review and comment during the CEQArequired 45-day public review period from September 22, 2025 to November 6, 2025; and
WHEREAS, the Planning Commission of the City of Garden Grove held a duly noticed public hearing on May 7, 2026 regarding the Project, including the SEIR, and adopted Resolution No. 6133-26 recommending that the City Council, pursuant to Paragraph 1(a) of the Stipulated Writ, certify the SEIR, adopt a Supplemental Mitigation Monitoring and Reporting Program, and adopt Findings of Fact, including a Statement of Overriding Considerations; and
WHEREAS, pursuant to a legal notice, a Public Hearing was held by the City Council on June 9, 2026, and all interested persons were given an opportunity to be heard; and
WHEREAS, the City Council gave due and careful consideration to the matter during its meeting of June 9, 2026; and
WHEREAS, the SEIR has been completed in compliance with the Writ and CEQA; and
WHEREAS, the SEIR reflects the City’s independent judgment and analysis; and
WHEREAS, the City Council has reviewed and considered the information in the Final SEIR; and
WHEREAS, the Project’s potential impacts related to Greenhouse Gas emissions have been identified in the SEIR as significant and unavoidable. The Project’s potential impacts related to VMT have been identified as less than significant with the incorporation of mitigation. The City, therefore, must adopt a Supplemental Mitigation Monitoring and Reporting Program. Further, the City must adopt a “Statement of Overriding Considerations” per CEQA Guidelines Section 15093 475
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describing the reasons the City Council has determined that the economic, legal, social, technological, or other benefits of the Project outweigh its significant unavoidable impacts, thus rendering the significant unavoidable impacts acceptable under CEQA; and
WHEREAS, concurrently with the adoption of this Resolution, the City Council adopted a Resolution contingently approving Site Plan No. SP-107-2022 (Rev. 2026) pursuant to Paragraph 1(b) of the Stipulated Writ and introduced and conducted the first reading of an Ordinance reapproving Planned Unit Development No.

PUD-141-01(A) pursuant to Paragraph 1(c) of the Stipulated Writ; and WHEREAS, pursuant to Paragraph 3 of the Stipulated Writ, the City is required to file a return to the Stipulated Writ summarizing the actions taken by the City to comply with the Stipulated Writ no later than ninety (90) days after taking those actions.

NOW, THEREFORE, BE IT RESOLVED, FOUND AND DETERMINED as follows:

1. The City Council finds that the above recitals are true and correct.

2. The City Council, pursuant to Paragraph 1(a) of the Stipulated Writ of Mandate, hereby: (a) certifies the SEIR attached hereto as Exhibit “A” and incorporated herein by reference; (b) adopts the Supplemental Mitigation Monitoring and Reporting Program attached hereto as Exhibit “B” and incorporated herein by reference; and (c) adopts Findings of Fact, including a Statement of Overriding Considerations, for the Project attached hereto as Exhibit “C” and incorporated herein by reference.

3. Pursuant to Public Resources Code Section 21081.6(a)(2) and CEQA Guidelines Section 15097(e), the City Council hereby designates the City of Garden Grove Community Development Department, located at 11222 Acacia Parkway, Garden Grove, California, 92840, as the custodian of the documents and materials that constitute the record of proceedings up which this decision is based.
476
Final Supplemental Environmental Impact Report
Site B-2 Hotel Project
STATE CLEARINGHOUSE NUMBER 2022060174
MAY 2026
Prepared for:

CITY OF GARDEN GROVE
Office of Economic Development
11222 Acacia Parkway
Garden Grove, California 92840
Contact: Monica Covarrubias, Senior Project Manager
Prepared by:
27271 Las Ramblas, Suite 340
Mission Viejo, California 92691
Contact: Rachel Struglia, PhD, AICP
EXHIBIT "A" 477
478
FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 TOC-i
Table of Contents
SECTION PAGE NO.

Acronyms and Abbreviations.....................................................................................................................................ACR-1 1 Introduction ...................................................................................................................................................... 1-1

1.1 Contents and Organization of the Final Supplemental Environmental Impact Report .................. 1-2

1.2 Draft SEIR Comments ........................................................................................................................ 1-2 2 Responses to Comments Received ................................................................................................................ 2-1 Comment Letter – Caltrans (A1) .................................................................................................................... 2-3 Response to Comment Letter A1 ...................................................................................................... 2-5 Comment Letter – SAFER (O1) ....................................................................................................................... 2-7 Response to Comment Letter O1...................................................................................................... 2-9 Comment Letter – Unite Here Local 11 (O2) ...............................................................................................2-11 Response to Comment Letter O2....................................................................................................2-39 References .....................................................................................................................................................2-76 3 Changes to the Draft Supplemental Environmental Impact Report ............................................................. 3-1

3.1 Introduction......................................................................................................................................... 3-1

3.2 Changes to the Draft SEIR ................................................................................................................. 3-1

3.2.1 Changes to the Table of Contents, Tables .......................................................................... 3-1

3.2.2 Changes to Chapter 1, Executive Summary........................................................................ 3-2

3.2.3 Changes to Chapter 3, Project Description.......................................................................3-15

3.2.4 Changes to Section 4.1, Greenhouse Gas Emissions ......................................................3-15

3.2.5 Changes to Section 4.2, Transportation............................................................................3-36 4 Supplemental Mitigation Monitoring and Reporting Program....................................................................... 4-1

4.1 Introduction......................................................................................................................................... 4-1

4.2 Supplemental MMRP Table ............................................................................................................... 4-1 5 General Responses to Post–Public Review Comment Letters Received ..................................................... 5-1 TABLES
2-1 Comments Received on the Draft Supplemental Environmental Impact Report......................................... 2-1

4.2-4 VMT Reduction for Project-Generated VMT per Employee ..........................................................................3-37 4-1 Supplemental Mitigation Monitoring and Reporting Program....................................................................... 4-2 5-1 Representative Comment Letters Received After Close of the Public Review Period ................................. 5-1

APPENDIX
A Employee VMT Estimation for Site B-2 Hotel Project Memorandum 479

TABLE OF CONTENTS
FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 TOC-ii

INTENTIONALLY LEFT BLANK
480
FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 ACR-i
Acronyms and Abbreviations
Acronym/Abbreviation Definition
CalEEMod California Emissions Estimator Model
CALGreen California Green Building Standards
Caltrans California Department of Transportation
CAPCOA California Air Pollution Control Officers Association CEQA California Environmental Quality Act
CNG compressed natural gas
CTR Commute Trip Reduction
EIR environmental impact report
EV electric vehicle
EVSE Electric Vehicle Supply Equipment
GHG greenhouse gas
ITE Institute of Transportation Engineers
LEED Leadership in Energy and Environmental Design
MM Mitigation Measure
MMRP Mitigation Monitoring and Reporting Program
MND Mitigated Negative Declaration
MT CO₂e metric tons carbon dioxide equivalent
NOP Notice of Preparation
OCTAM Orange County Transportation Analysis Model
OD Origin/Destination
PA Production/Attraction
PDF project design feature
PRC California Public Resources Code
RHNA Regional Housing Needs Assessment
SAFER Supporters Alliance for Environmental Responsibility SANDAG San Diego Association of Governments
SCAG Southern California Association of Governments
SEIR Supplemental Environmental Impact Report
South Coast AQMD South Coast Air Quality Management District TAZ traffic analysis zone
TDM transportation demand management
TNC Transportation Network Company
TSF thousand square feet
VMT vehicle miles traveled
VOC volatile organic compound
481

ACRONYMS AND ABBREVIATIONS
FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 ACR-ii

INTENTIONALLY LEFT BLANK
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FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 1-1
1 Introduction
In accordance with the California Environmental Quality Act (CEQA) Guidelines (CEQA Guidelines) Section 15088 and the Writ of Mandate (Appendix B to the Site B-2 Hotel Draft Supplemental Environmental Impact Report [SEIR]), the City of Garden Grove, as the lead agency, has evaluated the comments received regarding the Draft SEIR, dated September 2025. This Final SEIR assesses the potentially significant environmental effects of the Site B-2 Hotel Project (Project), SCH No. 2022060174.

As described in the Draft SEIR, the proposed Project would involve construction of a full-service high-rise (maximum height of 350 feet) resort hotel with hotel program entertainment/pool deck (height of approximately 61 feet) on a

3.72-acre site at the northwest corner of Harbor Boulevard and Twintree Avenue in the City of Garden Grove (City).

The Project site is previously disturbed where the north-northeastern parcels of the Project site are paved and used for excess parking for the adjacent Sheraton Hotel; the remaining parcels are vacant dirt pads with limited vegetation. The proposed hotel would include 500 guest suites with balconies and guest amenities/services reserved exclusively for hotel patrons, such as a themed pool experience with lazy river; a theater; a ballroom; meeting rooms; food and beverage spaces, themed amenities and shops, and an arcade; and a spa and fitness center. The proposed Project would also include a five-level parking garage (approximately 61 feet in height, with four levels above grade and one level below grade) with a total of 528 spaces, including spaces available for valet parking. Project construction would last approximately 30 months and would be completed in a single phase.

The City will rely on the environmental impact analysis presented in this Final SEIR when issuing discretionary approvals associated with implementing the Project. In addition to City approvals, approvals from other state and local agencies may rely on the Final SEIR to the extent the Project requires discretionary approval from those agencies, including the following:
▪ California Department of Transportation (Caltrans) – Encroachment permit for any activity in a Caltrans right-of-way
If the Project requires other discretionary approvals from state or local agencies, those agencies may rely on the Final SEIR, pursuant to Section 21069 of the California Public Resources Code, as responsible agencies.

Before approving a project, CEQA requires the lead agency to prepare and certify a Final EIR (in this case, a Final SEIR). The contents of a Final EIR are specified in Section 15132 of the CEQA Guidelines as follows:

The Final EIR shall consist of:

A. The draft EIR or a revision of the draft.

B. Comments and recommendations received on the draft EIR either verbatim or in summary.

C. A list of persons, organizations, and public agencies commenting on the draft EIR.

D. The responses of the Lead Agency to significant environmental points raised in the review and consultation process.

E. Any other information added by the Lead Agency.

The lead agency must provide each agency that commented on the Draft SEIR with a copy of the lead agency’s proposed response at least 10 days before certifying the Final SEIR. 483
1 – INTRODUCTION
FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 1-2

1.1 Contents and Organization of the Final
Supplemental Environmental Impact Report
This Final SEIR will be used by the City as an informational document for the proposed Project. The Final SEIR, in compliance with Section 15132 of the CEQA Guidelines, is organized as follows:

Chapter 1, Introduction. This chapter provides a general overview of the proposed Project and the Final SEIR.

Chapter 2, Responses to Comments Received. This chapter includes a list of those who provided comments on the Draft SEIR during the public review period. This chapter also includes the comments received on environmental issues raised during the public review process for the Draft SEIR, and the City’s responses to these comments. Each comment is assigned a comment number that corresponds to a response.

Chapter 3, Changes to the Draft Supplemental Environmental Impact Report. This chapter contains a summary of changes made to the document since publication of the Draft SEIR. Changes are signified by strikethrough text (i.e., strikethrough) where text was removed, and by underlined text (i.e., underline) where text was added. As reflected in Chapter 3, these revisions make insignificant changes to the Draft SEIR and do not qualify as significant new information as described in CEQA Guidelines Section 15088.5(a).

Chapter 4, Supplemental Mitigation Monitoring and Reporting Program. This chapter of the Final SEIR provides the Supplemental Mitigation Monitoring and Reporting Program (MMRP) for the proposed Project. The Supplemental MMRP is presented in table format and identifies mitigation measures for the proposed Project, the party responsible for implementing each mitigation measure, the timing for implementing each mitigation measure, and the monitoring and reporting procedures for each mitigation measure.

Chapter 5, General Responses to Post–Public Review Comment Letters Received. This chapter includes three representative comment letters on the Draft SEIR that were received after the public review period and provides general responses to these letters, despite their having arrived outside the public review period.

Appendix A, Employee Estimation Memorandum. This appendix provides clarifying information relating to the methodology used for employee estimation in the SEIR’s analysis.

1.2 Draft SEIR Comments
A Notice of Availability of the Draft SEIR was sent to agencies and interested parties on September 22, 2025, and the Draft SEIR was circulated for public review from September 22, 2025, through November 6, 2025. The City received three comment letters during the 2025 public review period from the following commenters:
▪ Caltrans
▪ Rebecca Davis, Lozeau Drury LLP, for Supporters Alliance for Environmental Responsibility (SAFER) ▪ Law Office of Jordan R. Sisson for Unite Here Local 11 A list of the comments received, copies of the comment letters received, and responses to comments are included in Chapter 2 of this Final SEIR.
484
FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 2-1
2 Responses to Comments Received
This chapter of the final Supplemental Environmental Impact Report (Final SEIR) includes a copy of all comment letters that were submitted during the public review period for the Draft SEIR for the proposed Site B-2 Hotel Project (Project), along with responses to those comments in accordance with California Environmental Quality Act (CEQA) Guidelines Section 15088. The public review period for the Draft SEIR began on September 22, 2025, and ended on November 6, 2025.

One public scoping meeting was held on April 30, 2025. Comments received during the scoping meeting and in writing during the scoping period were included in the Draft SEIR in Chapter 2, Introduction, and included in Appendix A, Notice of Preparation and Scoping Comments, of the Draft SEIR.

All written letters commenting on the Draft SEIR during the public comment period have been coded with a letter and number to facilitate identification and tracking (see Table 2-1). The comment letters were reviewed and divided into individual comments. Individual comments and the responses to them were assigned corresponding numbers (e.g., A1-1, A1-2, A1-3). Each comment letter submitted by an agency is identified by an (A), and letters from organizations are identified by an (O). To aid readers and commenters, electronically bracketed comment letters have been reproduced in this document, with the corresponding responses provided immediately following each comment letter.

Table 2-1. Comments Received on the Draft Supplemental Environmental Impact Report
Comment
Letter
Designation Commenter Date
Agencies
A1 California Department of Transportation (Caltrans) October 16, 2025 Organizations
O1 Rebecca Davis, Lozeau Drury LLP, for Supporters
Alliance for Environmental Responsibility (SAFER)
November 3, 2025
O2 Law Office of Jordan R. Sisson for Unite Here Local 11 November 6, 2025 Notes: A = agency; O = organization.

The lead agency must evaluate comments on the Draft EIR and prepare written responses for inclusion in the Final EIR (California Public Resources Code Section 21091[d]; 14 CCR 15088[a], 14 CCR 15132). The written responses must describe the disposition of any “significant environmental issues” raised by commenters (California Public Resources Code Section 21091[d][2][B]); 14 CCR 15088[c], 14 CCR 15132[d], 14 CCR 15204[a]). 485
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Response to Comment Letter A1
California Department of Transportation, District 12
Scott Shelley
Branch Chief – Local Development Review/Climate Change/Transit Grants October 16, 2025
A1-1 This comment repeats the Draft SEIR’s summary of the Project. No response is necessary.

A1-2 This comment recommends the installation of high visibility crosswalks at all three existing crosswalks at the intersection of Twintree Lane and Harbor Boulevard to increase the visibility of pedestrian crossings.

The comment does not reference a specific CEQA topic area or section of the Draft SEIR. Nonetheless, Mitigation Measure (MM) GHG-5 already requires the Project to implement measures that will encourage use of transit, bicycling and walking. Specifically, that mitigation measure requires the Project to “Improve the walkability and design of the Project by providing pedestrian and bicycling connections within the Project site and to adjacent off-site facilities (i.e., sidewalks, crosswalks, wayfinding signage, etc.).” Although not required to mitigate Project impacts, the City and Project applicant will evaluate the viability of the California Department of Transportation (Caltrans) request and, if merited and prior to Project operations, the City and Project applicant will install high visibility crosswalks at the location of the three existing crosswalks at the Twintree Lane and Harbor Boulevard intersection. A condition of approval has been added to the proposed Project accordingly.

A1--3 This comment requests the City to continue to coordinate with Caltrans for any future development that could impact state transportation facilities. The City will continue to coordinate with Caltrans. 489
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Response to Comment Letter O1
Rebecca Davis, Lozeau Drury LLP
On Behalf of SAFER
November 3, 2025
O1-1 This comment provides a partial summary of the Project description in the Draft SEIR. No response is necessary.

O1-2 The comment alleges that the Draft SEIR fails as an informational document and also that it does not include all feasible mitigation measures to reduce the Project’s impacts.

The comment does not identify any specific deficiencies in the Draft SEIR. The Draft SEIR has been prepared in conformance with CEQA and the CEQA Guidelines. The Draft SEIR analyzes the environmental impacts as identified in, and required by, the Writ of Mandate. Furthermore, the Draft SEIR was prepared by experts in the areas of vehicle miles traveled (VMT) and greenhouse gas (GHG) emissions modeling. The analysis and determinations in the Draft SEIR are supported by substantial evidence (including facts, reasonable assumptions predicated upon facts, and expert opinion supported by facts), as defined in Section 15384 of the CEQA Guidelines.

CEQA Guidelines Section 15088.5, Recirculation of an EIR Prior to Certification, describes the requirements for recirculation of an EIR. This section applies to the SEIR as well. The comment identified no grounds that require recirculation and no further response is necessary.

O1-3 The comment states that SAFER reserves the right to supplement their comments during the administrative process. The comment is noted.
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Response to Comment Letter O2
Jordan R. Sisson, Attorney
On Behalf of Unite Here Local 11
November 6, 2025
O2-1 This comment is introductory and provides only a partial summary of the Project Description in the Draft SEIR. No response is necessary.

O2-2 The comment summarizes those comments that are made throughout the letter.

The Draft SEIR was prepared in compliance with CEQA and the Writ of Mandate (Writ). Thus, it includes a comprehensive analysis of the Project’s potential greenhouse gas (GHG) emissions and vehicle miles traveled (VMT) impacts. Responses to the comments in this letter are provided below and are summarized as follows:

Disclosure of Project Components. The Draft SEIR and supporting technical reports provide a detailed description of the proposed Project, including site location, design features, and operational characteristics (see Draft SEIR Section 1.4, Overview of the Project; Section 3, Project Description; and Appendix C, Greenhouse Gas Emissions Technical Report [GHG Report], Section

1.4). These disclosures satisfy CEQA’s requirements. No revision to the SEIR is required. For further discussion, see Response to Comment O2-7.

Users of the Project’s Components. The Draft and Final SEIR state that only registered hotel guests will have access to the Project and its various amenities (Chapter 3, Project Description, Draft SEIR, p. 3-4). This limitation is stated in the project design features (PDFs) that are incorporated into the Project’s Supplemental Mitigation Monitoring and Reporting Program (Supplemental MMRP; see Chapter 4 of the Final SEIR). The comment’s speculation to the contrary is unsupported. For further discussion, see Responses to Comments O2-6 through O2-11.

GHG Emissions and VMT Impacts. The comment asserts that the Project’s GHG and VMT impacts may be underestimated. Relying on expert analysis, reasonably foreseeable occupancy scenarios, and established methodologies and significance thresholds, the Draft SEIR properly evaluated the proposed Project’s potential GHG emissions and VMT impacts. The Draft SEIR discloses that, even with implementation of all feasible on-site mitigation (Mitigation Measure [MM] GHG-1 through MMGHG-14) and carbon offsets (MM-GHG-15), emissions would remain significant and unavoidable.

The proposed Project’s VMT impacts were evaluated using the Orange County Transportation Analysis Model (OCTAM) which is developed and maintained by the Orange County Transportation Authority and mitigated through MM-TRA-1 and MM-TRA-2. These measures would reduce the proposed Project’s VMT impacts to less than significant levels. Nothing further is required by CEQA or the Writ. For further discussion, see Responses to Comments O2-8, O2-10, and O2-12-.

Inclusion of a Housing Alternative. The comment alleges that the Draft SEIR should have included a housing alternative. In compliance with CEQA, the Draft SEIR evaluates feasible alternatives to the proposed Project, including a reduced-intensity hotel alternative and a no-project alternative.

As explained in Section 6.3 of the Draft SEIR, a housing-only development would not conform to the General Plan and zoning criteria, nor would it meet most of the Project’s objectives. For these reasons, such a development was “considered but rejected” as a proposed Project alternative. For further discussion, see Responses to Comments O2-26 through O2-35. 523
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Mitigation Measures. This introductory comment states that further/modified mitigation measures are required. The Final SEIR includes modifications to the mitigation measures and project design features (PDFs) made in response to comments received during the public review period. For further discussion, see Responses to Comments O2-38, O2-40, O2-42, O2-44, and O2-48.

The Draft SEIR and Supplemental MMRP comply with CEQA by providing full disclosure of anticipated impacts, applying conservative assumptions, and imposing all feasible mitigation. Although certain impacts remain significant and unavoidable (GHG emissions), the analysis and mitigation framework are consistent with state and regional climate policies and supported by substantial evidence.

O2-3 The comment references consistency with various plans and policies. The comment is introductory in nature and summarizes subsequent comments. Responses to those comments are provided below.

No further response to this comment is necessary.

O2-4 The comment is requesting that the SEIR be revised to address the points raised in the letter.

Responses to the letter’s comments are provided below. Changes made to the Draft SEIR in response to this letter or otherwise are included in Chapter 3 of this Final SEIR. No further response to this comment is necessary.

O2-5 The comment cites established CEQA case law regarding the requirement for an accurate, stable, and finite project description as a foundational element of a legally sufficient EIR, referencing San Joaquin Raptor Rescue Center v. County of Merced (2007), Citizens for a Sustainable Treasure Island v. City and County of San Francisco (2014), and Western Placer Citizens for an Agricultural and Rural Environment v. County of Placer (2006). The Draft SEIR contains a detailed project description in Chapter 3 that identifies the Project’s location and characteristics, including PDFs. This description of the proposed Project enables the public, decision makers, and reviewing agencies to meaningfully evaluate the proposed Project’s environmental impacts, consider mitigation measures, and assess alternatives. No further response is necessary.

O2-6 The comment summarizes the letter’s more detailed comments alleging that the Draft SEIR does not disaggregate (address separately) the individual Project components or make enforceable the assumption that 1,000 overnight guests will be on site. See Responses to Comments O2-7 through O2-10.

The proposed Project is a full-service high-rise themed resort hotel. It is intended to function as a fully immersive guest experience where guests come to stay and take full advantage of the amenities. To this end, and as incorporated in the proposed PDFs that are incorporated into the Project’s Supplemental MMRP, hotel amenities would be available only to hotel guests. Day passes would be prohibited. In other words, the restriction of amenities to registered hotel guests is a PDF incorporated in the Supplemental MMRP, not merely an analytical assumption. Accordingly, there is no reasonable basis to disaggregate Project components or to assume that there will be more guests on site than the registered hotel guests. No revision to the SEIR is needed.

O2-7 The comment raises three points: (1) the Draft SEIR does not explain changes to the Project between the Mitigated Negative Declaration (MND) and Draft SEIR, contending that the total building size increased from the 691,693 square feet identified in the MND to 718,919 square feet in the Draft SEIR; (2) unlike the MND, the Draft SEIR does not disaggregate square footage by individual amenity; 524
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and (3) the assumption that amenities are restricted to hotel guests only is not adequately explained.

The second and third issues are related and will be addressed together.

The total building square footage has not changed between the MND and the SEIR. The difference in the disclosed building square footage referenced in the comment results from: (1) the MND excluded the below-grade parking square footage (52,206 square feet); and (2) the MND included the themed hotel pool square footage (24,980 square feet). The below-grade parking square footage should have been included, while the swimming pool square footage should have been excluded because it does not constitute building floor area. Both of these errors were corrected in the SEIR, resulting in 718,919 square feet (691,693 + 52,206 − 24,980 = 718,919). No comments were received on the MND regarding these issues, nor were they identified in the Writ as a matter requiring further analysis. The Project has not changed in any material respect compared to what was analyzed in the 2022 MND.

The Draft SEIR did not disaggregate uses because this is not an accurate reflection of how the hotel will be operated. The Draft SEIR modeled the proposed Project as a single “hotel” land use because all on-site components—including the fitness room, theater, swimming pool, and restaurant—are ancillary to the hotel use and would not be operated as independent public destinations. Based on the PDFs incorporated into the Supplemental MMRP, hotel amenities would be available for registered hotel guests only. This approach is consistent with the Institute of Transportation Engineers (ITE) Trip Generation Handbook for ITE Land Use 310, which defines a hotel as “a place of lodging that provides sleeping accommodations and supporting facilities such as full-service restaurant, cocktail lounge, meeting rooms, banquet rooms, and convention facilities” along with recreational amenities such as pools and fitness rooms—treating all such facilities as integral components of a single hotel use (ITE 2017). It is further consistent with California Emissions Estimator Model (CalEEMod) guidance for mixed-use projects, under which ancillary facilities that do not function as independent trip-generating destinations are appropriately subsumed within the primary land use category. Disaggregating the hotel’s ancillary amenities as separate land uses would not produce a more accurate analysis; it would mischaracterize the proposed Project by treating captive on-site uses as though they would generate independent external trips and corresponding emissions. They would not.

No SEIR revision is necessary in response to this comment.

O2-8 The comment asserts that the Draft SEIR’s GHG Report (Appendix C to the Draft SEIR) should not have relied on CalEEMod modeling that analyzes only hotel guest uses of ancillary amenities and features.

Please see Responses to Comments O2-6 and O2-7. The comment assumes that the Draft SEIR may underestimate emissions by not analyzing the Project as if outside users could separately access Project amenities and features.

As previously explained, the proposed Project was modeled as a single hotel land use because all ancillary components are integral to the hotel operation, are limited to registered guests pursuant to the PDFs incorporated into the Supplemental MMRP, and do not function as independent tripgenerating destinations. This is not a departure from accepted methodology—it is a more accurate characterization of the Project than the prior MND, which disaggregated uses in a manner that does not reflect how the facility will actually operate.

As explained in Section 4.1.4 of the Draft SEIR, the proposed Project’s GHG emissions were generated by CalEEMod (Draft SEIR, p. 4.1-26). The Draft SEIR explained the CalEEMod inputs that were used to 525
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project the proposed Project’s potential GHG emissions on pages 4.1-26 through 4.1-33 and in Appendix C. These inputs included the land use types and sizes (Table 4.1-2); construction scenario (Table 4.1-3); and mobile, area, energy, water and wastewater, solid waste, refrigerant, and stationary sources (Draft SEIR, pp. 4.1-29 through 4.1-31). The Draft SEIR went on to explain which PDFs were quantitatively accounted for in CalEEMod (Draft SEIR, pp. 4.1-31 through 4.1-33).

The GHG analysis did not rely solely on CalEEMod default values. Project-specific inputs were substituted for defaults where the proposed Project’s operational characteristics warranted refinement. For example, energy consumption estimates were adjusted to account for the heating demands of the themed swimming pool and associated water facilities—a feature that is not reflected in generic hotel defaults. Water use estimates were drawn from the proposed Project’s Water Supply Assessment (Psomas 2022) rather than CalEEMod defaults, providing a Project-specific basis for waterrelated emissions. Amenities such as the themed pool are captured in the modeling through adjusted inputs that reflect their actual operational demands.

The resulting emissions inventory accounts for all major source categories—mobile, area, energy, water, waste, and refrigerants—associated with the hotel and its full complement of amenities. The comment has not identified a specific emission source that is absent from this inventory, nor has the comment provided quantitative support for the assertion that disaggregation would yield materially different results.

With respect to DisneylandForward, that project included theme park and amusement park uses that are categorically distinct from hotel operations, attract an entirely separate and independent visitor population, and have no equivalent in CalEEMod’s default land use categories. The proposed Project does not include any public-facing theme park or amusement facility. Its amenities are operationally and functionally equivalent to those described in ITE Land Use 310, which expressly encompasses pools, fitness rooms, restaurants, lounges, and meeting facilities as standard hotel components (ITE 2017).

For these reasons, the Draft SEIR’s GHG emissions analysis appropriately modeled the Project as a unified hotel use with Project-specific adjustments, consistent with CEQA and accepted modeling practices. No revision to the SEIR is necessary.

O2-9 The comment addresses the CalEEMod GHG modeling of mobile source emissions. The comment assumes that the Project’s 1,000 guests are based on 2 overnight guests per 500 hotel rooms. This assumption is incorrect. As explained in detail in the Draft SEIR, the number of overnight guests used in the VMT analysis, and in turn in the CalEEMod calculation of mobile source emissions, is based on a reasonably foreseeable occupancy scenario (2.5 persons per room, at 80% occupancy) (Draft SEIR, p. 4.2-13). To the extent this comment reiterates a concern about day users of the proposed Project’s amenities, see Responses to Comments O2-6 through O2-8.

The comment seems to assume that the Draft SEIR used only the 1,000 guests to model the Project’s GHG emissions but 1,000 guests plus 446 employees to calculate the Project’s VMT impacts. That assumption is incorrect. For purposes of the CalEEMod mobile source module, the OD Origin/Destination (VMT) is the relevant methodology. As Draft SEIR Section 4.2 explains, the OD method sums up all VMT from trips that either start or end within the Project. And, as acknowledged in the comment, the OD VMT assessment used a service population of 1,000 guests plus 446 employees 526
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(Draft SEIR, Appendix D, Attachment A, p. 6). Specifically, as described in Table A of the VMT assessment, the Project service population of 1,000 guests and 446 employes results in a total Projectgenerated VMT of 21,914 (Draft SEIR, Appendix D, p. 6). The GHG Technical Report attached to the Draft SEIR as Appendix C shows that this total 21,914 VMT figure from the VMT assessment was included in CalEEMod (SEIR, Appendix C, pp. 61, 73, and 188).

No revision to the SEIR is needed in response to this comment.

O2-10 The comment assumes that day visitors could access the hotel’s amenities. Relying on that assumption, the comment asserts that the Draft SEIR’s VMT analysis undercounts vehicle trips by limiting its service population to 446 employees and 1,000 overnight guests; that this represents a departure from the prior MND, which accounted separately for theater trips; and that the analysis should have followed the DisneylandForward approach of incorporating day-guest trips independent of hotel occupancy.

The comment suggests that the VMT analysis should have assumed that more guests would visit the hotel to use the hotel amenities. As explained above, no day visitors or outside guests will be permitted.

Because there would be no independent day-visitor population, separate trip rates for ancillary uses are not warranted (see Responses to Comments O2-6 to O2-8).

The prior MND assumed the theater would be open to visitors other than registered hotel guests. That assumption was not consistent with the proposed Project operations discussed in the MND and evaluated in the Draft SEIR.

As explained previously, DisneylandForward includes theme park and amusement facilities open to the general public, generating a large day-guest population entirely independent of hotel occupancy. The proposed Project has no equivalent. As such, separate trip rates for ancillary uses independent of hotel trips are not required for the proposed Project (see Response to Comment O2-8).

No revision to the SEIR is required.

O2-11 The comment states that the Draft SEIR’s analysis does not include day visitors in its VMT analysis, as DisneylandForward did. It also cites Great Wolf Lodge as a comparable example, where access to the facility is not limited to registered guests. As explained in Responses to Comments O2-6 to O2-10, access to all on-site amenities—including the theater, restaurant, and themed pool—would be restricted to registered hotel guests pursuant to the PDFs incorporated into the Supplemental MMRP (see Chapter 4, Supplemental Mitigation Monitoring and Reporting Program, of this Final SEIR). Therefore, it would not be appropriate to estimate trips and VMT from day guests because the Project is unlike Disneyland, Knott’s Berry Farm, Legoland, or Great Wolf Lodge in that respect. No revision to the SEIR is required.

O2-12 The comment restates that the Draft SEIR’s VMT and GHG emissions analysis does not account for trips and VMT from day visitors or guests. The comment suggests that the SEIR either reassess use of on-site amenities by day guests or include a condition of approval or PDF in the MMRP that limits the number of employees and guests to the assumptions used in the Draft SEIR. 527
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The City incorporates Responses to Comments O2-6 through O2-11 on the same topic here. As stated in those responses, no revision to the SEIR is necessary.

O2-13 This comment acknowledges that the Draft SEIR estimates the Project’s GHG emissions at 7,520.09 metric tons of carbon dioxide equivalent (MT CO₂e) per year, compared to 3,316 MT CO₂e per year in the prior MND, and prefaces further comments regarding the Draft SEIR’s GHG analysis. Responses to those further comments are provided below.

As context for the responses that follow, the updated Draft SEIR GHG emissions analysis was prepared in response to the Writ and in compliance with CEQA. The analysis was updated to reflect current modeling inputs, a new version of CalEEMod, and Project-specific operational source inputs (emergency generator, increased energy use for water heating). The GHG methodology estimates GHG emissions using CalEEMod (the statewide standard modeling program) and the GHG analysis evaluates the Project in comparison to the lowest South Coast Air Quality Management District threshold: 1,400 MT CO2e per year for commercial projects.

O2-14 This comment reiterates the assumption about the use of the Project amenities by day guests and recommends either making that restriction an enforceable condition in the Supplemental MMRP or revising the analysis to account for potential day-visitor access. See Responses to Comments O2-6 to O2-12. The restriction of amenities to registered hotel guests is already specified in the Draft SEIR’s project description (Section 3.4.2, Operations, p. 3-4) and incorporated into the Supplemental MMRP, not merely an analytical assumption. No revision to the SEIR is required in response to this comment.

O2-15 The comment states that the CalEEMod worksheets identify more than 20 emissions reduction measures that correlate with California Air Pollution Control Officers Association (CAPCOA) mitigation strategies, and that it is unclear how these measures correspond to the Draft SEIR’s listed PDFs and mitigation measures, whether they are consistent with CAPCOA strategies, and why other CAPCOA measures were not considered for incorporation. More detailed comments on mitigation measures are provided in Section E of the comment letter (designated as Comments O2-36 through O2-53 and addressed herein in Responses to Comments O2-36 through O2-53); corresponding responses are provided in this section in Responses to Comments O2-16 and O2-17.

CEQA does not require inclusion of any CAPCOA measures in a GHG emissions analysis. The Draft EIR analyzed and disclosed the Project’s potentially significant GHG impacts with and without mitigation.

That analysis included an evaluation of PDFs and feasible mitigation measures, some of which were based on measures identified in CalEEMod or on CAPCOA recommendations. The Project’s PDFs and mitigation measures do not mirror CAPCOA language verbatim; rather, they were intentionally tailored to reflect Project-specific design features, construction methods, and operational characteristics. This approach is consistent with CEQA best practice and CAPCOA guidance, which anticipates that lead agencies will adapt recommended measures to suit individual projects. In compliance with CEQA, the Draft SEIR documents the basis for any reductions in GHG emissions or impacts based on application of the PDFs and mitigation measures. Although the Draft SEIR is already compliant with CEQA, to improve clarity, Table 4.1 in Section 4.2, Supplemental Mitigation Monitoring and Reporting Program, in the Final SEIR includes text in italics specifying which CAPCOA measures from the CalEEMod worksheets correlate to each PDF or mitigation measure. 528
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Regarding the comment’s suggestion to incorporate additional CAPCOA measures, it is important to note that CEQA does not require adoption of every possible mitigation measure or measures not required to substantially reduce a project’s GHG emissions in light of other measures already imposed.

Under CEQA Guidelines Section 15126.4(a)(1), mitigation must be “feasible” and capable of substantially lessening or avoiding the significant environmental effect. Measures that are not applicable, do not achieve meaningful reductions, or are speculative do not meet this standard. Courts have reinforced this principle, holding that mitigation must be effective and supported by substantial evidence. The Draft SEIR’s mitigation strategy complies with CEQA’s requirements. Except as disclosed in the SEIR, the Supplemental MMRP imposes feasible, effective measures such as energy efficiency, renewable energy, water conservation, waste reduction, transportation demand management (TDM), and carbon offsets to reduce the Project’s potentially significant impacts.

O2-16 The comment opines that the City should impose different mitigation measures than those specified in the Draft SEIR. Specifically, the comment argues that the City should have included other, unspecified on-site mitigation measures targeting mobile and energy-related emissions before relying on offsets.

More detailed comments are provided in Section E of the comment letter (designated as Comments O2-36 through O2-53 and addressed herein in Responses to Comments O2-36 through O2-53); corresponding responses regarding unspecified on-site mitigation measures are provided in this section in Response to Comment O2-17.

The SEIR incorporates feasible and effective PDFs and mitigation measures that directly reduce the Project’s potentially significant GHG emissions, including mobile and energy-related GHG emissions.

These measures were selected because they are feasible and capable of substantially reducing emissions, as required by CEQA Guidelines Section 15126.4(a)(1). CEQA does not require adoption of measures that are infeasible or fail to achieve meaningful reductions.

Consistent with CAPCOA strategies and CEQA requirements, examples of the SEIR’s mitigation measures include the following:
▪ Transportation Measures: MM-TRA-1 and MM-TRA-2 reduce employee commute trips through commute trip reduction programs and bicycle facilities, while MM-GHG-5 promotes guest trip reductions by improving walkability, providing bicycle rentals, and encouraging public transit use. ▪ Energy Measures: MM-GHG-7 enhances building energy efficiency through advanced HVAC systems, smart controls, and low-E glazing, and MM-GHG-9 requires installation of on-site renewable energy (solar photovoltaic panels). MM-GHG-10 addresses water conservation, indirectly reducing energy demand for water heating and treatment.

Although the comment does not identify any specific energy or transportation measures, it is important to note that the Draft SEIR did not claim reductions in CalEEMod for certain transportation-related measures (see Chapter 4, Section 4.1, of this Final EIR for CAPCOA Measures T-5, Implement Commute Trip Reduction Program [Voluntary]; T-7, Implement Commute Trip Reduction Marketing; T-8, Provide Ridesharing Program; T-9, Implement Subsidized or Discounted Transit Program; and T-10, Provide Endof-Trip Bicycle Facilities) when doing so would have potentially resulted in an inaccurate representation of the Project’s GHG emissions. Specifically, the Project’s GHG emissions generated by VMT, and any related reductions, were based solely on the Project’s VMT’s modeling and analysis. That VMT modeling and analysis was prepared in accordance with the adopted City of Garden Grove Traffic Impact Analysis 529
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Guidelines for Vehicle Miles Traveled and Level of Service Assessment (VMT Guidelines; City of Garden Grove 2020) and OCTAM. Although the Project includes feasible transportation measures, such as commute trip reduction programs, bicycle facilities, and guest trip reduction strategies, consistent with CalEEMod, GHG reductions were not attributed to those measures because doing so would have required speculation. For those measures, the SEIR still imposed the mitigation as a binding commitment and provided a qualitative analysis rather than quantitative reductions that would not have been supported by substantial evidence. Applying additional VMT-based trip reduction credits in CalEEMod beyond what is already reflected in the OCTAM-based VMT analysis would effectively count the same reductions twice:
once in the VMT model and again in CalEEMod. The Draft SEIR avoided this approach to maintain analytical integrity and consistency between technical studies.

As the Draft SEIR discloses, even with the incorporation of feasible energy, transportation, and other GHG reduction measures, the Project’s GHG emissions, including from mobile and energy sources, remain significant. For this reason, the Project includes MM-GHG-15, which requires purchase and retirement of carbon offsets to achieve emissions below the South Coast Air Quality Management District’s lowest threshold of significance of 1,400 MT CO2e per year. Offsets are necessary because non-speculative, non-duplicative, quantifiable and feasible on-site mitigation measures are not sufficient to reduce the Project’s GHG emissions below a level of significance.

The primary source of GHG emissions for the Project are mobile and energy sources. CAPCOA’s Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity (Handbook) (CAPCOA 2024) establishes explicit caps to prevent double‑counting and overstatement when multiple transportation measures are combined. When land use, neighborhood design, parking/road pricing, and transit measures are combined, for example, the Handbook adopts a 70% maximum reduction in VMT, based on empirical comparisons of suburban vs. central‑city travel behavior. Because most mobile‑source GHG emissions scale directly with VMT, this 70% VMT cap results in a maximum theoretical GHG reduction of approximately 70% for mobile sources. However, a 70% maximum would not be achievable or reasonable for a guest-oriented resort hotel such as the Project located within the City because the Project’s travel demand is driven primarily by discretionary visitor trips originating outside the local region, over which the Project has little to no control, rather than by resident commute patterns or daily internal capture. Unlike mixed‑use urban developments or residential infill projects, a destination resort cannot materially influence trip frequency, trip length, or mode choice for most guests, who typically arrive by personal vehicle or regional air travel. As such, the empirical suburban-to-central-city VMT comparison underlying CAPCOA’s 70% cap is not applicable to a visitor‑serving hospitality use, and applying that maximum reduction would overstate achievable mobile‑source GHG emissions reductions and conflict with the Handbook’s guidance to avoid speculative or unsupported assumptions. Based on the experience and expertise of the City and its consulting experts, relying on the specifics of the Project and recognizing that the adopted mitigation would not result in quantifiable GHG emissions reductions, a reasonable estimate of potential GHG emissions reductions attributed to the Project’s transportation-focused mitigation measures (MM-GHG-4, MM-GHG-5, MM-TRA-1, and MM-TRA-2) would be in the range of 10%, Even if all energy GHG emissions were eliminated from the Project, the mobile sources alone would exceed the South Coast Air Quality Management District threshold of 1,400 MT CO2e per year.

Therefore, the Final SEIR appropriately and reasonably included GHG emission offset credits as a mitigation measure for the purposes of potentially reducing the Project’s GHG emissions below the significance threshold.
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O2-17 The comment reiterates the assumption about non-hotel guest use of the Project’s amenities and asserts that the required number of offsets may be underestimated. The comment also argues that the City should modify MM-GHG-15 to impose an annual reporting and reevaluation requirement related to Project GHG emissions, VMT, and mitigation effectiveness. More detailed comments on other PDFs and mitigation measures identified in the comment are provided in Section E of the comment letter (designated as Comments O2-36 through O2-53 and addressed herein in Responses to Comments O2-36 through O2-53).

For responses to comments regarding non-hotel guest use of the Project’s amenities, please see Response to Comment O2-6.

As to the arguments about requiring an annual reporting and reevaluation of GHG emissions and impacts, CEQA does not mandate such an approach following the adoption of an EIR. To do so would introduce a whole new level of uncertainty for projects, public agencies, and the public that is not required by CEQA. Rather, CEQA applies the “rule of reason,” meaning that the analysis and mitigation must be based on reasonable assumptions and substantial evidence, not speculative scenarios. CEQA requires a good-faith estimate of impacts at the time of environmental review based on a reasonable methodology and set of assumptions supported by substantial evidence (CEQA Guidelines Section 15064.4). Lead agencies are afforded discretion to determine the methodology for estimating GHG emissions impacts and selecting mitigation measures, provided the approach is explained and supported by substantial evidence. Further, CEQA prohibits application of the law that imposes additional substantive obligations beyond those specified in CEQA. The Draft SEIR’s GHG analysis, mitigation, and significance determinations comply with CEQA’s standards without imposition of the new methodology and speculation suggested in the comment.

MM-GHG-15 requires the purchase of carbon offsets either in a lump sum or annually to achieve emissions below the threshold of significance of 1,400 MT CO2e. The Draft SEIR’s methodology and analysis meet CEQA’s requirements for a reasonable, evidence-based analysis at the time the project is considered for approval.

O2-18 The comment states that the SEIR should be revised to address the issues previously identified and include consideration of additional mitigation measures, as further discussed in Section E of the comment letter (designated as Comments O2-36 through O2-53); see corresponding Responses to Comments O2-36 through O2-53.

The Draft SEIR includes a suite of GHG mitigation measures, MM-GHG-1 through MM-GHG-15, addressing energy efficiency, renewable energy, water conservation, waste reduction, TDM, and carbon offsets. CEQA does not require an EIR to incorporate every conceivable mitigation measure or to guarantee zero impact; rather, it requires a good-faith effort to disclose and mitigate significant impacts to the extent feasible. The Draft SEIR meets this standard.

O2-19 This comment is introductory and is followed by more detailed comments regarding VMT impacts. The comment cites cases and rulings that the comment contends relate to VMT analysis.

In accordance with CEQA requirements, the Project’s analysis in the Draft SEIR employs the VMT metric and includes both baseline and cumulative conditions analysis of the Project’s potential VMT impacts utilizing VMT Guidelines adopted by the City for that purpose. Specifically, the cumulative scenario 531
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represents the year 2050 and evaluates the potential impacts of the Project in addition to other development that would occur in the future (in terms of population and employment growth included in OCTAM). See Responses to Comments O2-20 through O2-25.

O2-20 The comment reiterates their statements about non-hotel-guest use of the Project’s amenities, as related to the trip generation and service population estimates used in the Draft SEIR. See prior Response to Comment O2-6. As discussed in that response, access to the Project’s amenities is restricted to registered hotel guests pursuant to PDFs that are incorporated into the Project’s Supplemental MMRP.

O2-21 The comment requests additional clarification for consistency of the service population estimation with the Great Wolf Lodge.

The comment questions whether the guest service population estimate used in the VMT analysis is consistent with data from the Great Wolf Lodge and other comparable projects, and whether data regarding potential day use was considered. For responses regarding day use of the Project’s amenities, please see Response to Comment O2-06.

Regarding consistency with the Great Wolf Lodge resort in Garden Grove mentioned in the comment, that resort also offers guests a fully immersive experience. Information provided to City staff via phone communication indicates that Great Wolf Lodge averages approximately 3.0 persons per room (AustinHarris, pers. comm., n.d.). Although per-room occupancy data was not readily available for specific hotels, because the Project is smaller in scale than Great Wolf Lodge, the regional average of 2.5 persons per room was used as a good-faith basis for estimating the guest service population. A lower occupancy per room results in a lower service population (i.e., denominator used in the VMT calculation) and therefore results in a higher VMT per service population.

Regarding hotel occupancy rates, data published by the American Hotel & Lodging Association reports that the nationwide hotel occupancy rate in 2019 was 65.9%, with projected 2023 occupancy of 63.8%.

California occupancy rates are notably higher, with 2019 occupancy at 74.9% and projected 2023 occupancy at 73.8% (AHLA 2023). Because resort uses of this nature tend to be seasonal and the Project would not be expected to operate at full capacity year-round, an occupancy rate of 80% was used as a reasonable assumption, which is slightly higher than both the national average and the California average. The City’s VMT technical expert’s use of relevant source data and engineering judgment led to the selection of the 80% occupancy rate. No further analysis is required.

O2-22 The comment seeks clarification of the Draft SEIR’s employee estimate of 446 employees. The comment suggests that the number is inflated, stating that the allegedly inflated estimate results in an understatement of the Project’s VMT impact and as a result reduces the mitigation required.

The Draft SEIR explains the basis for the employee estimate on page 4.2-14 and in the VMT Memorandum in Appendix D to the Draft SEIR. In accordance with the City’s VMT Guidelines, the VMT analysis utilized OCTAM, which is the transportation analysis model maintained by the Orange County Transportation Authority. OCTAM was also used to evaluate the potential VMT impacts of other resort/hotel uses in Orange County, including the DisneylandForward project.

The Draft SEIR explains that OCTAM does not have a modeling category for “hotel employment” or “resort hotel employment.” To estimate the number of employees for the proposed Project, therefore, 532
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the City’s technical experts researched other transportation models. One model, utilized because it represents a good fit for the Project, was the SANDAG transportation model (SANDAG Model), maintained by the San Diego Association of Governments (SANDAG). This is because the San Diego region has a number of hospitality uses with features and operations similar to the proposed Project, including several destination and non-destination hotels. The closest fit from the SANDAG Model land use input file for these purposes was “High Rise Hotel.” The applicable input for “High Rise Hotel” from the land use input file was used for calculating employment densities (SANDAG 2023) by the City’s technical experts.

The SANDAG Model land use input file utilizes a ratio of 1 employee per 1,550 square feet to determine the total number of employees in the “High Rise Hotel” use. Here, the VMT evaluation used the building area of 691,693 square feet for the Project size. Using 691,693 square feet, divided by 1,550 feet per employee, yields 446 employees. This includes part-time and full-time employees.

The comment questions the use of the gross building square footage when applying the SANDAG model. The SANDAG methodology for employment estimation relies on building square footage or area as the basis for estimating employees. SANDAG gathered and compiled real-world information from operating developments to identify the square-footage-based formula for estimating the number of employees. It uses total building area or rentable building area (where available) to estimate employment density datasets for non-residential uses, including hotels. Therefore, the Project’s building area was used to estimate the number of employees. The comment offers the opinion that the City should ignore the SANDAG methodology and instead exclude all gross floor area associated with the Project’s parking garage from the Project’s gross square footage for purposes of estimating employment numbers. However, using the incorrect inputs suggested by the comment would undermine the credibility of the SANDAG model results because it disregards the basic building-squarefootage-based methodology to identify an employment density for high-rise hotels. Excerpts from SANDAG ABM2+ Enhancements Final Report, 2.0 Employment Densities, Appendix A, Land Use Definitions, and Appendix B Table 38: Square Footage Based Employment Densities (SANDAG 2022) including spreadsheet with land use inputs (SANDAG 2023) used in the Project’s analysis have been provided as attachments to Appendix A, Employee VMT Estimation for Site B-2 Hotel Project Memorandum (Employee VMT Memo).

With respect to the SANDAG employee estimation methodology and the Draft SEIR’s reliance on 691,693 square feet as the building square footage, the Draft SEIR conservatively used a lower Project building square footage than that used for the GHG emissions analysis. As relevant to this comment, the VMT impact analysis involves a service-population-based calculation. As the comment recognizes, using higher employment numbers could actually reduce the VMT per-service-population results. While use of the higher building-square-footage number for VMT would have been proper, it would have resulted in only 18 more employees. The Draft SEIR’s arguably slight underestimation of employees (and corresponding slight overestimation of the Project’s VMT per service population) is a conservative approach that does not necessitate a modification to the SEIR.

In an abundance of caution, the City’s VMT experts compared the number of employees generated by the SANDAG model against other relevant sources of employment generation data. Those other sources relied on a per-hotel-room formula that specified that employee ratios can vary between 0.8 and 1.2 employees per room (see City of Hotels 2025). As applied to the proposed Project, the number of employees could range between 400 and 600 employees for a 500-room hotel. This range validates 533
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the SANDAG derived estimate of 446 employees, especially as the SANDAG rate was specifically established for a high-rise hotel like the Project.

The comment compares the SANDAG employee ratio to the ratio provided in the City of Los Angeles (LA) VMT calculator. The City of LA VMT calculator is a highly customized tool based on the 2016 City of LA Travel Demand Forecasting Model. Specifically, one item to note is that the jobs per unit for a hotel and motel are the same at 0.5 employees per room (LADOT & DCP City of LA VMT Calculator Documentation p. 11). The Project is substantially different from a typical hotel/motel found in the City of Los Angeles in terms of amenities and ancillary uses. Typically, a motel would include a small breakfast area and not any of the substantial amenities that will make the Project a destination resort.

Similarly, some larger hotels might have restaurants or meeting facilities, but again they would not include the Project’s combination of ballroom, meeting space, food, arcade, themed amenities, and spa uses. Therefore, because the SANDAG model includes an employment generation formula established for high-rise hotels like the Project, substantial evidence does not support the comment’s argument that the Draft SEIR should have instead used the City of LA methodology.

See Appendix A, Employee VMT Memo, for additional, clarifying information that further validates the methodology and expert conclusions summarized in the Draft and Final SEIR.

Therefore, the use of 446 employees properly estimates the VMT impact of the Project. As shown in the Project’s VMT analysis in the Draft SEIR and Appendix D, the VMT per employee is estimated as

15.3 VMT per employee, which is above the City’s VMT significance threshold of 14.6 VMT per employee and therefore requires mitigation. The VMT analysis recommends two mitigation measures (MM-TRA-1 and MM-TRA-2) that are feasible and would reduce the Project’s VMT impact from its employees to less-than-significant levels. Additional VMT reduction measures are included as part of MM-GHG-5. The Project does not require mitigation measures in addition to those currently identified in the Draft SEIR.

O2-23 The comment asks for clarification regarding the Project VMT analysis and use of OCTAM. The Project’s VMT assessment was prepared in accordance with the City’s VMT Guidelines and utilized OCTAM, the model recommended by the City’s VMT Guidelines for detailed VMT analysis (City of Garden Grove 2020, p. 19). The City’s VMT Guidelines require a project’s VMT analysis to be conducted using the metric of service population and, if appropriate, using the metric of resident or employee (City of Garden Grove 2020, pp. 16, 20). The Project’s VMT analysis goes above and beyond the City’s VMT Guidelines in that it evaluates VMT per service population as well as VMT per employee (Draft SEIR, Appendix D, VMT Memorandum, PDF p. 4).

The comment suggests that by comparing the Project to a retail use for VMT analysis purposes, the VMT study concedes that the Project may generate above-average occupancy compared to a typical business or tourist hotel in the City. The City VMT Guidelines state that “in some cases, it may be appropriate to extract the Project-generated VMT using the production-attraction matrix” and that “the City should evaluate the appropriate methodology based on the project land use types and context” (City of Garden Grove 2020, p. 20).

Conservatively, the VMT evaluation chose to employ the Production/Attraction, or PA, method alongside the OD method. The retail comparison in the VMT Memorandum was not a statement about the Project’s expected occupancy levels; it was a methodological explanation for why both the OD and PA VMT methods were utilized. As explained in the VMT Memorandum, the hotel use is similar to retail in 534
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the sense that guests may choose to stay at other hotels if this Project were not available, just as shoppers may go elsewhere if a particular retail center is not there (Draft SEIR, Appendix D, VMT Memorandum, p. 2). This characteristic means that, like retail, the Project generates a significant number of customer trips that are best captured through the OD method. At the same time, the hotel is similar to an office use in that employees commute to work, which is best captured through the PA method. By applying both methods, the VMT analysis accounts for both guest and employee trips. This methodological choice does not reflect anything about the Project’s anticipated occupancy levels, which are addressed separately in Response to Comment O2-21.

The comment argues that using the City boundary for the VMT analysis artificially truncates the review, given Project’s potential regional draw. The comment’s assertion that a project with a regional draw requires a different approach to VMT analysis than that used in the Draft SEIR demonstrates a misunderstanding of the purpose and function of the boundary method approach. The VMT Memorandum directly addresses this issue and explains why the City boundary is appropriate for this Project (Draft SEIR, Appendix D, VMT Memorandum, p. 2, footnote 3). The SEIR’s use of the City boundary to evaluate the Project’s effect on VMT does not mean the VMT analysis assumes that all Project guests will come from the City. The Draft SEIR does not make such an assumption. The boundary methodology evaluates all trips, including those that do not begin or end within the City boundaries. The Draft SEIR recognizes that the proposed Project is a destination resort hotel, which makes it different than a regional shopping center or office park. With all the amenities that will be offered at the hotel, Project guests can arrive and largely remain on site. The VMT analysis recognizes this core element of the Project and considers the Project’s location within Orange County, its regional accessibility via Interstate 5 and State Route 22, its proximity to John Wayne Airport, its proximity to nearby destinations such as Disneyland Resort, and the fact that most guests are anticipated to visit the Project with the specific intent to enjoy the Project’s on-site amenities and attractions (Draft SEIR, Appendix D, VMT Memorandum, p. 2, footnote 3). These factors distinguish the Project from traditional business hotels and limited-amenity tourist hotels where the hotel itself is not the destination. Those other types of hotels typically offer a place to stay for a night or more. However, other businesses and places are the primary destinations for those visitors and the trips generated by those guests are more likely to be dispersed across a wider geographic area and a larger boundary for those types of hotels might therefore be more appropriate. For example, the Great Wolf Lodge estimated that only 5% of its guests visit Disneyland (Austin-Harris, pers. comm., n.d.). Additionally, if guests choose to visit other attractions, another benefit of the Project is that guests can avail themselves of the public shuttle that offers a convenient means for guests who drive to the Project to visit other tourist attractions, such as Disneyland, without having to incur the cost and hassle of driving their own vehicle. The City boundary thus captures the relevant trip endpoints accurately (Draft SEIR, Appendix D, VMT Memorandum, pp. 2, 4).

The comment argues that the City’s VMT Guidelines do not include hotel guests in the service population metric, and that the VMT Guidelines require reasonableness checks of model outputs to ensure the proposed development’s effect is accurately captured.

The City’s VMT Guidelines define service population as population plus employment (City of Garden Grove 2020, p. 16). The City’s VMT Guidelines were developed for standard land uses such as residential, office, retail, and local-serving hotels. A destination resort hotel of this type, which attracts a significant guest population in addition to its employees, presents a unique circumstance, and the 535
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VMT Guidelines did not include a specific metric for such resort hotels. Consistent with the VMT Guidelines’ requirement that “all assumptions and methodologies of the VMT analysis are subject to review by the City Traffic Engineer” (City of Garden Grove 2020, p. 16), the VMT analysis was developed in consultation with City staff to ensure that the methodology appropriately captured the Project’s specific characteristics.

Including guests in the service population for the Project is the proper approach. OCTAM does not have a separate category for hotel guests (Draft SEIR, Appendix D, VMT Memorandum, PDF p. 3). When employees are input into the Project’s traffic analysis zone, the model automatically generates trips for both employees and guests (Draft SEIR, Appendix D, VMT Memorandum, PDF p. 2). This is because OCTAM treats hotel employment as service employment, a land use type that generates both worker commute trips and customer trips. Guest trips therefore appear in the model output automatically, as part of the total VMT figure. Because guest trips are included in the total VMT (the numerator), excluding guests from the service population (the denominator) would produce misleading results. Including guests in the service population ensures that the ratio accurately reflects the Project’s projected VMT efficiency. If guests were excluded from the denominator while their trips remained in the numerator, the ratio would be distorted. Including guests in both the numerator and denominator produces a more accurate and complete picture of the Project’s VMT per service population.

Additionally, as the comment notes, the City’s VMT Guidelines require that model outputs include reasonableness checks of productions and attractions to ensure the proposed development’s effect is accurately captured (City of Garden Grove 2020, p. 19). This was done with the Draft SEIR’s analysis.

The Project’s VMT analysis is based on both Project Generated VMT and Project Effect on VMT. While the additive method (where Project socioeconomic data is added to the existing traffic analysis zone) can calculate Project Effect on VMT, it does not isolate the Project to calculate Project Generated VMT.

The modeling for the Project therefore necessitated the creation of a Project-specific traffic analysis zone (TAZ), contrary to what the comment argues. The number of trips generated by the Project’s TAZ i.e., 3,262 daily trips (shown in Appendix C, CalEEMod Output Files, Section 5.9.1, pp. 260–261)—was compared to ITE trip generation estimates for the proposed uses (using a 5.84 daily trips per room rate for a hotel per the most recent ITE Trip Generation Manual (2025). Using ITE, a 500-room hotel is estimated to generate 2,920 daily trips. This result demonstrates that the model presents a conservative (higher) estimation of trips for purposes of the VMT analysis that is consistent with, and within a reasonable range of, what using ITE would have generated (i.e., +/− 10%). Because trip numbers generated by the model are higher, they more than adequately and sufficiently account for employee trips that are anticipated for the Project compared to a typical hotel. See Response to Comment O2-10 for a further discussion of the number of Project trips and VMT for the proposed uses.

The comment also suggests that custom theme-park-related trip rates should have been used, similar to the approach used for the DisneylandForward project. As discussed in Responses to Comments O2-08 and O2-10, DisneylandForward includes a public-facing theme park and amusement facilities that attract a significant, independent day-visitor population. The proposed Project has no equivalent public-facing theme park or amusement facility that will be accessible by anyone other than registered hotel guests, pursuant to PDFs incorporated in the Project’s Supplemental MMRP. Custom theme-park trip rates are therefore not applicable. The Project’s VMT analysis is consistent with the City’s VMT Guidelines. No revision to the Draft SEIR is required.
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O2-24 The comment asserts that the Draft SEIR failed to incorporate additional TDM measures that would be relevant to the Project’s consistency with various General Plan Air Quality and Circulation Element goals and policies.

The Draft SEIR incorporates feasible and enforceable TDM mitigation measures that directly address the Project’s VMT impacts and are consistent with the General Plan policies identified in the comment.

MM-TRA-1 implements a commute trip reduction program for employees, consistent with General Plan policies promoting TDM and reduced vehicle trips. MM-TRA-2 provides end-of-trip bicycle facilities, consistent with General Plan policies promoting bicycle access. MM-GHG-5 promotes transit use and walkability for guests, consistent with General Plan policies encouraging alternative transportation modes. Together these measures reduce the Project’s VMT impacts to less-than-significant levels and demonstrate consistency with the applicable General Plan provisions.

CEQA does not require adoption of every available TDM measure. CEQA only requires those that are feasible and necessary to reduce significant impacts to a less than significant level. The Project’s VMT impacts have been reduced to less than significant levels through the adopted mitigation measures.

The reference to additional General Plan policies does not demonstrate a conflict between the Project and those policies. It merely suggests that additional measures could have been included. That is not a deficiency under CEQA. The comment’s specific TDM recommendations are addressed in Responses to Comments O2-39 through O2-51.

No revision to the Draft SEIR is required.

O2-25 This comment is a concluding recommendation that the SEIR address the issues raised in Comments O2-19 through O2-24 and that further mitigation be considered. Please see Responses to Comments O2-19 through O2-24 for responses to the issues summarized in this memorandum.

O2-26 This comment is introductory and paraphrases general CEQA concepts regarding the required alternatives analysis. The comment argues that the Draft SEIR failed to consider an alternative that includes at least some level of affordable housing on site. As discussed in Responses to Comments O2-27 through O2-35, the Draft SEIR’s alternatives analysis was prepared in compliance with CEQA and the Writ of Mandate. The Draft SEIR considered a reasonable range of alternatives, including a noproject alternative and a reduced-intensity hotel alternative, and evaluated whether a housing alternative would be feasible and capable of meeting the Project’s objectives. The Draft SEIR meets CEQA’s requirements for alternatives analysis.

O2-27 The comment states that the Draft SEIR should have considered a mixed-use alternative with both hotel and residential/affordable housing components.

CEQA states that alternatives must “attain most of the basic objectives of the project” and “achieve the project’s fundamental purpose.” A lead agency is permitted to reasonably define the underlying project purpose and is not required to analyze an alternative that cannot achieve the basic goal of the project.

The unequivocal purpose of the proposed Project is to develop a themed, destination resort hotel. The Project’s objectives include, among others, the following: (1) develop a destination hotel; (2) provide for an enhanced overnight guest experience with themed amenities attractive to families and other visitors who will use the Project as a tourist destination location in and of itself; (3) implement the Project site’s International West Mixed Use General Plan designation by including hotel, entertainment 537
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and resort elements to promote guest visits of multiple days; (4) develop a destination hotel in a location with convenient access to public transit and a shuttle system that connects the Project to other tourist attractions in the area, including those along the Harbor Boulevard resort corridor; (5) support increased tourism in the City while also complementing other tourist destinations in surrounding communities; (6) generate a material amount of transient occupancy and property tax revenue for the City; and (7) develop a facility of sufficient size to attract a partnership with a national or international theme park franchise (Draft SEIR, Section 1.4.2, p. 1-3).

As a matter of public policy, the City has identified this property for entertainment/resort/tourism uses.

The Project site is in an area of the City designated as International West Mixed Use (Focus Area A) along Harbor Boulevard, generally between Chapman Avenue on the north and the Garden Grove Freeway (State Route 22) on the south. According to the Garden Grove General Plan (City of Garden Grove 2008), this area:

Holds critical importance for the City for revitalization and economic stimulus purposes.

Ideally situated south of the Disneyland Resort district, this area has opportunities to capitalize and expand tourist-based and entertainment-related uses. Full-service hotels and new restaurants have been constructed, predominately at the intersection of Chapman Avenue and Harbor Boulevard. An Economic Impact and Master Plan for the International West Resort Area was prepared to identify strategies to complement established entertainment, hospitality, and sports venues in the surrounding areas by planning for three entertainment centers connected by themed commercial services and retail uses, entertainment venues, hotels, theaters, and parks.

As the Draft SEIR reflects, the Project site’s 3.72-acre property is well situated for the Project’s proposed resort hotel use, with frontage along Harbor Boulevard for themed entertainment uses within easy driving distance of Disneyland Resort and within easy proximity of existing tourism based uses in the City (Draft SEIR, Section 3.3, Project Objectives, p. 3-3). The Project site is a prime location for a themed hotel, which is consistent with the long-term vision of the City.

Further, the comment erroneously states that the Draft SEIR did not evaluate a mixed-use alternative with residential and hotel uses. As the Draft SEIR analyzed and disclosed, both an exclusively residential and a mixed-use housing alternative are addressed in the “Alternatives Considered but Rejected” section (Draft SEIR, Section 6.3.4, Residential Alternative, p. 6-4, and Section 6.3.6, MixedUse Development Alternative, pp. 6-5 and 6-6). The SEIR demonstrates that neither of those options were feasible or capable of meeting the Project’s objectives, nor would the options clearly reduce potentially significant VMT or GHG impacts associated with the Project. The Project site is 3.72 acres in size and would be entirely consumed by a 500-room hotel, themed pool deck, parking garage, and amenities. There is no land available for housing on the Project site without fundamentally reducing the hotel size. A reduced hotel size alternative was considered and rejected in the Draft SEIR because it would not meet most of the Project’s basic objectives. A mixed-use alternative that reduces the hotel to accommodate housing would not attain the primary objective of a fully programmed destination resort hotel. Contrary to the comment’s assertion, the Project objectives were not artificially constrained to exclude housing.

Although the International West Mixed Use designation permits a mix of uses, including commercial, entertainment, hotel, and residential, as a matter of public policy and local land use authority, the City 538
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is not required to maximize residential development on every site within that designation. The City’s state-compliant 2021–2029 Housing Element, adopted October 10, 2023, includes a detailed housing site inventory identifying thousands of parcels throughout the City that are appropriate for affordable and market rate housing development. Specifically, the City has identified more than 2,400 underutilized properties not meeting their full economic potential that could be developed for affordable housing. This site is not among them. Rather, it has long been designated for resort and entertainment uses, consistent with the City’s long-term vision for the International West Mixed Use corridor. Because the City and the state have determined that the sites identified in the General Plan Housing Element are sufficient for the City to potentially meet its share of regional housing needs, the comment lacks merit.

O2-28 The comment argues that the Draft SEIR should have considered whether the Project must include affordable housing to be consistent with specified plans and policies, including CAPCOA Measures T-1 and T-4, SCAG RTP/SCS policies, General Plan provisions, and the CARB Scoping Plan. See Responses to Comments O2-29 through O2-31 regarding SCAG RTP/SCS policies, General Plan provisions, and the CARB Scoping Plan. This response specifically focuses on CAPCOA Measures T-1 and T-4.

CAPCOA is a nonprofit professional association of air pollution control and air quality management district officers. It is not a state agency and does not have any regulatory authority. For this reason, CAPCOA measures are voluntary guidance tools, not mandatory regulatory requirements. The CAPCOA Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity (CAPCOA 2024) is a resource that lead agencies and project applicants may consult when identifying and quantifying potential GHG emission reductions for CEQA compliance purposes, but it does not establish any legal or regulatory standards. Neither CEQA nor any state regulation requires a project to evaluate its consistency with, or to adopt measures in, CAPCOA’s guidance.

The CAPCOA measures referenced in the comment, T-1 (Increase Residential Density) and T-4 (Integrate Affordable and Below Market Rate Housing), are transportation-related measures designed to reduce VMT by locating housing close to jobs, services, and transit. The referenced measures are designed for residential projects and are not applicable to the proposed Project. They address how to site and design housing projects to minimize VMT. The measures do not require a commercial project to include housing. See Response to Comment O2-27 for a discussion of the public policy aspects of this comment and the Draft SEIR’s alternatives analysis supporting the rejection of a residential alternative on CEQA grounds.

The proposed Project is a hotel development on a site designated for visitor-serving and resort uses in the City’s General Plan. It is consistent with that designation. The fact that the Project does not also include affordable housing does not render it inconsistent with CAPCOA’s measures regarding residential projects.

Although the Project does not include residential uses, it advances the GHG emissions reduction and VMT minimization goals that inform CAPCOA Measures T-1 and T-4 through other means identified in the Draft SEIR, including its location and design. The Project site is located along a major transportation corridor near existing transit, providing employment opportunities in proximity to transit and services.

As the Draft SEIR analyzes and discloses, these characteristics align with CAPCOA principles of reducing VMT through infill development and transit accessibility. 539
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O2-29 The comment offers policies from SCAG’s 2024 Connect SoCal RTP/SCS and implies that the Project must include affordable housing to be consistent with SCAG’s regional planning framework.

The opinions offered are based on a misapplication of the Connect SoCal plan and the specific RTP/SCS measures identified. The 2024 Connect SoCal document explains that it “does not directly implement or construct projects or have land use authority” (SCAG 2024a). The document also explains that “[d]ecisions about land use and growth, such as what type of housing, offices, or retail get built and where, rests fundamentally with each local government – sometimes referred to as ‘local land use authority.’ A given city or county articulates its land use planning through general plans, specific plans, and other documents (such as zoning ordinances or development agreements)” (SCAG 2024a, p. 47).

The Draft SEIR includes an analysis of the Project’s consistency with applicable RTP/SCS provisions.

As reflected in Draft SEIR Table 4.1-6, Project Potential to Conflict with Connect SoCal 2024, the Project as mitigated does not conflict with Connect SoCal. Unlike the comment, Table 4.1-6 considers the RTP/SCS policies in context, including the Project site’s location, land use designation, and purpose.

SCAG’s Connect SoCal policies are regional planning goals. They are not mandatory requirements and not every measure identified in the document is applicable to every project or property. A project is consistent with a regional plan if it does not substantially conflict with the plan’s relevant policies. A project need not advance every goal contained in the plan to be found consistent, because different goals serve different purposes and many relate to specific types of activities. The housing-related policies cited in the comment are directed at SCAG, local governments, and regional partners as aspirational goals for increasing housing production across the region on sites the local land use authorities have identified for housing development. They do not require individual commercial projects to include residential components.

The Project affirmatively advances several Connect SoCal objectives, including the following:
▪ Promoting infill development in a built-out urban area, reducing pressure for greenfield development ▪ Providing employment opportunities near existing transit and services, helping reduce regional commute distances
▪ Enhancing mobility options through TDM measures and proximity to high-frequency transit routes The City addresses its regional housing obligations, and by extension Connect SoCal 2024’s residential goals and policies, through its state-compliant 2021–2029 Housing Element (City of Garden Grove 2023), which identifies more than 2,400 underutilized properties throughout the City that are appropriate for affordable housing development. That is the appropriate mechanism for meeting regional housing needs, not conditions imposed on individual commercial projects the City has long identified as important to the City’s economic development goals and policies.

In summary, the Project is consistent with the City’s General Plan and advances regional sustainability goals through infill development and transit accessibility. The Draft SEIR also demonstrates that the Project, with mitigation, does not conflict with the RTP/SCS. No revision to the Draft SEIR is required.

O2-30 The comment asserts that promoting mixed-use development aligns with various Garden Grove General Plan provisions in the Safety, Land Use, Community Design, Circulation, Economic Development, Air Quality, and Housing Elements and references policies related to integrated land uses, improved mobility, air quality benefits, and housing diversity.
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Established law regarding general plan consistency does not require each individual project to satisfy every policy stated in a general plan, and state law does not impose such a requirement. General plans reflect a wide range of competing interests, and agencies are given broad discretion to construe the plan’s policies in light of the plan’s purposes and to balance the plan’s policies when weighing them.

The Draft SEIR includes a General Plan consistency analysis that evaluates the relevant CEQA topic areas. That discussion demonstrates that the Project is consistent with applicable General Plan provisions. Unlike the comment, Draft SEIR Table 4.1-8, Project Potential to Conflict with City of Garden Grove General Plan, considers the General Plan in context, including the Project site’s location and the Project’s land use designation and purpose. As that discussion and analysis demonstrates, the Project site is designated in the General Plan for visitor-serving commercial uses, and the proposed Project is consistent with that designation.

As demonstrated in Draft SEIR Table 4.1-8 and the associated analysis, the Project as mitigated does not conflict with the applicable General Plan provisions relevant to the CEQA topic areas that the Writ required the SEIR to address. For example, the Project was found to be consistent with the General Plan for the following reasons:
▪ The Project is located on an infill site along a major transportation corridor, near existing transit, which supports mobility and air quality goals.
▪ It provides visitor-serving uses and employment opportunities, consistent with the Economic Development and Land Use Elements.
▪ The Project incorporates PDFs and mitigation measures that promote sustainability, energy efficiency, and reduced vehicle trips, aligning with Air Quality and Circulation Element policies.

With respect to the comment’s suggestion that the Project must include housing to comply with the General Plan, the General Plan does not support that argument. As discussed in Response O2-27, the City’s housing objectives are addressed through other designated areas in the City identified in the Housing Element. Therefore, the Project site is not needed to meet General Plan housing standards.

The Draft SEIR’s determinations of consistency are based on substantial evidence. No revision to the SEIR is required.

O2-31 The comment states that CARB’s 2022 Scoping Plan Appendix D (Local Action), building on the 2017 Scoping Plan Appendix B (Local Action), urges numerous local strategies related to mixed-use development and affordable housing, and recommends that the SEIR evaluate the Project’s consistency with these measures.

As noted in CARB’s 2022 Scoping Plan, Appendix D is not regulatory but is intended to provide clarification on specific topics for planners, CEQA practitioners, and community groups regarding challenges local jurisdictions face when implementing GHG reduction strategies or approving housing projects. It is not exhaustive and focuses primarily on climate action plans and local authority over new residential development.

The comment does not acknowledge that the Draft SEIR includes a Scoping Plan consistency analysis.

As reflected in Draft SEIR Section 4.1 and Table 4.1-7, Project Potential to Conflict with 2022 Scoping Plan, the Project as mitigated does not conflict with applicable Scoping Plan strategies. Unlike the 541
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comment, the Draft SEIR’s analysis considers the relevant context, including the Project site’s location, land use designation, and purpose. Specifically, the Project site is an infill location designated for visitor-serving commercial uses under the City’s General Plan. Consistent with CARB’s overarching goals, and just by way of some examples, the Project incorporates the following strategies:
▪ Infill Development: The Project utilizes an existing urban site, reducing pressure for greenfield development and supporting compact growth patterns consistent with CARB’s land use strategies in both the 2017 and 2022 Scoping Plans.
▪ Transit Accessibility and VMT Reduction: The site is located along a major transportation corridor with high-frequency transit service. The Project incorporates TDM measures, including commute trip reduction programs, bicycle facilities, and guest amenities that encourage walking and transit use, consistent with CARB’s local action strategies to reduce VMT (see MM-TRA-1, MM-TRA-2, and MM-GHG-5).
▪ Energy Efficiency and Decarbonization: The Project includes advanced HVAC systems, highperformance glazing, and on-site solar photovoltaic panels, aligning with CARB’s goal of transitioning to clean energy and reducing building-related emissions (see MM-GHG-7 and MM-GHG-9). ▪ Water and Waste Reduction: The Project includes measures to conserve water and divert waste, reducing indirect emissions consistent with CARB’s short-lived climate pollutant reduction strategies (see MM-GHG-10 and MM-GHG-11).

Because the Draft SEIR evaluates and discloses the Project with imposition of the mitigation, the Project does not conflict with the CARB Scoping Plan.

As discussed in Response to Comment O2-27, the City’s housing obligations are addressed through other designated areas identified in the City’s Housing Element. No revision to the Draft SEIR’s consistency analysis is required.

O2-32 The comment suggests that the Draft SEIR requires a jobs–housing analysis. The comment states that this is relevant to the SEIR’s VMT and GHG analysis.

A formal jobs–housing balance analysis is not required by CEQA. CEQA requires that an EIR discuss a project’s potential growth-inducing impacts, including the housing needs of new employees and the probable location of that housing (CEQA Guidelines Section 15126.2[e]; Napa Citizens for Honest Government v. Napa County Board of Supervisors [2001] 91 Cal.App.4th 342, 370; Defend the Bay v. City of Irvine [2004] 119 Cal.App.4th 1261, 1266). Under established CEQA case law, when a project accommodates growth already contemplated in a city’s general plan, it does not constitute a growth-inducing impact requiring detailed analysis. In Clover Valley Foundation v. City of Rocklin (2011) 197 Cal.App.4th 200, 225–228, the court distinguished between “inducing new growth” and “merely accommodating growth for which the City has already planned,” and agreed with the City’s position that growth-inducing impacts are problematic only “where a project is inducing growth to occur which is not already planned for.”
The Project is a destination hotel resort on an infill site on a property that has been General Plan designated as IW, which contemplates just such a use. As acknowledged by the comment, the Draft SEIR includes an evaluation of the Project’s potential growth-inducing impacts. That analysis demonstrates that any growth attributable to the Project is consistent with employment growth already 542
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projected in local and regional land use plans. According to the Connect SoCal 2024 Demographics and Growth Forecast Technical Report prepared by SCAG, the City’s total employment was 60,700 in 2019, with an anticipated increase of 4,300 jobs by 2035 and an additional 5,500 jobs by 2050 (SCAG 2024b, p. 41). The Project’s 446 employees represent approximately 10% of the anticipated job growth by 2035 and approximately 5% by 2050. This is well within projected growth already planned for and analyzed at the programmatic level (Draft SEIR, Section 5.4, Growth-Inducing Impacts).

SCAG’s Connect SoCal 2020 plan projected similar employment growth for Garden Grove, forecasting an increase from 57,800 jobs in 2016 to 68,200 jobs by 2045, a total increase of approximately 10,400 jobs (SCAG 2020). The Project’s 446 employees represent approximately 4.3% of that projected growth. The consistency between the 2020 and 2024 Connect SoCal employment projections for Garden Grove confirms that the Project’s employment falls well within planned growth under both plans.

SCAG is also the agency responsible for preparing the Regional Housing Needs Assessment (RHNA) allocation within the Southern California region. SCAG’s 6th cycle RHNA allocation was prepared using employment and household growth projections from the Connect SoCal 2020 plan. Because SCAG’s RHNA methodology specifically incorporates employment growth projections, the housing demand generated by projects like this one is already factored into Garden Grove’s RHNA allocation. The City’s Housing Element was developed in response to that RHNA allocation and identifies sufficient sites throughout the City to meet the resulting housing demand. The Project site is not one of the properties identified in the Housing Element as required for the City to meet its RHNA obligations. Therefore, as the Draft SEIR analyzes and discloses, the Project would have less than significant growth-inducing impacts.

No revision to the Draft SEIR is required.

O2-33 The comment identifies what it represents as California Housing and Community Development (HCD) statistics regarding housing production in the City.

This comment does not identify a deficiency in the Draft SEIR’s CEQA analysis. The City’s progress toward its RHNA allocation is a housing policy matter, not a CEQA significance threshold. Senate Bill 166 and Housing Element Program 8 (no net loss) are designed to prevent the loss of sites identified in a jurisdiction’s housing element to accommodate its RHNA allocation. The Project site is not identified in Garden Grove’s Housing Element as a site for affordable housing development.

Furthermore, the proposed Project does not remove, demolish, or convert any existing affordable housing units. Accordingly, approval of this Project does not trigger Senate Bill 166 or the no net loss requirement. As discussed in Response to Comment O2-27, the City’s Housing Element identifies more than 2,400 underutilized properties throughout the City that are appropriate for affordable housing development. The City’s progress toward its RHNA allocation is addressed through those designated sites. No revision to the SEIR is required.

O2-34 The comment raises general legal arguments about the relationship between feasible mitigation, Project alternatives, and the adoption of a statement of overriding considerations under CEQA. The comment does not identify any specific deficiency in the Draft SEIR’s analysis or present substantial evidence that would affect the City Council’s future consideration of a statement of overriding considerations. 543
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As explained in Responses to Comments O2-27 through O2-33 and O2-35, a mixed-use housing alternative was neither feasible nor capable of meeting most of the Project’s objectives. As discussed in Responses to Comments O2-6 through O2-25, the Draft SEIR’s impact analysis is supported by substantial evidence. No revision to the Draft SEIR is required.

O2-35 This comment is a concluding recommendation regarding Section D of the comment letter. Please see Responses to Comments O2-26 through O2-34 for applicable responses. No revision to the Draft SEIR is required.

O2-36 The comment is an introductory paragraph that summarizes the author’s arguments regarding CEQA’s mitigation requirements. The comment asserts that the Project’s potentially significant GHG emissions impacts could be further mitigated through modifications to the MMRP.

The City acknowledges that mitigation is a core component of CEQA analysis and that mitigation measures must be enforceable and not illusory. The Project’s mitigation measures meet those and all relevant CEQA standards. Each measure is clearly defined, enforceable through the Supplemental MMRP, and except as disclosed in the Draft SEIR with respect to the GHG offset credit mitigation measure, supported by substantial evidence demonstrating feasibility and effectiveness.

The comment’s disagreement regarding the scope or content of certain measures does not render them defective under CEQA. CEQA requires that mitigation measures be feasible and capable of substantially reducing a significant impact, not that they eliminate all impacts or incorporate every conceivable strategy (CEQA Guidelines Section 15126.4[a][1]). Courts have affirmed that lead agencies have discretion to determine appropriate mitigation, provided there is a nexus and rough proportionality between the measure and the impact addressed This principle ensures that mitigation is reasonably related to a project’s impacts and not excessive or unrelated.

The Draft SEIR includes a suite of GHG mitigation measures (MM-GHG-1 through MM-GHG-15) that address the Project’s primary emission sources (energy and transportation) through feasible on-site strategies and, where necessary, carbon offsets. These measures are enforceable and will be implemented as part of the Project, consistent with CEQA and relevant case law. However, as the Draft SEIR discloses, uncertainty exists regarding the future availability of carbon offset credits and those credits serving as feasible and effective mitigation. Therefore, the Draft SEIR discloses that, notwithstanding the imposition of MM-GHG-15 requiring carbon offsets, the Project’s GHG impacts were determined to be significant and unavoidable.

The Draft SEIR satisfies CEQA’s requirements for enforceable, non-illusory mitigation measures. The comment’s opinion regarding additional measures does not invalidate the adequacy of the mitigation imposed by the SEIR or the analysis and determinations in same.

O2-37 The comment states that PDFs should be explicitly included in the MMRP. In response, Draft SEIR lists the applicable PDFs and provides that the “following summarizes the Project Design Features (PDFs) that are incorporated into the Project relative to the analysis in this SEIR and that will be included in the MMRP” (Draft SEIR, Section 3.4.3, pp. 3-4 through 3-5). As reflected in the Final SEIR, Chapter 4, the PDFs have been incorporated into the Supplemental MMRP. 544
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O2-38 The comment is introductory, stating that the SEIR’s mitigation measures are commendable but that further modifications and enhancements identified in subsequent comments are warranted.

The mitigation measures identified in the Draft SEIR (MM-GHG-1 through MM-GHG-15 and MM-TRA-1 and MM-TRA-2) were developed to address the Project’s specific potentially significant GHG and VMT related impacts and are consistent with CEQA requirements for enforceable mitigation. Although these measures share similarities with CAPCOA-recommended strategies, they have been tailored to reflect the Project’s specific construction and operational characteristics, site constraints, and regulatory context.

The City acknowledges that the CAPCOA measures are a tool that agencies can use when evaluating and mitigating potentially significant GHG and VMT impacts. However, agencies are not required by CEQA to impose CAPCOA measures in whole or in part. As CEQA requires, the mitigation measures included in the Draft SEIR provide effective and enforceable strategies to reduce GHG emissions and transportation-related impacts to less than significant levels. The comment appears to advocate for strict application of CAPCOA measures without consideration of the specific nature and circumstances of the Project. Such an approach could easily run afoul of CEQA. In contrast, the Draft SEIR evaluated potentially applicable CAPCOA measures and the Draft SEIR imposes Project-specific mitigation measures that represent a reasonable and appropriate approach based on substantial evidence and the Project’s environmental setting.

As the following responses and the Final SEIR disclose, although not required, some of the comment’s suggested modifications have been incorporated where they helped to clarify the intent of the previously drafted measures or enhanced their effectiveness. These refinements improve implementation and strengthen enforceability without altering the substance of the mitigation measures or the Draft SEIR’s analysis and conclusions. Importantly, these modifications do not require recirculation of the Draft SEIR as they do not constitute “significant new information” as defined under CEQA Guidelines Section 15088.5.

O2-39 The comment states that Draft SEIR includes several construction-related GHG mitigation measures (MM-GHG-1 through MM-GHG-3) and asserts that these may be inadequate. The comment recommends explicitly incorporating all construction-related PDFs into the MMRP, ensuring use of Tier 4 final engines where feasible, and expanding measures beyond limited equipment types (e.g., generators, cranes, compressors) to cover broader construction activities.

As discussed in the Draft SEIR Section 4.1, Greenhouse Gas Emissions, GHG mitigation measures for construction emissions are limited; however, feasible mitigation has been provided in MM-GHG-1 through MM-GHG-3.

As noted in Response to Comment O2-37, all PDFs have been incorporated into the Supplemental MMRP. As noted in Response to Comment O2-15, a notation has been added to clearly identify which CAPCOA measure from the CalEEMod worksheets are applicable to each PDF or mitigation measure.

As stated in the Draft SEIR, all PDFs were qualitative.

As to Tier 4 engines, the previously approved 2022 MND included PDF-3, which required that “All diesel construction equipment should have Tier 4 low emission ‘clean diesel’ engines (OEM [original equipment manufacturer] or retrofit) that include diesel oxidation catalysts and diesel particulate filters that meet the latest California Air Resources Board (CARB) best available control technology.” This PDF 545
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was already imposed as a performance standard in the Project’s PUD and will continue to apply to the Project if approved in connection with the City’s consideration of the SEIR. PDF-3 was not analyzed in the Draft SEIR because that measure does not serve to reduce GHG emissions. Rather, Tier 4 equipment targets criteria air pollutants, specifically oxides of nitrogen (NOx) and particulate matter.

These air quality topics are beyond the scope of the Writ and therefore the SEIR.

The third argument presented in the comment refers to MM-GHG-1 and MM-GHG-2 and their relationship to CAPCOA-1. The comment offers an opinion that the mitigation measures imposed are narrower and/or different than the corresponding CAPCOA measure. The Draft SEIR imposed feasible mitigation measures related to Project construction consistent with CEQA requirements. PDF-8 requires the use of electric-powered equipment on a broad basis where feasible, which addresses the intent of reducing emissions from construction activities. MM-GHG-1 does not supersede or limit PDF-8. Instead, MM-GHG-1 addresses a subset issue as it targets specific equipment types, such as generators, cranes, and air compressors, where electric alternatives have been determined to be commercially available and can be feasibly implemented for this Project. These combined measures ensure enforceability and practicality.

As the Draft SEIR discloses, the primary source of construction-related GHG emissions are from heavy equipment use and the temporary field office, which are already addressed through PDF-8, MM-GHG-1, and MM-GHG-2. The comment asks for an expansion of these measures, but including equipment types for which electric alternatives are not currently feasible would not be practical or enforceable.

Therefore, the Draft SEIR appropriately focuses on measures that are both effective and achievable.

To be responsive to the comment, MM-GHG-1 has been clarified to implement the original intent by requiring a construction equipment emissions minimization plan that broadly requires electrification where feasible. Notably, for purposes of identifying the GHG emission reductions the mitigation measure will achieve, emissions reductions have only been credited for the crane, generators, and air compressors, because those equipment pieces have been determined to be feasible at this stage of the CEQA process. MM-GHG-2 requires the temporary construction field office to be equipped with energy-efficient lighting and Energy Star certified heating and cooling units.

MM-GHG-1 and MM-GHG-2 address those construction components that (1) account for a substantial portion of construction emissions and (2) are under the direct control of the Applicant and its contractors. Although the edits made to MM-GHG-1 in response to the comments clarify the type of construction equipment that could be powered with electricity, the GHG emissions reductions quantified in the SEIR are conservatively limited to those known to be feasible and commercially available at the time of Project implementation. Expanding the measures to include equipment types for which electric alternatives are not currently feasible, or that are not typically specified at this stage of the CEQA process, would result in a less reliable, less conservative approach compared to the approach in the SEIR.

The final component of the comment relates to CAPCOA Measure C-1B (Use Cleaner Fueled Construction Equipment). That CAPCOA measure was evaluated for feasibility to reduce the Project’s GHG construction emissions during preparation of the Draft SEIR. The City did not impose that measure, however, for reasons that include the following:
▪ CalEEMod Limitations: In CalEEMod, “cleaner fueled equipment” under C-1B is currently limited to compressed natural gas (CNG). The Project already addresses electrification through CAPCOA 546
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Measure C-1A, which is imposed and reflected in PDF-8 (Draft SEIR, p. 4.1-32) and MM-GHG-1.

PDF-8 broadly requires the use of electric-powered equipment where feasible, which is a more effective and widely applicable strategy compared to use of CNG. Measure C‑1B’s restriction to CNG reflects an older, transitional mitigation framework, whereas Measure C‑1A is consistent with current best practice and regulatory direction in California air quality planning. Unlike electrification, CNG remains a combustion‑based technology that emits NOx, involves methane slip, and is associated with hazardous air pollutants. CARB’s 2022 Scoping Plan for Achieving Carbon Neutrality identifies widespread electrification and major reductions in fossil natural gas use as necessary to meet State air quality and climate goals, and CARB regulations further recognize methane and toxic emissions from natural gas systems as significant concerns.

Accordingly, CAPCOA Measure C‑1A represents a more stringent and policy‑consistent mitigation approach than CalEEMod Measure C‑1B, and no changes to the Draft SEIR are required. ▪ Other Cleaner Fuels: CAPCOA Measure C-1B references fuels such as renewable diesel and hydrogen, which are not explicitly modeled in CalEEMod (see CAPCOA 2024, pp. 411–413).

Renewable diesel use can also have other environmental impacts, including increased lifecycle emissions of certain pollutants (e.g., NOx) and potential upstream impacts related to feedstock sourcing and land use. Hydrogen-fueled construction equipment is currently very limited in availability and not practical for this Project.
▪ Project Measures Meet Intent: The Project meets the intent of CAPCOA Measure C-1B through PDF-8 (requiring electric equipment broadly, where feasible) and MM-GHG-1, which specifically requires the use of electric generators, cranes, and air compressors during the painting phase.

These measures provide enforceable and feasible strategies to reduce GHG emissions consistent with CEQA requirements.

For these reasons, imposing CAPCOA Measure C-1B would not provide additional meaningful reductions beyond what is already achieved through the Project’s PDFs and mitigation measures. The Draft SEIR’s approach ensures effective and practical implementation without introducing infeasible requirements.

O2-40 The comment addresses MM-GHG-3 (Construction Debris Recycling). Without support, the comment argues that MM-GHG-3 will have limited effectiveness because the site is largely vacant and there are enforcement challenges, and recommends requiring post-construction monitoring. Additionally, the comment recommends incorporating CAPCOA Measures S-4 (Recycling Wood-Based Materials) and S-5 (Sourcing Wood from Urban Reuse Programs) into the MMRP.

The Draft SEIR incorporates MM-GHG-3, which requires the recycling or salvaging of non-hazardous construction debris. Contrary to the comment, this measure as drafted applies broadly to all construction materials, not just demolition debris. Specifically, the mitigation measure imposes a requirement to first develop a plan based on identified performance criteria for approval by the City and then a requirement to, as expressed in the Draft SEIR “recycle or salvage nonhazardous construction debris such that a minimum target of 75% is achieved. This will exceed the City’s current target of 65% diversion.” Nonetheless, in response to the comment, the Final EIR will modify MM-GHG-3 to add clarifying language regarding the broad scope of the construction recycling requirements.

MM-GHG-3 Construction Debris Recycling. Prior to the start of construction, the Project’s contractor shall develop a Construction Waste Management Plan (Plan) for 547
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submittal and approval to the City of Garden Grove. The Plan shall recycle or salvage non-hazardous construction debris, such that a minimum target of 75% is achieved. This will exceed the City’s current target of 65% diversion. including but not limited to wood, metal, concrete, asphalt, and other reusable materials generated during construction activities. The contractor shall implement the Plan to achieve a minimum diversion target of 75% of non-hazardous construction and demolition debris from landfills, exceeding the City’s current 65% diversion requirement. (CAPCOA Measure S-4)
The clarifying language does not change the substance of what was already required by MM-GHG-3 as disclosed in the Draft SEIR; therefore, recirculation of the SEIR is not required under CEQA Guidelines Section 15088.5.

The comment references CAPCOA Measure S-4 in support of its argument about the need for recycling of wood-based materials. As noted above, any wood-based construction materials used during Project construction are already covered by the broad requirements of MM-GHG-3. Nothing further is required in that regard. Also, as the Project site is devoid of trees and existing structures, no tree removal or demolition of existing wood structures that would generate significant wood waste would occur.

The comment also requests that the City impose CAPCOA Measure S-5 on the Project. The comment does not offer a GHG reduction justification for inclusion of such a qualitative measure. The comment also ignores the Project’s commitment to sustainable building practices is reflected in PDF-27. That PDF prioritizes low-impact, sustainably sourced, and recyclable materials across construction and interior finishes. This includes the use of low–volatile organic compound (VOC) paints, Forest Stewardship Council–certified wood, and recycled-content flooring. PDF-27 also requires implementation of vendor standards requiring environmental product declarations and third-party certifications to verify material sustainability, selection of materials not only for their initial environmental footprint but also for durability and long-term performance. As the Draft SEIR demonstrates, the PDFs and mitigation measures could reduce Project impacts below the applicable significance thresholds, and the measures suggested in the comment would have no qualitative GHG reduction benefits. Nothing further is required.

O2-41 The comment states that the Project does not appear to include feasible construction-related mitigation measures and recommends adding CAPCOA Measures C-3 (Use Local Construction Contractors) and C-4 (Use Local and Sustainable Building Materials) to the MMRP. The comment asserts that these measures would reduce VMT and fuel consumption and align with General Plan Conservation Element goals and policies.

The comment does not acknowledge that the Draft SEIR imposed feasible VMT mitigation measures and PDFs that reduced the Project’s potentially significant impacts to less than significant. Therefore, CEQA does not require the imposition of additional mitigation as suggested in the comment. The measures in the Draft SEIR are technologically feasible, enforceable through the Supplemental MMRP, and effective in reducing GHG emissions and construction-related impacts. As discussed further below, additional CAPCOA measures suggested by the comment (e.g., Measures C-3 and C-4) were considered but determined to be either qualitative, already addressed through existing measures, or impractical to enforce under CEQA.
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CAPCOA Measure C-3 (Use Local Construction Contractors) was considered but determined not to be needed, feasible, valid, or effective for the following reasons:
▪ Economic and social considerations do not provide a quantifiable reduction in emissions. ▪ CEQA should not be used to dictate policy matters of the type addressed in this measure. Contractor selection is based on specialized expertise, safety standards, and capacity to deliver a complex project on schedule.
▪ Contractor selection is a contractual and business decision, not an environmental performance standard, making this measure unqualified as potentially binding CEQA mitigation.

CAPCOA Measure C-4 is a qualitative measure in CalEEMod and does not provide quantifiable VMT reductions. Although not relevant to the comment’s focus on VMT impacts, the Project is designed to meet Leadership in Energy and Environmental Design (LEED) accreditation standards, which include sustainable building design and material selection. This commitment is reflected in PDF-27, which prioritizes low-impact, sustainably sourced, and recyclable materials, including Forest Stewardship Council–certified wood, recycled-content flooring, and low-VOC finishes. Vendor standards also require environmental product declarations and third-party certifications to verify material sustainability. No modifications to the Final SEIR are required based on this comment.

O2-42 The comment states that MM-GHG-11 (Waste Reduction) “may be inadequate.” The comment alleges that the mitigation measure uses permissive language (“may include”) rather than mandatory (“shall include”) for program elements like recycling and organics diversion. The comment instead suggests using CAPCOA Measures S-1 and S-2 and included a list of the comment’s ideas of other steps a hotel could take related to recycling.

As noted in the 2024 CAPCOA Handbook, measures S-1 and S-2 result in potentially small reduction in GHG emissions from waste management pathways. The CAPCOA Measure S-1 states, “this measure will institute or extend recycling services to reduce the volume of landfilled waste” and CAPCOA Measure S-2, states, “this measure will implement an organics diversion program to reduce the volume of organic waste sent to landfills” (CAPCOA 2024). Neither measure prescribes specific items or diversion targets. MM-GHG-11 captures both CAPCOA measures and imposes a diversion target.

The Draft SEIR incorporates MM-GHG-11, which requires waste reduction measures, including organics diversion. Contrary to the comment’s argument, the measure includes mandatory language requiring Project compliance with a minimum diversion rate of 25% for solid waste and organics, which establishes a clear performance standard consistent with CEQA. As disclosed in the Draft SEIR, Section

4.1, page 4.1-30, California Department of Resources Recycling and Recovery (CalRecycle) data shows that hotels and lodging contribute 1.5% to the total commercial waste stream in Garden Grove (CalRecycle 2025). The CalRecycle data also shows that hotels and lodgings in Garden Grove divert approximately 19.8% of their mixed solid waste. The most recent statewide waste characterization study showed that large hotels divert 22.7% of their mixed solid waste (CalRecycle 2006). Based on these statistics, the diversion target of 25% for the Project would be above and beyond what has historically been achieved and demonstrates the Project’s commitment to waste management.

MM-GHG-11 only uses permissive language (“may include”) when identifying the non-exclusive list of options the Project could use to achieve the mandated minimum waste diversion rate. This approach 549
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is intentional to allow flexibility and innovation in achieving the required diversion rate rather than prescribing a rigid list of actions.

Although MM-GHG-11 already complies with CEQA and is consistent with applicable General Plan goals, the Final SEIR will identify some of the comment’s suggestions, such as coordination with food banks and composting facilities (CAPCOA Measure S-3), as additional options the Project could choose from to achieve the mandated waste diversion reduction rate. Those additions to MM-GHG-11 do not require recirculation of the Draft SEIR under CEQA Guidelines Section 15088.5.

O2-43 The comment asks a question about MM-GHG-4 in relation to CAPCOA Measure T-14. The comment seems to suggest that the mitigation measure imposing CALGreen Tier 2 standards for the Project’s EV charging facilities should be expanded to broadly require Tier 2 standards for the Project. The comment does not argue that MM-GHG-4 is not feasible or enforceable or otherwise CEQA compliant.

The comment is made in isolation without consideration of all the PDFs, mitigation measures, and regulatory requirements imposed on the Project. The Draft SEIR includes MM-GHG-4, which requires installation of EV charging infrastructure consistent with CALGreen Tier 2 standards. MM-GHG-4 is not a measure designed to address energy standards for all components of the Project. The mitigation measure addresses one specific component of the Project, EV chargers. Like CAPCOA Measure T-14 (Provide Electric Vehicle Charging Infrastructure) referenced in the comment, MM-GHG-4 only addresses EV charging facilities. No inconsistency exists. With respect to other elements of the Project, the Project as a whole must comply with the CALGreen mandatory standards as a matter of law. Those other Project components, such as energy efficiency and building envelope requirements, are addressed through separate measures and design features that meet or exceed applicable code requirements, such as PDF-11 (California Building Standards), MM-GHG-7 (Building Energy Efficiency), and MM-GHG-8 (Cool Roof/Deck).

O2-44 The comment requests clarifications and modifications to MM-TRA-2 (Provide End-of-Trip Bicycle Facilities) related to bike parking and voluntary CALGreen measures. The comment also states that the mitigation measures should include other components of CAPCOA Measure T-34 or T-10 and provide electric bikeshare and/or scootershare program consistent with CAPCOA Measures T-22-A through T-22-D.

MM-TRA-2 (Provide End-of-Trip Bicycle Facilities) is already consistent with CAPCOA Measures T-10 (Provide End-of-Trip Bicycle Facilities) and T-34 (Provide Bike Parking). The comment’s description of T-34 as “Use Electric or Hybrid Powered Equipment” is incorrect; T-34 pertains to bike parking requirements, according to the CAPCOA Handbook (CAPCOA 2024).

The comment’s suggestion that there is uncertainty about the bike parking is unfounded. The 2022 California Building Code requires 5% short-term bicycle parking for new motorized vehicle spaces and requires 5% of the tenant-occupied vehicular parking spaces for long-term bicycle parking. There are no Tier 2 standards for bicycle parking. Compliance with the current California Building Code, calculated using the total 528 parking spaces provided by the Project, translates to approximately 27 short-term and 27 long-term bicycle parking spaces. MM-TRA-2 requires a minimum of 38 spaces for guests (i.e., short term) and 32 secure bicycle parking spaces for employees (i.e., long term). Thus, the minimums in the mitigation measures exceed the code requirements of 27 short-term and 27 longterm bicycle spaces. 550
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To avoid any doubt, MM-TRA-2 has been clarified in the Final SEIR to specify that the 38 bicycle parking spaces are short-term spaces for guests, and the 32 secure bicycle parking spaces are longer-term spaces for employees. Although the existing measure is clear as drafted, the revised language will explicitly state that employee spaces are not displaced by guest rentals. It should be noted that MMGHG-5 also references the 38 guest spaces. Thus, the clarifying language does not trigger recirculation as required under CEQA Guidelines Section 15088.5.

As to the comment’s recommendation for additional mitigation measures, please see Response to Comment O2-36. Although not needed for the Draft SEIR or Final SEIR to comply with CEQA as VMT impacts are already less than significant with the incorporated measures and because the CAPCOA measures referenced in the comment are qualitative measures under CalEEMod, the PDF incorporated into the Supplemental MMRP will require that the Project install a self-service bicycle repair station adjacent to the guest and employee bicycle parking spaces in response to the comment. Further, with respect to the comment’s suggested addition of CAPCOA Measures T-22-A through T-22-D (Electric Bikeshare/Scootershare), those measures do not apply to the Project’s land use type, scale, or locational context. Those CAPCOA measures target residential neighborhood design, per the CAPCOA Handbook (2024).

In summary, MM-TRA-2 meets CEQA requirements by providing enforceable bicycle facilities consistent with CAPCOA guidance. The analysis and determinations disclosed within the Draft SEIR demonstrate that the Project will have less than significant VMT impacts with the mitigation imposed and no further mitigation is required.

O2-45 The comment states that MM-GHG-6 (Limit Large Diesel Trucks During Operation) lacks clarity on whether limiting heavy-duty trucks to 10 per day is a mitigation measure or a PDF. The comment states that this measure is unlikely to significantly reduce GHG emissions because trucks are not the primary source of emissions for a hotel like the Project. The comment also argues the Project should include electrified loading docks per CAPCOA Measure T-53.

The Draft SEIR clearly identifies MM-GHG-6 as a mitigation measure, not a PDF. This measure was analyzed in the GHG Report (Appendix C of the Draft SEIR), which includes two sets of CalEEMod results:
▪ Unmitigated Scenario (“B-2 Hotel GHG Construction and Operation August 2025 – Unmitigated Detailed Report,” Draft SEIR, Appendix C, pp. 127–199)
▪ Mitigated Scenario with Truck Restrictions (“B-2 Hotel GHG Construction and Operation August 2025 – Mitigated with Truck Restrictions Detailed Report,” Draft SEIR, Appendix C, pp. 200–272) In the unmitigated scenario, CalEEMod applied its default mobile source fleet mix, which is based on CARB’s EMFAC model and DMV registration data for the region. This default mix assumed approximately 70 heavy-duty truck trips per day, which overstates truck-related GHG emissions. As the comment notes, unlike a warehouse, heavy-duty truck emissions are not the main contributor to the Project’s GHG emissions. In the mitigated scenario, the fleet mix was adjusted to reflect the restriction to 10 heavy-duty trucks per day under MM-GHG-6, which still likely overstates the Project’s heavy-duty truck emissions. Nevertheless, MM-GHG-6 imposes limits on the number of heavy-duty trucks per day.

As shown in the GHG Report, mobile source emissions decreased from 2,655 MT CO₂e (unmitigated) to 2,480 MT CO₂e (mitigated) (Draft SEIR, Appendix C, PDF pp. 142 and 215). 551
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Regardless, as the comment itself argues, large diesel truck trips during operation would be minimal.

Further, MM-GHG-5 ensures that the maximum number of daily trips will not exceed 10 making such a measure unnecessary. The comment itself offers no substantial evidence to support the request. In addition, CAPCOA Measure T-53 (Electrified Loading Docks) is a qualitative measure in CalEEMod that would not provide quantifiable reductions for the Project. Further, the comment fails to acknowledge that the Project already includes PDF-12 and PDF-21, which limit idling time for delivery vehicles, effectively reducing emissions during loading/unloading.

In summary, MM-GHG-6 is an enforceable mitigation measure that was modeled and shown to result in the GHG emissions disclosed in the Draft SEIR for the mitigated condition. Please see Response to Comment O2-36 for a discussion of the CEQA standard regarding mitigation. The additional measures suggested by the comment are not needed or required by CEQA.

O2-46 The comment states that MM-GHG-5 duplicates MM-TRA-2. The comment asserts that the Draft SEIR does not discuss CAPCOA Measures T-19A/B (Construct or Improve Bike Facility), T-32 (Orient Project Toward Transit/Bike/Pedestrian Facility), T-33 (Locate Project near Bike Path), and T-37 (Dedicate Land for Bike Trails). Given the Project’s location along a Class II bike lane, the comment recommends modifying MM-GHG-5 to include specific elements consistent with these CAPCOA measures or to explain why such measures are not feasible.

The comment mischaracterizes MM-GHG-5 and MM-TRA-2. As shown in the Draft SEIR, MM-GHG-5 broadly applies to measures designed to reduce guest vehicle trips. Some of those measures include the provision of bicycle infrastructure for guests. In contrast, MM-TRA-2 addresses bicycle parking for employees.

In addition, please see Responses to Comments O2-15 and O2-36 explaining that CEQA does not require incorporation of all CAPCOA measures or all measures suggested by a comment. With respect to the suggestion about CAPCOA Measures T-19-A/B, T-32, T-33, and T-37, the recommended action is not warranted for at least the following reasons:
▪ CAPCOA Measures T-19-A/B (Construct or Improve Bike Facility) do not apply to the Project’s land use type, scale, or locational context per CalEEMod guidance. ▪ CAPCOA Measures T-32 and T-33 are qualitative in CalEEMod and largely relate to site orientation and accessibility. These measures do not apply to the Project’s land use type, scale, or locational context; they target residential neighborhood design, per the 2024 CAPCOA Handbook. The Project site is in a highly urbanized area near a mix of commercial and residential uses, within close proximity to public transit and adjacent to a Class II bike lane. As disclosed in the Draft SEIR, the site is targeted for hotel development due to its proximity to attractions and destinations, which inherently support destination accessibility. Between compliance with PDFs, mitigation measures and regulatory requirements, the Project will include bicycle parking for employees and guests and will be designed in accordance with City standards for pedestrian and bicycle infrastructure, improving walkability and connections to alternative transportation modes. ▪ CAPCOA Measure T-37 relates to dedication of land for bike trails. Measure T-37 is not applicable to the Project in CalEEMod because it does not apply to the Project’s land use type, scale, or locational context; it targets residential neighborhood design, per the 2024 CAPCOA Handbook.

Further, the Project site is already located adjacent to a Class II bike lane. 552
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In summary, MM-GHG-5 is an enforceable mitigation measure that is adequately discussed and described in the Draft SEIR. CEQA does not require the additional mitigation recommended by the comment. No revision to the Draft SEIR or Supplemental MMRP is warranted.

O2-47 The comment states that MM-GHG-5 includes basic pedestrian infrastructure elements (e.g., sidewalks, crosswalks, wayfinding signage) that are standard requirements for urban projects and are unlikely to yield meaningful GHG emissions reductions. The comment draws comparisons between MM-GHG-5 and CAPCOA Measure T-17 (Improve Street Connectivity) and Measure T-18 (Provide Pedestrian Network Improvement). The comment argues that the CAPCOA measures may not be applicable to the Project and that MM-GHG-5 may not result in quantifiable emission reductions.

MM-GHG-5 includes pedestrian and bicycle infrastructure improvements as part of a comprehensive strategy to reduce guest vehicle trips and promote alternative transportation modes. As the comment notes, sidewalks, crosswalks, and wayfinding signage are common requirements for urban projects; however, incorporating these elements into a mitigation measure ensures they are enforceable and implemented as part of the Project’s GHG emissions reduction strategy. MM-GHG-5 also goes beyond standard requirements by integrating unique features such as bicycle rentals for hotel guests, transit information, and qualitative assessments of effectiveness through guest feedback and annual reporting. As disclosed in the Draft SEIR, MM-GHG-5 was not evaluated as a quantifiable GHG emissions reduction measure given the uncertainty about the magnitude of reductions that could be achieved.

The CAPCOA measures cited, T-17 (Improve Street Connectivity) and T-18 (Provide Pedestrian Network Improvement), are not relevant to the Project. Those measures are primarily intended for residential neighborhood design and are most effective at the plan or community scale. Per CalEEMod guidance, these measures do not apply to the Project’s land use type, scale, or locational context. The Project is a hotel development in a highly urbanized area adjacent to existing city streets and a Class II bike lane; therefore, creating new street networks or retrofitting existing ones is not a measure that would achieve quantitative or qualitative GHG emissions reductions for the Project.

MM-GHG-5 is appropriate because it memorializes pedestrian and bicycle improvements, ensures compliance through City verification, and includes operational strategies to actively encourage walking, bicycling, and transit use. CEQA does not require adoption of all possible mitigation measures, only those that are feasible and capable of substantially reducing impacts (CEQA Guidelines Section 15126.4[a][1][B]).

MM-GHG-5 is a reasonable and enforceable measure that addresses pedestrian and bicycle connectivity within the Project context and supports GHG reduction goals.

O2-48 The comment addresses the marketing element of MM-GHG-5. The comment states that the marketing component resembles CAPCOA Measure T-7 (CTR [Commute Trip Reduction] Marketing) that is typically aimed at employees. The comment recommends incorporating CAPCOA Measure T-43 (Provide RealTime Transit Information).

MM-GHG-5 includes provisions to provide guests with information about transit options and nearby attractions to encourage the use of alternative transportation modes. The comment erroneously compares the mitigation measure to CAPCOA Measure T-7 (CTR Marketing), which typically targets 553
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employees. MM-GHG-5 is tailored to the Project’s hotel use and focuses on reducing guest vehicle trips through marketing and operational strategies. As discussed in previous responses, the Draft SEIR evaluated MM-GHG-5 as a qualitative GHG emissions measure.

The recommendation to incorporate CAPCOA Measure T-43 (Provide Real-Time Transit Information) was considered and the measure has been incorporated into MM-GHG-5 as described in the Final SEIR.

While CAPCOA Measure T-43 is identified in CalEEMod as qualitative, the Draft SEIR already requires the Project to provide transit information to guests, including local bus routes, schedules, and wayfinding to nearby transit stops along Harbor Boulevard. The Project will further implement this requirement by providing real‑time transit information, consistent with CAPCOA Measure T-43, to enhance awareness and use of alternative transportation modes in a manner appropriate to the Project’s operational context. The clarifications made to MM-GHG-5 do not require recirculation of the Draft SEIR under CEQA Guidelines Section 15088.5.

As discussed in responses to comments such as O2-36, CEQA requires adoption of feasible mitigation measures that substantially reduce significant impacts but does not mandate inclusion of all suggested measures (CEQA Guidelines Section 15126.4[a][1][B]). MM-GHG-5 is appropriate and enforceable because it memorializes transit-related information as part of the Project’s mitigation strategy and includes qualitative assessments and annual reporting to ensure effectiveness.

O2-49 The comment states that MM-GHG-5 does not address first- and last-mile transportation needs, such as hotel shuttles or incentives for rideshare services. The comment recommends modifying the measure to include CAPCOA Measures T-38 (Provide First and Last Mile TNC [Transportation Network Company] Incentives) and T-44 (Provide Shuttles), with a focus on electric shuttles and subsidized TNC trips for guests and employees. The comment suggests that these services should be made available to prospective guests and employees to further reduce VMT and mobile emissions.

MM-GHG-5 includes measures to provide guests with information about transit options and nearby attractions to encourage alternative transportation use. The comment does not acknowledge, as disclosed in the Draft SEIR, that the Project is located within 0.5 miles of a major transit stop or the Anaheim Transportation Network Route 3 and 4 transit lines that will allow Project guests to travel to tourist attractions in the area such as Great Wolf Lodge and Disneyland without reliance on personal vehicles. Thus, first- and last-mile transit services already exist. Although not required to support the Draft SEIR’s GHG and VMT impact determinations, the Final SEIR includes the following clarifications to existing measures incorporated in response to this comment: dedicated shuttles, real-time transit information, and transit pass purchase options.

The comment suggests adding CAPCOA Measures T-38 (Provide First and Last Mile TNC Incentives) and T-44 (Provide Shuttles) to further reduce vehicle trips. These measures were considered but determined not to be required given the nature of the Project and the analysis in the Draft SEIR, for reasons including the following:
▪ MM-TRA-1 addresses employee travel by requiring subsidized transit passes for employees. ▪ MM-GHG-5 has been updated to clarify that the hotel will provide information to guests about how to purchase transit passes and potential transit promotions. 554
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▪ MM-GHG-5 has been updated to clarify that the hotel will make available a dedicated shuttle service linking the hotel to nearby transportation, shopping and entertainment destinations, prioritizing battery‑electric vehicles where route length and charging logistics allow.

The above-referenced existing or clarified measures will not change the Draft SEIR’s GHG emissions analysis or conclusions, and the clarifications do not trigger recirculation of the SEIR under CEQA Guidelines Section 15088.5.

MM-GHG-5 is a reasonable and enforceable mitigation measure that memorializes guest-focused strategies such as providing transit information, promoting walking and bicycling, and integrating alternative transportation options into the guest experience. CEQA does not require anything further.

O2-50 The comment acknowledges that MM-GHG-5 is a qualitative measure and that the Draft SEIR analyzes it accordingly. The comment argues that the mitigation measure should be mandatory and “performance based,” with annual monitoring.

The comment does not accurately describe the scope or purpose of MM-GHG-5 or the referenced CAPCOA measures. That mitigation measure is specifically designed to reduce guest vehicle trips through operational strategies such as promoting walking, bicycling, and transit use. The measure is not an employee commuter trip reduction program and thus is not intended to address the same issues as CAPCOA Measures T-5 (Voluntary CTR) and T-6 (Mandatory CTR) referenced in the comment. Those measures do not apply to hotel guests.

Although a comparison is not relevant given the different purposes of the measures, MM-GHG-5 requires the Project to implement specific actions and goes beyond CAPCOA Measure T-5 by including a qualitative assessment and annual reporting. Thus, the measure is mandatory and it includes a requirement that the Project operator conduct monitoring and provide the resultant data to City. There is no requirement under CEQA to adopt a mandatory measure such as CAPCOA Measure T-5 or T-6 for guests. The Project’s approach is appropriate because the Draft SEIR evaluates MM-GHG-5 as a qualitative measure that imposes guest-focused strategies, integrates alternative transportation options into the guest experience, and includes qualitative assessments and annual reporting to ensure effectiveness of GHG emissions reduction goals. Based on the Draft SEIR’s qualitative analysis of MM-GHG-5, the overall discussion and determination regarding GHG impacts and the mandates of CEQA, the additional VMT guest data the comment recommends is neither required nor necessarily useful. MM-GHG-5 is a reasonable and enforceable measure specific to the Project. CEQA requires nothing further.

O2-51 The comment states that MM-TRA-1 (Implement Commute Trip Reduction Marketing) is similar to CAPCOA Measures T-5 and T-6. This comment concerns a VMT related mitigation measure, but the comment asserts that changes should be made to this mitigation measure to address the comment’s statements about GHG emissions.

The comment’s characterization of MM-TRA-1 is misleading. MM-TRA-1 is a employee CTR program that the Draft SEIR properly credits with a 4% VMT reduction based on the modeling and other substantial evidence presented in the record. The comment does not question the effectiveness of that measure in achieving the identified VMT reduction using the measures identified as part of MM-TRA-1 in the Draft SEIR.
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The comment fails to acknowledge, as discussed in Responses to Comments O2-9 and O2-16, that the GHG analysis did not take any further reductions in GHG emissions for implementation of MM-TRA-1.

Thus, the GHG emissions presented in the Draft SEIR are likely conservative. Please also refer to Responses to Comments O2-9 and O2-16, which address the GHG arguments repeated in this comment and the interplay between the VMT and GHG emissions analysis and mitigation measures.

The comment offers no support for the request for additional GHG emissions analysis or the requested mitigation measures given the Draft SEIR’s discussion and determinations regarding the Project’s GHG emissions impacts. Nonetheless, the following discusses each of the specific topic areas identified in the comment:
▪ Comment O2-50. With respect to the comment’s cross-reference to Comment O2-50, please see the Response to Comment O2-50 above.
▪ CAPCOA Measure T-9. The comment erroneously states that the Draft SEIR GHG Report (Appendix C) included CAPCOA Measure T-9. To the contrary, the VMT Memo included as Appendix D of the SEIR included CAPCOA Measure T-9. Appropriate VMT reduction for CAPCOA Measure T-9 has been applied as part of MM-TRA-1 and is explained in Response to Comment O2-44. As noted above, no separate reductions in GHG emissions have been taken for this measure. As described in MM-TRA1, 100% of the employees will be considered eligible to participate in the CTR program. MM-TRA-1 includes transit subsidies for employees as one component of the program and uses participation percentages as a reasonable scenario based on professional judgment and experience with this measure. Especially for an operation like a hotel, with its 24-hour operations, it would be speculative to assume greater transit usage than evaluated in the Draft SEIR. Speculative analysis and assumptions of the type recommended by the comment are anathema to CEQA and its mandate for a good-faith effort at full disclosure of a project’s potentially significant impacts. ▪ CAPCOA Measures T-11 (Provide Employer-Sponsored Vanpool) (qualitative measure) and T-13 (Implement Employee Parking Cash-Out) (quantitative measure). The Project includes MM-TRA-1, which implements a CTR program for employees and is similar to CAPCOA Measures T-11, which encourage ridesharing and reducing single-occupancy vehicle trips. Further, MM-TRA-1 encourages ridesharing by setting aside a minimum of 10 preferential parking spaces for carpools/vanpools.

Additionally, MM-GHG-5 promotes alternative transportation for guests by integrating transit information into the guest experience and providing bicycle parking and rentals. As discussed in Response to Comment O2-49, a disincentive exists for single-rider vehicle trips because the Project is located within 0.5 miles of a major transit stop, the Anaheim Transportation Network public transit lines provide service to regional transit locations such as Disneyland, and the hotel will provide a shuttle service. With regard to CAPCOA Measure T-13, this measure was not incorporated into the Project because it is a context-dependent measure with effectiveness varying widely by land use type, employee demographics, and parking environment (CAPCOA 2024). CAPCOA and transportation agencies have cautioned that parking cash-out is more suitable for individual office or institutional projects and may not be appropriate or scalable for complex land uses such as hospitality resorts (Fehr and Peers 2024). As such, excluding T-13 is consistent with accepted professional practice and CEQA’s mandate to avoid speculative analysis. ▪ CAPCOA Measures T-25 (Extend Transit Network Coverage or Hours), T-26 (Increase Transit Service Frequency), and T-27 (Implement Transit-Supportive Roadway Treatments). T-25 and T-27 are quantitative measures and T-27 is a qualitative measure. These measures are primarily intended for transit agencies or larger-scale developments with control over regional transportation 556
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infrastructure. The Project is an infill resort hotel located within 0.5 miles of a major transit stop along a major transportation corridor. The Project does not have authority to extend transit coverage, increase service frequency, or implement roadway treatments, which are under the jurisdiction of local transit agencies and/or matters without a nexus to an infill development like the Project. Further, the measures are not applicable per CalEEMod for the Project’s land use type, land scale, and/or locational context.
▪ CAPCOA Measure T-46 (Provide Transit Shelters). This is a qualitative measure, but it is not applicable per CalEEMod for the Project’s land use type, land scale, and/or locational context. ▪ CAPCOA Measure T-47 (Provide Bike Parking Near Transit). This is a qualitative measure, but it is not applicable per CalEEMod for the Project’s land use type, land scale, and/or locational context.

See also the discussion in Response to Comment O2-49 regarding the Project site’s proximity to various public transit services and noting that MM-TRA-1 and MM-GHG-5 require on-site bicycle parking for employees and guests. Nothing further is required.

CEQA requires adoption of feasible mitigation measures that reduce impacts to a less than significant level but does not mandate inclusion of all suggested measures or measures outside the Project’s control (CEQA Guidelines Section 15126.4[a][1][B]). The Draft SEIR’s GHG emissions analysis and significance determinations comply with CEQA. The comment’s recommendations are unnecessary and are not required by CEQA.

O2-52 The comment acknowledges that the Draft SEIR includes energy-related mitigation measures (MMGHG-7 through MM-GHG-12). Without support, the comment recommends the adoption of additional CAPCOA measures and asks for clarification about the Project LEED certification level. The comment also criticizes MM-GHG-10 as permissive based on an erroneous description of the measure’s requirements. The comment concludes with the assertion that MM-GHG-13 (Prohibit Wood-Burning Devices) is unlikely to be meaningful for a non-residential project. ▪ In response, as it relates to the LEED certification levels and State energy standards, the GHG analysis assumed that the Project would achieve energy efficient levels of at a minimum of 15% above the 2022 Title 24 Building Envelope Energy Efficiency Standards. To clarify the intent of MMGHG-7, that measure will be revised in the Final SEIR to mandate that the Project achieve, at a minimum, an energy efficient level of 15% greater than what is required by the 2022 Title 24 Building Envelope Energy Efficiency Standards. As already mandated by MM-GHG-7, those reductions must be validated by the City prior to the issuance of building permits. In addition, although not required or assumed in the Draft SEIR’s GHG analysis, please see response to comment O2-43 for a discussion of the comment regarding CalGreen Tier 2 standards and MMGHG-4. MM-GHG-7 has been clarified in the Final SEIR to state that the Project shall achieve a LEED certification of Gold or Platinum.

With respect to the specific CAPCOA energy measures identified in the comment, no further changes are necessary or required under CEQA for at least the following reasons:
▪ CAPCOA Measure E-1: The requirements of this measure are implemented through MM-GHG-7 (15% above Title 24).
▪ CAPCOA Measure E-2: Appliance efficiency is one potential strategy for achieving the energy reduction standards identified in MM-GHG-7. That measure also addresses HVAC operations, and 557
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an energy management system. Given the performance standard included in the mitigation measure, additional, appliance specific provisions are unnecessary. ▪ CAPCOA Measures E-3-A/B: These are qualitative measures in CalEEMod addressing energyefficient residential boilers (E-3-A) and commercial boilers (E-3-B) and are not applicable to the Project’s land use type or scale per CalEEMod.
▪ CAPCOA Measure E-5: This measure is not feasible due to limited roof space; furthermore, MMGHG-8 addresses heat island reduction. ▪ CAPCOA Measures E-21, E-22, and E-25: These are qualitative measures in CalEEMod addressing cool pavements (E-21), obtaining Third-Party HVAC Commissioning and Verification of Energy Savings (E-22), and installing electric heat pumps (E-25). The intent of these measures is captured through MM-GHG-7 and MM-GHG-8. MM-GHG-7 includes electric heat pumps for space heating and domestic water heating.
▪ CAPCOA Measures E-12 and E-16: These measures are targeted at residential development and are not applicable. Further, zero net energy is infeasible for this Project due to limited roof space for solar and the energy demands of resort hotel operations. In addition, as disclosed in the Draft and Final SEIR, the Project incorporates meaningful energy reduction measures, as well as a requirement to install a solar energy system that will generate a minimum of 267,000 kilowatthours per year (MM-GHG-9). ▪ CAPCOA Measure E-24: This measure addresses strategically providing battery storage. Battery storage has been added to MM-GHG-7 for clarification purposes, as shown below in strikethrough/underline:

MM-GHG-7 Building Energy Efficiency Measures. Prior to issuance of building permits, the Project Applicant applicant or designee shall submit documentation of building energy efficiency measures to the City of Garden Grove, such that a minimum of 15% above 2022 Title 24 Building Envelope Energy Efficiency Standards is achieved. Energy efficiency measures shall include, at a minimum, the following:

LED Lighting – High-lumen LED light fixtures shall be used exclusively for the lighting of spaces throughout the Project that require 8 to 10 watts per fixture.

Energy efficient lighting shall be incorporated into all on-site lighting and energy-efficient appliances shall be incorporated into Project operations.

HVAC Optimization – The HVAC system shall include the following:
a. Heat Electric heat pumps will be used for space heating and domestic hot water, with all systems integrated and monitored by the Project Building Management System for performance optimization, fault detection, and energy tracking. to heat spaces and water using a heat exchanger and will be monitored by the Project Building Management System (BMS).
b. Smart thermostats, which include a motion sensor detector and door/window open sensors, will be installed in each guest room.
c. The central plant will utilize a Combination Plant with SmartPlate EV.

Glazing – All glazing for the tower and exterior public spaces shall be installed with Low-E glass [U-factor (thermal transmittance) ≤ 0.28 and Solar Heat Gain Coefficient (SHGC) ≤ 0.23. 558
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Energy Management System – The Project shall use advanced systems to monitor and optimize energy use in real time.

Benchmarking and Monitoring – The Project shall incorporate an Energy Star Portfolio Management system to track and manage energy consumption.

Third-Party Verification/LEED Certification – The Project shall obtain third-party HVAC commissioning verification or LEED certification of Gold to Platinum to verify energy savings.

Battery Energy Storage – The Project would include an on‑site battery energy storage system occupying approximately 500 to 1,000 square feet, consisting of modular lithium‑ion battery cabinets and associated electrical equipment. The system would be used for peak load management and grid resiliency consistent with California Fire Code and Title 24 requirements. (CAPCOA Measure E-1 is quantified; CAPCOA Measures E-7, E-9, E-22, E-24, and E25 are qualitative)
Further, CEQA does not require incorporation of the additional water conservation recommendation suggested by the comment for reasons that include the following:
▪ MM-GHG-10 requires a Water Conservation Compliance Report and imposes a performance standard mandate of a minimum 10% reduction in total water use compared to the baseline of 167 gallons per room per day (Psomas 2022). As specified in the mitigation measure, the Project must achieve an average of no more than 150.3 gallons per capita per day at full Project occupancy.
▪ As the Draft SEIR discloses, the Project already implements feasible CAPCOA water measures, including W-2 (Greywater Use), W-5 (Water-Efficient Landscaping), and W-7 (Water Conservation Strategy), as elements of achieving the water conservation required by MM-GHG-10. ▪ Other CAPCOA measures (e.g., W-1 [Use Reclaimed Non-Potable Water], W-3 [Use Locally-Sourced Water Supply], W-4 [Require Low-Flow Water Fixtures], and W-6 [Reduce Turf in Landscapes and Lawns]) are either infeasible due to lack of recycled water availability or duplicative of measures already included in MM-GHG-10.

Regarding MM-GHG-13 (Prohibit Woodburning devices, Natural Gas Fireplaces and Fire Pits), hotels, especially those with aquatic and event space uses like the Project, will include fireplaces and fire pits.

Consistent with CAPCOA Measure E-14, which is directed at residential uses, MM-GHG-13 ensures that any potential guest gathering features such as fireplaces and fire pits will use clean energy sources such as electricity, eliminating a potential emissions source. Nothing would be served by the comment’s suggestion that the City remove this measure and the Draft SEIR’s GHG analysis only addresses this restriction as a qualitative measure.

For the reasons noted above, the Draft and Final SEIR’s consideration of energy efficiency matters is consistent with CEQA’s requirements. Nothing further is required.

O2-53 The comment states that MM-GHG-15 (Carbon Offsets) is commendable but offers an opinion that carbon offsets should only be used after all feasible on-site mitigation measures have been implemented or deemed infeasible. The comment again treats CAPCOA, particularly language in CAPCOA Measure M-2, as if it were controlling as it relates to compliance with CEQA. The law does not support the comment’s argument in general or specifically as it relates to Carbon Offsets. Without 559
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factual or legal support, the comment also recommends annual reporting and reassessment of carbon offset requirements over the Project’s 30-year lifespan.

MM-GHG-15 requires the purchase of carbon offsets to address any remaining GHG emissions after implementation of all the PDFs and on-site mitigation measures identified in the Final SEIR. The mitigation measure incorporates elements and requirements consistent with GHG reduction approaches recommended by the GHG experts at Dudek. The carbon offset elements included within MM-GHG-15 are consistent with CEQA’s requirements, including minimum standards for the credits, a process of third-party verification, and prioritization of where projects generating credits are located.

As discussed in these responses to comments, the CAPCOA measures recommended by the comment are either already required of the Project through PDFs or mitigation measures, are not applicable to the Project, are not of a nature that would allow for quantification such that the amount of carbon offsets would be reduced, or are otherwise not feasible or speculative. Similarly, nothing in CEQA requires a mitigation measure to impose continual reassessment and recalibration. For example, CEQA Guidelines Section 15126.4(a)(1)(B) requires adoption of feasible mitigation measures that substantially reduce significant impacts but does not mandate prioritization beyond what is feasible or require ongoing reassessment once impacts have been evaluated and mitigated. The approach suggested by the comment would run counter to CEQA’s informed decision-making mandates because it would create uncertainty for the decision makers, developer, operator, and the public as to what the Project must do to offset its GHG emissions. MM-GHG-15 is appropriate and consistent with CEQA. No further response is required.

O2-54 This comment expresses appreciation for the opportunity to comment on the Draft SEIR and does not require a response.

References
AHLA (American Hotel & Lodging Association). 2023. “Hotel Occupancy: 2019 Performance vs. 2023 Projections by State.” Oxford Economic Analysis. February 2023. https://www.ahla.com/sites/default/files/ SOTI_report_Oxford_Data_Occupancy.pdf.

Austin-Harris, J. n.d. Phone call re: per-room occupancy data at Great Wolf Lodge between J. Austin-Harris (General Manager, Great Wolf Lodge) and G. Blodgett (Deputy Director Economic Development, City of Garden Grove).

CalRecycle (California Department of Resources Recycling and Recovery). 2006. Targeted Statewide Characterization Study: Waste Disposal and Diversion Findings for Selected Industry Groups (341-2006- 0006). Accessed June 2025. https://www2.calrecycle.ca.gov/Publications/Download/787.

CalRecycle. 2024. Baseline Report for the Zero Waste Plan. July 1, 2024. Accessed June 2025. https://www2.calrecycle.ca.gov/Publications/Details/1741.

CalRecycle. 2025. Business Group Waste Stream Calculator. Accessed August 2025. https://www2.calrecycle.ca.gov/WasteCharacterization/BusinessGroupCalculator. 560
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CAPCOA (California Air Pollution Control Officers Association). 2024. Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity. October 2024.

Accessed February 2025. https://www.airquality.org/ClimateChange/Documents/ 2024%20Handbook%20Update_AB434.pdf.

City of Anaheim. 2023. “Transportation Section” and “CEQA Transportation Analysis” for the DisneylandForward Project. Section 5.14 and Appendix J-1 in DisneylandForward Subsequent Environmental Impact Report No. 352, State Clearinghouse No. 2021100402, prepared by Psomas for the City of Anaheim, September 2023. Prepared by Gibson Transportation Consulting Inc. for the City of Anaheim. August 2023.

City of Garden Grove. 2008. Garden Grove General Plan. May 2008. https://ggcity.org/planning/general-plan.

City of Garden Grove. 2020. City of Garden Grove Traffic Impact Analysis Guidelines for Vehicle Miles Traveled and Level of Service Assessment. Prepared by Fehr & Peers. May 2020.

City of Garden Grove. 2022. City of Garden Grove Economic Development Report & Analysis, B-2 Site: NewAge Garden Grove ll, LLC Nickelodeon Resort Hotel Prepared Pursuant to Government Code Sections §53083 and §52201. August 28, 2022. https://ggcity.org/sites/default/files/economic-development-report-andanalysis.pdf.

City of Garden Grove. 2023. “2021–2029 Housing Element.” Chapter 12 in Garden Grove General Plan.

Resolution No. 9825-23. Adopted October 10, 2023. https://ggcity.org/sites/default/files/gghea.pdf.

City of Hotels. 2025. “Hotel Staff.” Online article. https://www.city-of-hotels.com/165/hotel-staff-en.html.

Crain and Associates. 2013. “Millennium Hollywood Project Transportation Modeling Procedures and Results.” Appendix B in the Final Environmental Impact Report for the Millennium Hollywood Project, City of Los Angeles, February 8, 2013. February 1, 2013.

Dayoub, D. 2021. “Why Are We Surprised that Hospitality Workers Are Moving to Other Sectors?” Article on the Ludwig Institute for Shared Economic Prosperity website. October 22, 2021. https://www.lisep.org/ content/why-are-we-surprised-that-hospitality-workers-are-moving-to-other-sectors.

Fehr and Peers. 2024. VMT/GHG Model Mitigation Program Report. December 2024. https://ccag.ca.gov/wpcontent/uploads/2024/12/VMT-GHG_Model_Mitigation_Program_Final_Report.pdf ITE (Institute of Transportation Engineers). 2017. Trip Generation Handbook, Third Edition. Prepared by K.G.

Hooper for ITE. https://ecommerce.ite.org/ItemDetail?iProductCode=RP-028D-E.

ITE. 2025. Trip Generation Manual, 12th Edition. August 2025. https://www.ite.org/technical-resources/ topics/trip-and-parking-generation-v2/trip-generation-info/.

LADOT and DCP (Los Angeles Department of Transportation and Los Angeles Department of City Planning). 2020.

City of Los Angeles VMT Calculator Documentation, Version 1.3. May 2020. https://ladot.lacity.gov/sites/ default/files/documents/vmt_calculator_documentation-2020.05.18.pdf.

Psomas. 2022. Site B-2 Hotel Water Supply Assessment. March. Prepared for AECOM and the City of Garden Grove.
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SANDAG (San Diego Association of Governments). 2023. SANDAG ABM2+ Version 14.2.2. File containing information on land use unit type. Email communication between C. Arellano and S. Tewani.

September 11, 2023.

SANDAG. 2022. SANDAG ABM2+ Enhancements Final Report. August 2022. https://github.com/SANDAG/ ABM/wiki/Reports-and-Documents.

SCAG (Southern California Association of Governments). 2001. Employment Density Study Summary Report.

October 31, 2001. Prepared by The Natelson Company Inc. for SCAG. https://docplayer.net/30300085- Employment-density-study-summary-report-october-31-prepared-for-southern-california-association-ofgovernments.html.

SCAG. 2020. “Demographics and Growth Forecast.” Technical report, Connect SoCal 2020. Adopted September 3, 2020. https://www.scag.ca.gov/connect-socal-2020.

SCAG. 2024a. Connect SoCal 2024: The 2024–2050 Regional Transportation Plan/Sustainable Communities Strategy of the Southern California Association of Governments. Adopted April 4, 2024. https://scag.ca.gov/sites/default/files/2024-05/23-2987-connect-socal-2024-final-complete040424.pdf SCAG. 2024b. “Demographics & Growth Forecast.” Technical report, Connect SoCal 2024.

Adopted April 4, 2024. https://scag.ca.gov/connect-SoCal-2024. 562
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3 Changes to the Draft Supplemental
Environmental Impact Report

3.1 Introduction
As provided in Section 15088(c) of the California Environmental Quality Act (CEQA) Guidelines, responses to comments may take the form of a revision to a draft environmental impact report (EIR) or may be a separate section in a Final EIR. This chapter of the Final Supplemental EIR (SEIR) complies with the latter option and provides changes to the Draft SEIR in strikethrough text (i.e., strikethrough) signifying deletions, and underlined text (i.e., underline) signifying additions. These notations are meant to provide clarification, corrections, or minor revisions identified during the review period or as a result of public comments received for the proposed Site B-2 Hotel Project (Project) since the release of the Draft SEIR, as required by Section 15132 of the CEQA Guidelines. None of the corrections or additions constitutes significant new information or substantial Project changes requiring recirculation of the SEIR, as defined by Section 15088.5 of the CEQA Guidelines.

3.2 Changes to the Draft SEIR

3.2.1 Changes to the Table of Contents, Tables
List of Tables, pages TOC-iii, TOC-iv1
TABLES
1-1 Summary of Environmental Impacts and Mitigation Measures.................................................................... 1-7 1-2 Comparison of Project and Alternatives .......................................................................................................1-31 2-1 NOP Comments................................................................................................................................................ 2-5 3-1 Surrounding Land Uses and Designations ..................................................................................................... 3-2 3-2 Construction Equipment Assumptions ........................................................................................................... 3-3 3-3 Project Components......................................................................................................................................... 3-4 4-1 Geographic Scope and Method of Evaluation for Cumulative Impacts ........................................................ 4-2

4.1-1 Greenhouse Gas Emissions Sources in California......................................................................................4.1-4

4.1-2 CalEEMod Land Use Development Summary ...........................................................................................4.1-27

4.1-3 Construction Scenario Phasing ..................................................................................................................4.1-28

4.1-4 Estimated Annual Construction Greenhouse Gas Emissions – Unmitigated..........................................4.1-34

4.1-5 Estimated Annual Operational Greenhouse Gas Emissions – 2028 – Unmitigated ..............................4.1-35

4.1-6 Project Potential to Conflict with Connect SoCal 2024 ............................................................................4.1-36

4.1-7 Project Potential to Conflict with 2022 Scoping Plan ...............................................................................4.1-54 1 The tables shown as underlined in this section were included in the Draft SEIR. This correction is made to the Table of Contents because tables were inadvertently omitted from the Draft SEIR’s Table of Contents. 563
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4.1-8 Project Potential to Conflict with City of Garden Grove General Plan......................................................4.1-57

4.1-9 Estimated Annual Construction Greenhouse Gas Emissions – Mitigated...............................................4.1-82

4.1-10 Estimated Annual Operational Greenhouse Gas Emissions – 2028 – Mitigated ........................................4.1-82

4.1-11 Estimated Annual Construction Greenhouse Gas Emissions – Mitigated plus Carbon Offsets.............4.1-89

4.1-12 Estimated Annual Operational Greenhouse Gas Emissions – 2028 – Mitigated plus Carbon Offsets....................................................................................................................4.1-89

4.2-1 Project Generated OD VMT per Service Population.................................................................................4.2--15

4.2-2 Project Generated PA or Home Based Work VMT per Employee ............................................................4.2--15

4.2-3 Project Effect on VMT.................................................................................................................................4.2--16

4.2-4 VMT Reduction for Project Generated VMT per Employee ......................................................................4.2--18 6-1 Summary of Alternative 1 Success at Meeting Project Objectives ............................................................... 6-7 6-2 Reduced Project Alternative Estimated Annual Construction Greenhouse Gas Emissions – Unmitigated...............................................................................................................................6-10 6-3 Reduced Project Alternative Estimated Annual Operational Greenhouse Gas Emissions – 2028 – Unmitigated .................................................................................................................6-10 6-4 Comparison of the Project and Reduced Project Alternative Estimated Annual Greenhouse Gas Emissions – 2028 – Unmitigated ....................................................................................6-11 6-5 Summary of Alternative 2 Success at Meeting Project Objectives .............................................................6-13 6-6 Comparison of Project and Alternatives .......................................................................................................6-15

3.2.2 Changes to Chapter 1, Executive Summary

1.4.3, Project Design Features, page 1-3
An Initial Study/Mitigated Negative Declaration (IS/MND) was previously prepared for the proposed Project and approved by the City of Garden Grove in 2022 and included several Project Design Features (PDFs) as conditions of approval. The following section summarizes those applicable PDFs that are incorporated here. It should be noted that all the following PDFs are qualitative/supporting measures. Therefore, for purposes of quantifying the Project’s GHG emissions, no GHG reductions were taken from implementation of these measures.

PDF-28 The Project amenities shall be available to registered hotel guests only. There will be no day passes allowed.

PDF-29 The Project amenities include a self-service bicycle repair station adjacent to the guest and employee bicycle parking spaces.

1.6, Areas of Known Controversy, page 1-6 (bulleted list) ▪ Request for the Project to rely on the South Coast Air Quality Management District’s CEQA guidance and evaluate all phases of the Project and air pollutant sources ▪ Request for the Project applicantApplicant to consider including a Transportation Demand Management analysis within the EIR and implementation of appropriate detours, signage, and safety measures for pedestrians and bicyclists in the construction phase and encouragement of Complete Street design 564
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▪ Request that the City should clarify what environmental review is being supplemented and receipt of all notices concerning any CEQA/land use actions associated with the Project

1.8, Summary of Environmental Impacts and Mitigation, pages 1-7 through 1-27 Table 1-1 summarizes the conclusions of the environmental analysis contained in this SEIR. Table 1-1 provides a complete list of the project’s environmental impacts including the level of significance before and after mitigation, based on the analysis and conclusions presented in Chapter 4 of this SEIR. Each mitigation measure includes the corresponding California Air Pollution Control Officers’ Association (CAPCOA) alphanumerical designation for the measure in italics immediately following the mitigation text to indicate alignment with recognized VMT and GHG best practices. The potentially significant impacts related to VMT and conflicts with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs can be reduced to less than significant through incorporation of mitigation measures identified in Chapter 4 (see Impact GHG-2 and Impact TRA-1 in Section 4.1, Greenhouse Gas Emissions and Section 4.2, Transportation). The Project would result in significant unavoidable Project and cumulative impacts to GHG emissions, even with the implementation of identified mitigation measures (see Impact GHG-1 Section 4.1, and Table 1-1 for details).

1.8, Table 1-1, pages 1-6 through 1-27
MM-GHG-1. Construction Equipment ElectrificationElectric Construction Equipment. Prior to issuance of building permits, the Project Applicant’s or designee’s contractor shall submit a Construction Equipment Emissions Minimization Plan for City of Garden Grove (City) approval that:
(1) Identifies all off-road equipment anticipated by phase. (2) Requires generators, cranes, electric scissor/boom lifts, forklifts/telehandlers (where feasible), welders (where feasible), and electric/solar light towers when commercially available. (3) Requires grid power for temporary construction power. (4) Where electric equipment is not available for a listed task, documents non-availability (size/class, delivery lead time, site constraints) and requires the cleanest feasible alternative (Tier 4 Final/zero-emission alternatives as available).

In addition, the Project shall limit air compressors used during the architectural coating/painting phase to equipment that is electric-powered. Compliance shall be demonstrated through equipment lists, rental records, and weekly logs and shall be summarized in a post-construction compliance memo for the Supplemental Mitigation Monitoring and Reporting Program (Supplemental MMRP) file. applicant or designee shall submit documentation to the City of Garden that temporary power will be established to the Project site during vertical construction. All generator(s) and crane(s) shall be electric-powered. In addition, the Project shall limit air compressors used during the architectural coating/painting phase to equipment that is electric-powered. (CAPCOA Measure C-1-A) MM-GHG-2. Construction Office Energy Efficiency. Prior to issuance of building permits, the Applicant or designee shall submit documentation to the City of Garden Grove that temporary construction field office(s) are equipped with energy efficient lighting such as compact fluorescent or LEDs and that heating and cooling units are Energy Star certified.

MM-GHG-3. Construction Debris Recycling. Prior to the start of construction, the Project’s contractor shall develop a Construction Waste Management Plan (Plan) for submittal and approval to the City of Garden Grove. The 565
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Construction Waste Management Plan shall recycle or salvage non-hazardous construction debris such that a minimum target of 75% is achieved. This will exceed the City’s current target of 65% diversion. including but not limited to wood, metal, concrete, asphalt, and other reusable materials generated during construction activities.

The Plan shall also include provisions for salvaging wood materials for reuse in furniture, engineered wood products, mulch, or other applications. The contractor shall implement the Plan to achieve a minimum diversion target of 75% of non-hazardous construction and demolition debris from landfills, exceeding the City’s current 65% diversion requirement. (CAPCOA Measure S-4)
MM-GHG-4. Electric Vehicle Charging Infrastructure. Prior to issuance of building permits, the Project applicant Applicant or designee shall submit a site plan to the City of Garden Grove for approval noting the location of electric vehicle infrastructure and charging stations. Prior to issuance of the final certificate of occupancy, the Project applicant Applicant or designee shall provide electric vehicle (EV) charging infrastructure within the Project site as required by the applicable California Green Building Standards Code, but that, at a minimum, meets or exceeds 2022 California Green Building Standards Code Tier 2 standards. Tier 2 requires approximately 225 parking spaces to be EV capable, and 75 spaces to be equipped with EV Supply Equipment (EVSE). The Project shall install a minimum of 225 EV capable spaces and 100 EVSE spaces. (CAPCOA Measure T-14) MM-GHG-5. Guest Vehicle Trip Reductions. Prior to issuance of building permits, the Project applicant Applicant shall submit a site plan to the City of Garden Grove for approval identifying where pedestrian and bicycle connections to adjacent facilities will be provided and where bicycle parking spaces will be provided. The City shall verify the inclusion of pedestrian and bicycle infrastructure prior to the issuance of the final certificate of occupancy.

The Project applicant Applicant or designee shall ensure that, at a minimum, the following trip reduction measures are implemented during Project operations to reduce the number of auto-based trips generated by the Project and to encourage the use of transit, bicycling, and walking. ▪ Improve the walkability and design of the Project by providing pedestrian and bicycling connections within the Project site and to adjacent off-site facilities (i.e., sidewalks, crosswalks, wayfinding signage, etc.). ▪ Provide secure on-site bicycle racks to accommodate a minimum of 38 bicycle parking spaces and provide bicycle rentals for hotel guests.
▪ Alternative transportation services such bike rentals and transit information shall be seamlessly integrated into the guest experience, making alternative modes of travel easy to understand, access, and use. ▪ Hotel management/concierge should provide information that promotes walking, bicycling and public transit options to nearby attractions. This should include real-time transit information provided through dedicated monitors, interactive electronic displays, websites, or mobile applications identifying on local bus routes and schedules, and as well as wayfinding to the existing transit stops along Harbor Boulevardwithin the Project vicinity.
▪ Provide a shuttle service linking the hotel to nearby shopping and entertainment destinations, prioritizing battery‑electric vehicles where route length and charging logistics allow; the program may be operated under a vendor contract with scheduled runs during peak guest activity and on‑demand service for special events.
▪ Hotel management will make available transit passes for purchase and provide clear wayfinding to public transit and shuttle service.
▪ Qualitative assessments (e.g., user satisfaction surveys, walk audits, guest feedback) shall be regularly conducted to evaluate the effectiveness of trip reduction strategies. 566
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▪ An annual report summarizing how transportation options are being used, guest perceptions, and planned improvements shall be submitted to the City.
(CAPCOA Measures T-34, T-38, T-43, and T-44)
MM-GHG-6. Limit Large Diesel Trucks During Operation. Prior to issuance of certificate of occupancy, the Project Applicant applicant or designee shall submit a Truck Delivery Management Plan to the City of Garden Grove that documents how truck deliveries will be restricted and monitored. The Project applicant Applicant or designee shall implement a monitoring program to restrict the number of large diesel trucks coming to the site (i.e. for deliveries, trash collection, or other services) to an average of 10 trucks per day or less. This restriction is specifically applicable to trucks classified as medium-heavy duty and heavy-heavy duty with gross vehicle weight (GVW) greater than 19,500 pounds. Annual reports summarizing heavy-duty truck trips shall be provided to the City of Garden Grove. (CAPCOA Measure C-2)
MM-GHG-7. Building Energy Efficiency Measures. Prior to issuance of building permits, the Project Applicant applicant or designee shall submit documentation of building energy efficiency measures to the City of Garden Grove, such that a minimum of 15% above 2022 Title 24 Building Envelope Energy Efficiency Standards is achieved.

Energy efficiency measures shall include, at a minimum, the following:

1. LED Lighting – High-lumen LED light fixtures shall be used exclusively for the lighting of spaces throughout the Project that require 8 to 10 watts per fixture

2. Energy efficient lighting shall be incorporated into all on-site lighting and energy-efficient appliances shall be incorporated into Project operations.

3. HVAC Optimization – The HVAC system shall include the following:
a. Heat Electric heat pumps will be used for space heating and domestic hot water, with all systems integrated and monitored by the Project Building Management System for performance optimization, fault detection, and energy tracking.to heat spaces and water using a heat exchanger and will be monitored by the Project Building Management System (BMS). b. Smart thermostats, which include a motion sensor detector and door/window open sensors, will be installed in each guest room.
c. The central plant will utilize a Combination Plant with SmartPlate EV.

4. Glazing – All glazing for the tower and exterior public spaces shall be installed with Low-E glass [U-factor (thermal transmittance) ≤ 0.28 and Solar Heat Gain Coefficient (SHGC) ≤ 0.23.

5. Energy Management System – The Project shall use advanced systems to monitor and optimize energy use in real time.

6. Benchmarking and Monitoring – The Project shall incorporate an Energy Star Portfolio Management system to track and manage energy consumption

7. Third-Party Verification/LEED Certification – The Project shall obtain third-party HVAC commissioning verification or LEED certification of Gold to Platinum to verify energy savings

8. Battery Energy Storage – The Project would include an on‑site battery energy storage system occupying approximately 500 to 1,000 square feet, consisting of modular lithium-ion battery cabinets and associated electrical equipment. The system would be used for peak load management and grid resiliency and consistent with California Fire Code and Title 24 requirements. (CAPCOA Measure E-1 is quantified; CAPCOA Measures E-7, E-9, E-22, E-24, and E-25 are qualitative) 567
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MM-GHG-8. Cool Roof/Deck. Prior to issuance of building permits, the Project Applicant applicant or designee shall submit plans to the City for approval that require cool roof and cool deck surfaces to be included as part of the Project for the podium and tower, consistent with the specifications provided below. ▪ Cool Roof Installation: All roofing materials shall meet or exceed the California Title 24, Part 6 requirements for cool roofs, based on roof slope:
- Low-sloped roofs (≤ 2:12 pitch):
o Aged Solar Reflectance (SR) ≥ 0.63
o Thermal Emittance (TE) ≥ 0.75
o Or Solar Reflectance Index (SRI) ≥ 75
- Steep-sloped roofs (> 2:12 pitch):
o Aged SR ≥ 0.20
o TE ≥ 0.75
o Or SRI ≥ 16
▪ Cool Deck Surfaces: All exterior hardscape surfaces exposed to sunlight (e.g., pool decks, patios, walkways) shall use high-albedo materials or cool surface coatings with:
- Minimum SR of 0.29 or higher
- Or materials with a demonstrated surface temperature reduction of at least 10°F compared to conventional concrete or asphalt
To meet the above standards, the project applicantApplicant may implement one or more of the following:
▪ Use Energy Star®-rated roofing products or materials listed in the Cool Roof Rating Council (CRRC) directory. ▪ Apply reflective coatings or single-ply membranes with compliant SR and TE values. ▪ Install light-colored or permeable pavers, cool concrete, or coated surfaces for decks and walkways, such as permeable interlocking concrete pavers, porous asphalt, permeable concrete, geocell systems, or bio-asphalt.
▪ Incorporate green roofs or vegetated shading structures as alternative compliance pathways (subject to City approval).

Monitoring and Reporting shall include:
▪ Submittal of roofing and hardscaping material specifications to the City of Garden Grove Building Division prior to issuance of building permits.
▪ City inspectors shall verify installation during final inspection and prior to issuance of the final certificate of occupancy.
(CAPCOA Measure E-21)
MM-GHG-9. Renewable Energy. The Project Applicant or designee shall install a solar photovoltaic system capable of generating a minimum of 267,000 kilowatt hours (kWh) per year prior to issuance of certificate of occupancy. (CAPCOA Measure E-10-B)
MM-GHG-10. Water Conservation. Prior to receiving the final certificate of occupancy, the Project Applicant applicant or designee shall submit a Water Conservation Compliance Report to the City of Garden Grove for review 568
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and approval. The Project shall achieve a minimum 10% reduction in total water use compared to the baseline of 167 gallons per room per day as identified in the Water Supply Assessment (Psomas 2022). This equates to a target of no more than 150.3 GPCD at full occupancy. The Water Conservation Compliance Report shall include product specifications for all water-saving fixtures and systems, landscape and irrigation plans, greywater system design and capacity documentation, post-occupancy water use monitoring plan for the first 12 months after occupancy. To meet or exceed the performance standard, the Project may implement a combination of the following water conservation strategies:
▪ Low-Flow Water Fixtures for guest rooms and public area ▪ Smart Irrigation System - outdoor landscaping shall include weather-based irrigation controllers and drought-resistant landscaping to minimize outdoor water use. ▪ Greywater Recycling.
(CAPCOA Measures W-2, W-5, and W-7)
MM-GHG-11. Waste Reduction. Prior to issuance of the final certificate of occupancy, the Project Applicant applicant or designee shall submit a Waste Management, Recycling, and Composting Plan to the City of Garden Grove for review and approval. The program shall be implemented on site at the Project location and apply to all operational areas, including guest services, food and beverage operations, maintenance, and administrative functions. The waste reduction program shall be fully implemented during Project operations. The Plan shall specify a minimum diversion of 25% of municipal solid waste, including organics, generated on site from landfill disposal.

The Waste Management, Recycling, and Composting Plan may include but not be limited to the following:
▪ Recycling Program
- Labeled Provide labeled bins for recyclables and certified hauler contracts. - Promote recycled paper and other products like soap.
▪ Organics and Composting Program
- Collection of Collect food scraps and compostables.
▪ Source Reduction Measures
- Reduce single-use items and paper use.
- Ban disposable (i.e., designed to be used once and discarded) foodware items and accessories. - Allow customers to bring their own reusable items.
- Require hand soap in refillable containers.
- Do not provide water in plastic bottles or disposable single-use cups. - Do not use expanded polystyrene (i.e., Styrofoam).
- Require reusable napkins and tablecloths with recyclable disposable napkins only for takeout. - Provide hand dryers in areas accessible to customers. - Require reusable laundry bags.
- Require reusable dishware for room service.
- Offer toiletries on request rather than automatically. - Provide key cards made of non-plastic materials, including traditional metal keys or wood, bamboo, and paper options for chip-based cards.
- Incentivize returning keys to discourage waste.
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- Provide non-plastic shower caps, razors, shaving cream, slippers, eye masks, and ear plugs. - Remove minifridge items that use plastic.
- Eliminate the use of garbage bags if possible, or use garbage bags made of compostable material. - Serve employee meals with reusable dishware and cutlery and provide reusable water bottles for all employees with accessible water bottle refill stations. - Replace paper towels with reusable dish rags.
▪ Employee and Guest Education
- Staff Provide staff training and signage for guests.
▪ Monitoring and Reporting
- Track waste and submit Annual Waste Diversion Report to the City of Garden Grove.

In addition, if the hotel/operations qualify as a covered edible food generator, the Project will contract with a food recovery organization/service and keep required records. If not covered, the Project will evaluate a partnership during operator onboarding and implement if feasible. (CAPCOA Measure S-1/S-2; CAPCOA Measure S-3 is a qualitative measure in CalEEMod and is not quantified in the operational analysis) MM-GHG-12. Zero Emission Landscape Equipment. During Project operations, the Project Applicant or designee shall ensure zero-emission landscape equipment (defined as equipment that does not emit tailpipe emissions during operation) is utilized. The Project Applicant applicant or designee shall be responsible for ensuring that all landscape maintenance contractors and staff comply with this measure. All landscape maintenance activities associated with the Project shall utilize zero-emission landscaping equipment, such as electric-powered or batteryoperated tools. This requirement applies to all landscaped areas within the Project site, including but not limited to courtyards, green spaces, perimeter landscaping, and rooftop gardens. The requirement shall be implemented prior to the commencement of landscape maintenance operations. To meet or exceed the performance standard, the Project may implement a combination of the following strategies:

Electric-Powered Equipment
▪ Use of electric or battery-powered:
- Leaf blowers.
- Lawn mowers.
- Hedge trimmers.
- Edgers.
- Chainsaws.

Contractor Requirements
▪ Include zero-emission equipment requirements in all landscape maintenance contracts. ▪ Require contractors to provide documentation of equipment type and compliance.

On-Site Charging Infrastructure
▪ Install dedicated charging stations or outlets for landscape equipment. 570
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Equipment Inventory and Tracking
▪ Maintain an inventory of all landscape equipment used on site. ▪ Submit an annual compliance report to the City of Garden Grove verifying that only zero-emission equipment is in use.

Training and Education
▪ Provide training to landscape maintenance staff on the proper use and maintenance of electric equipment. ▪ Display signage or include information in sustainability reports to promote awareness. (CAPCOA Measure LL-1)
MM-GHG-13. Prohibit Woodburning dDevices, Natural Gas Fireplaces, and Fire Pits. Prior to the issuance of building permits, the Project Applicant applicant or designee shall submit building design plans for approval of the City showing the prohibition of on-site woodburning devices, natural gas fireplaces, fire pits, or other decorative combustion features throughout the Project site. Prior to the issuance of the final certificate of occupancy, the City shall confirm that this prohibition has been implemented.

This measure shall apply to all refrigeration and HVAC systems installed and operated within the Project site, including guest rooms, common areas, kitchens, and mechanical rooms. The Project shall ensure that:
▪ 100% of installed HVAC and refrigeration systems use refrigerants with a GWP ≤ 750, consistent with California Air Resources Board (CARB) regulations.
▪ The refrigerant management program shall achieve a minimum 10% reduction in potential refrigerant emissions compared to standard industry practices, as demonstrated through leak rate tracking and maintenance logs.

To meet or exceed the performance standard, the Project may implement a combination of the following strategies:

Mechanical Equipment
▪ Install microchannel heat exchangers in A/C equipment in place of conventional heat exchangers.

Use of Low-GWP Refrigerants
▪ Select refrigerants such as R-32, R-454B, or other CARB-compliant alternatives with GWP ≤ 750. ▪ Avoid high-GWP refrigerants such as R-410A and R-404A.

Leak Detection and Prevention
▪ Install automatic leak detection systems for large-capacity systems. 571
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▪ Conduct quarterly inspections and maintain leak logs.

Refrigerant Recovery and Disposal
▪ Use certified technicians for refrigerant recovery and disposal. ▪ Maintain documentation of recovered and recycled refrigerants.

Preventive Maintenance Program
▪ Implement a scheduled maintenance plan to inspect and service HVAC and refrigeration systems. ▪ Include refrigerant charge optimization and system performance checks.

Training and Certification
▪ Ensure all HVAC technicians are EPA Section 608 certified. ▪ Provide training on low-GWP refrigerant handling and leak prevention.

Third-Party Verification
▪ Obtain third-party verification of refrigerant management practices through programs such as GreenChill or LEED Enhanced Refrigerant Management credit.

Timeline for Acquisition of Carbon Offset Credits
Construction
Prior to issuance of grading permits, the Project Applicant (or its designee) shall purchase and retire carbon offsets in a quantity sufficient to offset all construction GHG emissions in a lump sum with the quantification, performance standards, and requirements set forth below. Alternatively, construction offsets may be purchased on an annual basis by purchasing the first phase of construction offsets prior to start of grading and then purchasing offsets for each following year by December 31 of the year preceding the new year in which construction will occur. Annual construction GHG emission offsets shall also be subject to the same quantification, performance standards, and requirements set forth below.

Operation
Prior to issuance of the final certificate of occupancy, the Project Applicant or its designee shall purchase and retire carbon offsets in a quantity sufficient to offset, for a 30-year period following occupancy of the Project, the construction and operational GHG emissions from Project to the 1,400 MT CO2e per year threshold, consistent with the quantification, performance standards and requirements set forth below. Alternatively, the Project Applicant or 572
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its designee may purchase and retire annual operational GHG offsets for a period of 30 years by December 31 of the year preceding each new year after the issuance of the final certificate of occupancy. Annual operational GHG emission offsets shall also be subject to the same quantification, performance standards, and requirements set forth below.

Quantification of GHG Emissions and Reductions Required.

Construction
The estimated total construction GHG emissions to be offset are 3,362.30 MT CO2e if purchased in a lump sum. If purchased on an annual basis, the following schedule provides the estimated annual emissions and date of compliance.

Year Offsets Required (MT CO2e) Purchase and Retirement Deadline 1 402.52 Prior to issuance of grading permits
2 1,434.02 December 31st of Year 1
3 1,410.81 December 31st of Year 2
4 114.95 December 31st of Year 3
Total 3,362.30 N/A
Notes: MT CO2e = metric tons of carbon dioxide equivalent; N/A = not applicable.

Operation
The estimated operational emissions are 7,408.02 MT CO2e. To mitigate operational emissions below the 1,400 MT CO2e threshold, the Project would purchase and retire one lump sum of 180,270.60 MT CO2e of offsets ([7,408.02 MT CO2e − 6,009.02 [(offsets]) = 1,399 MT CO2e remaining)]; 6,009.02 MT CO2e × 30-year life = 180,270.60 MT CO2e; or purchase and retire 6,002.46 MT CO2e of offsets on an annual basis for 30 years. The following schedule provides the estimated offset emissions and dates of compliance under the scenarios where credits are purchased and retired in a lump sum or on an annual basis.

Scenario Offsets Required (MT CO2e) Purchase and Retirement Deadline Lump Ssum 180,270.60 Prior to issuance of certificate of occupancy Annual Bbasis
30-year term
6,009.02 Prior to issuance of certificate of occupancy for Year 1 and December 31st of preceding year.

Note: MT CO2e = metric tons of carbon dioxide equivalent.

If the Project Applicant or its designee selects the scenario where the credits are purchased on something other than in one lump sum initially, they can purchase and retire the remaining offsets required in a lump sum in accordance with the remaining term and conditions outlined herein. If the Project Applicant or its designee selects the Annual Basis scenario initially, they can purchase and retire the remaining offsets required in a lump sum in accordance with the remaining term and conditions outlined herein.

Carbon Offset Standards – Eligible Registries, Acceptable Protocols, Defined Terms, and Geographic Priorities
“Carbon offset” shall mean an instrument, credit or other certification verifying the reduction of GHG emissions issued by the following CARB-accredited registries: Climate Action Reserve, the American Carbon Registry, or Verra 573
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(formerly, the Verified Carbon Standard); as well as credits issued for projects listed on the California Carbon Sequestration and Climate Resiliency Project Registry, which is maintained by the California Natural Resources Agency and may provide additional offsets. This shall include, but is not limited to, an instrument, credit or other certification issued by these registries for GHG reduction activities. The Project shall neither purchase offsets from the Clean Development Mechanism registry nor purchase offsets generated under Clean Development Mechanism protocols.

To be eligible under this mitigation measure, carbon offsets must satisfy the “Reporting and Enforcement Standards” below and demonstrate that each registry shall continue its existing practice of requiring the following for the development and approval of protocols or methodologies:

1. Adherence to established GHG accounting principles set forth in the International Organization for Standardization (ISO) 14064, Part 2 or the World Resources Institute/World Business Council for Sustainable Development (WRI/WBCSD) Greenhouse Gas Protocol for Project Accounting; and

2. Oversight of the implementation of protocols and methodologies that define the eligibility of carbon offset projects and set forth standards for the estimation, monitoring and verification of GHG reductions achieved from such projects. The protocols and methodologies shall:
a. Be developed by the registries through a transparent public and expert stakeholder review process that affords an opportunity for comment and is informed by science; b. Incorporate standardized offset crediting parameters that define whether and how much emissions reduction credit a carbon offset project should receive, having identified conservative project baselines and the length of the crediting period and considered potential leakage and quantification uncertainties;
c. Establish data collection and monitoring procedures, mechanisms to ensure permanency in reductions, and additionality and geographic boundary provisions; and, d. Adhere to the principles set forth in the program manuals of each of the aforementioned registries, as such manuals are updated from time to time. The current registry documentation, includes the Climate Action Reserve’s Reserve Offset Program Manual2 (April 2024) and Climate Forward Program Manual3 (December 2021); the American Carbon Registry’s The ACR Standard, Requirements and Specifications for the Quantification, Monitoring, Reporting, Verification, and Registration of ProjectBased GHG Emissions Reductions and Removals4 (July 2023); and, Verra’s VCS Standard, Program Guide5 (August 2023) and Methodology Requirements6 (October 2023).

The City has reviewed the registries’ methodologies and has determined that protocols established pursuant to such methodologies – including updates to those protocols and methodologies as may occur from time to time by the registries in accordance with the registry documentation listed in the prior paragraph to ensure the continuing efficacy of the reduction activities – are eligible for use under this mitigation measure.

The carbon offsets purchased to satisfy this measure must represent the reduction or sequestration of one MT CO2e that is “not otherwise required” (CEQA Guidelines Section 15126.4(c)(3)). The carbon offsets must achieve the standard of additional, real, permanent, quantifiable, verifiable, and enforceable reductions, which are defined 2 https://climateactionreserve.org/wp-content/uploads/2024/04/Reserve-Program-Manual-v9.2.pdf. 3 https://climateforward.org/wp-content/uploads/2021/12/Climate-Forward-Program-Manual-December-2021_12-FINAL.pdf. 4 https://acrcarbon.org/wp-content/uploads/2023/10/ACR-Standard-v8.0.pdf. 5 https://verra.org/documents/vcs-program-guide-v4-4/.
6 https://verra.org/documents/vcs-methodology-requirements-v4-4/. 574
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for purposes of this mitigation measure as follows consistent with the applicable provisions in the California Code of Regulations, Title 17:

1. “Additional” means that the carbon offset is not otherwise required by law or regulation, and not any other GHG emissions reduction that otherwise would occur.

3. “Verifiable” means that the GHG reduction underlying the carbon offset is well documented, transparent and set forth in a document prepared by an independent verification body that is accredited through the American National Standards Institute (ANSI).

4. “Permanent” means that the GHG reduction underlying the carbon offset is not reversible; or, when GHG reduction may be reversible, that a mechanism is in place to replace any reversed GHG emission reduction.

5. “Quantifiable” means the ability to accurately measure and calculate the GHG reduction relative to a project baseline in a reliable and replicable manner for all GHG emission sources and sinks included within the boundary of the carbon offset project, while accounting for uncertainty and leakage.

6. “Enforceable” means that the implementation of the GHG reduction activity must represent the legally binding commitment of the offset project developer to undertake and carry it out.

The City has reviewed and determined that methodologies and protocols established by American Climate Registry, Climate Action Reserve, and Verra establish and require carbon offset projects to comply with standards designed to achieve additional, real, permanent, quantifiable, verifiable and enforceable reductions. Additionally, the “Reporting and Enforcement Standards” below shall ensure that the requirements of this mitigation measure will be enforced, as the City has authority to hold the applicantApplicant accountable and to take appropriate corrective action if it determines that any carbon offsets do not comply with the requirements herein.

Such criteria and performance standards are intended only to further construe the standards under CEQA for mitigation related to GHG emissions (see, e.g., State CEQA Guidelines Section 15126.4(a), (c)), and are not intended to apply or incorporate the requirements of any other statutory or regulatory scheme not applicable to the Project (e.g., the Cap-and-Trade Program).
7 For purposes of this provision, offset credits will be deemed “unavailable” if they are either unobtainable generally from the CARBaccredited registries, or if on a per-unit basis if such a credit is otherwise available: (a) for offset credits within the City of Garden Grove, more than 2 times as costly as offset credits within the County of Orange, but not within the City of Garden Grove; (b) for offset credits within the County of Orange, more than 5 times as costly as offset credits within California, but not within the County of Orange; or (c) for offset credits within the United States, sufficient offset credits within California are available for purchase at any cost.
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Monitoring, Reporting and Enforcement Standards
Prior to the timeline identified in the initial section of this mitigation measure, the Project Applicant or its designee shall submit documentation in the form of a report to the City that identifies the quantity of emission reductions required by this mitigation measure, as well as the carbon offset proposed for acquisition to achieve compliance with this measure. For purposes of demonstrating that each offset is additional, real, permanent, quantifiable, verifiable and enforceable, the reports shall include: (i) the applicable protocol(s) and methodologies associated with the carbon offsets, (ii) the third-party verification report(s) and statement(s) affiliated with the carbon offset projects, (iii) the unique serial numbers assigned by the registry(ies) to the carbon offset, which serves as evidence that the registry has determined the carbon offset project to have been implemented in accordance with the applicable protocol or methodology and ensures that the offsets cannot be further used in any manner, and (iv) the carbon offset meets the locational attributes as specified by this mitigation measure and verified through a market survey report prepared by a carbon offset broker that identifies the carbon registry listings reviewed for carbon offset availability, including the related date of inquiry.

The Project Applicant (or its designee) shall select and retain at least one independent, third-party expert on GHG mitigation and offsets to review the documentation provided by the Applicant (or its designee) relating to, among other data, construction- and operation-related emissions, and provide a report with analysis and recommendations to the City (with supporting materials), on whether the Project has complied with the off-site GHG emissions reduction measures set forth in this mitigation measure. The Project Applicant’s (or its designee’s) selection of each expert, who shall not be a current or former employee or agent of the Project Applicant (or its designee), shall be subject to the approval of the City Attorney, which shall not be unreasonably withheld. The Project Applicant (or its designee) shall retain the expert(s) for all offset credit submissions made to the City until all offsets required this mitigation measure are acquired and accepted by the City.

If the City determines that the Project’s carbon offsets do not meet the requirements of this mitigation measure, the City shall provide a detailed explanation of the basis for the City’s determination. Carbon offsets not approved by the City as meeting the requirements of this mitigation measure cannot be used to reduce Project GHG emissions and the Applicant will be required to submit qualifying carbon offsets accepted by the City prior to the applicable timeframe specified in the first section of this mitigation measure. (CAPCOA Measure M-2)

1.8, Summary of Environmental Impacts and Mitigation, pages 1-27 through 1-29 MM-TRA-1. Implement Commute Trip Reduction Marketing (T-7): The Project applicantApplicant shall implement a marketing strategy to promote the Project site employer’s Commute Trip Reduction (CTR) program. Information sharing and marketing promote and educate employees about their travel choices to the employment location beyond driving such as carpooling, taking transit, walking, and biking, thereby reducing VMT and GHG emissions. 576
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However, to ensure that CTR achieves VMT reduction of at least 4%, the following measures will be incorporated:
a) The applicantApplicant shall provide on -site or online commuter information services to employees. The applicantApplicant shall also distribute a quarterly newsletter with tips, success stories and updates to ensure education and encouragement for the CTR program. b) The CTR shall require the Project applicantApplicant or their designee to appoint a Commute Program Coordinator to oversee the implementation and management of the marketing strategy. c) The applicantApplicant shall ensure on-site or online subsidized transit pass sales are available to all employees.
d) The applicantApplicant shall provide guaranteed ride home service by matching employees with other employees or providing access to platforms such as Rideharing.com and Lyft which that connect riders for daily commutes with nearby drivers.
e) A minimum of 10 preferential parking spaces for carpools/vanpools shall be provided. (CAPCOA Measures T-7, T-9-B)
MM-TRA-2. Provide End-of-Trip Bicycle Facilities (T-10): The Project shall install and maintain end-of-trip bicycle facilities for employee use. End-of-trip facilities include bike parking, bike lockers, showers, and personal lockers.

The provision and maintenance of secure bike parking and related facilities encourages commuting by bicycle, thereby reducing VMT and GHG emissions. The Project design includes on-site bicycle racks to accommodate a minimum of 38 short-term bicycle parking spaces and provide bicycle rentals for hotel guests on the ground level and 32 secure long-term bicycle parking spaces for employees; and additionally, locker and shower facilities will be provided for employees. Although it is not a mandatory requirement, the Applicant shall install a self-service bicycle repair station adjacent to the guest and employee bicycle parking spaces. (CAPCOA Measure T-10)

3.2.3 Changes to Chapter 3, Project Description
Section 3.4.3, Project Design Features
The following summarizes the Project Design Features (PDFs) that are incorporated into the Project relative to the analysis in this SEIR and that will be included in the conditions of approval and/or Supplemental Mitigation Monitoring and Reporting Program (MMRP). It should be noted that all the following PDFs are qualitative/supporting measures. Therefore, for purposes of quantifying the Project’s GHG emissions, no GHG reductions were taken from implementation of these measures.

PDF-28 The Project amenities shall be available to registered hotel guests only. There will be no day passes allowed.

PDF-29 The Project amenities include a self-service bicycle repair station adjacent to the guest and employee bicycle parking spaces.

3.2.4 Changes to Section 4.1, Greenhouse Gas Emissions
Section 4.1.4, Approach and Methodology, page 4.1-26
The California Emissions Estimator Model (CalEEMod) 2022 Version 2022.1.1.30 was used to estimate emissions from construction and operation of the Project (CAPCOA 2022). CalEEMod is a computer model developed in 577
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cooperation with air districts throughout the state to quantify criteria air pollutant and GHG emissions associated with construction activities and operation of a variety of land use projects. CalEEMod input parameters, including the land use type used to represent the Project and its size, construction schedule, and anticipated use of construction equipment, were based on the experience of GHG experts and information provided by the City, or the applicantApplicant, or relevant default model assumptions where Project specifics were unavailable.

Section 4.1.5, Project Design Features Previously Approved, page 4.1-31 The following summarizes the previously approved GHG related Pproject Ddesign Ffeatures (PDFs) that are incorporated into the Project. It should be noted that all the following PDFs are qualitative/supporting measures.

Therefore, for purposes of quantifying the Project’s GHG emissions and the potential significance of impacts, no GHG reductions were taken based on the implementation of these measures. A notation is provided in italics where these PDFs are based on a specific CAPCOA measure included in CalEEMod.

Section 4.1.5, Project Design Features Previously Approved, “Construction,” pages 4.1-31 through 4.1-32
PDF-4 Construction equipment should be maintained in proper tune.

Qualitative/supporting – Maintaining heavy-duty off-road construction equipment in proper tune reduces GHG emissions. When engines are well-maintained—through regular servicing, timely replacement of filters, proper lubrication, and calibration—they operate more efficiently, burn fuel more completely, and emit fewer pollutants. There is no way to quantify these reductions in CalEEMod. Potential GHG emissions reductions are not estimated.

PDF-5 All construction vehicles should be prohibited from excessive idling. Excessive idling is defined as 5 minutes or longer. (CAPCOA Measure C-2)
Qualitative/supporting – Reduction in idling time helps to reduce fuel consumption and thus GHG emissions. There is no way to quantify these reductions in CalEEMod. Potential GHG emissions reductions are not estimated.

PDF-8 For construction activities other than those addressed by MM-GHG-1 and MM-GHG-2, establish an electricity supply to the construction site and use electric powered equipment instead of dieselpowered equipment or generators, where feasible. (CAPCOA Measure C-1-A) Qualitative – Results in a reduction of diesel and gasoline use and thus GHG emissions.

Conservatively, given the uncertainty in predicting the amount of reduction and the mix of electric powered equipment and phase of construction, it is too speculative to take GHG emission reductions from this PDF.

Section 4.1.6, New Project Design Features, page 4.1-33 PDF-27 Sustainable Building Materials and Contracting. The Project will prioritize low-impact, sustainably sourced, and recyclable materials across construction and interior finishes, including low-VOC paints, Forest Stewardship Council-certified wood, and recycled-content flooring. The Project is also implementing vendor standards that require environmental product declarations and third-party certifications to verify material sustainability. .Materials shall be selected not only 578
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for their initial environmental footprint but also for durability and long-term performance, reducing the need for frequent replacement and associated waste.

In addition, the Project Applicant or their designee will include bid language requiring the contractor to prioritize sourcing within the region (e.g., Orange County/Southern California) where pricing and availability are competitive, and to document major material and subcontractor origins in the construction closeout package.

Qualitative/supporting – Sustainable building materials play a crucial role in reducing GHG emissions by addressing both embodied and operational carbon impacts in the construction sector.

Embodied carbon refers to emissions from the extraction, manufacturing, and transportation of materials, while operational carbon stems from a building’s energy use over time. It is too speculative to claim GHG reductions for sustainable building design measures because actual emissions reductions depend on uncertain factors like material sourcing, construction practices, and long-term building performance. Without verified, project-specific data, such claims lack the certainty needed for credible crediting. Accordingly, this measure is qualitative and potential GHG emissions reductions are not estimated.

Section 4.1.7, Impacts Analysis, Threshold GHG-1, “Level of Significance Before Mitigation,” page 4.1-35
The Project would have the a potentially significant impact.

Section 4.1.7, Impacts Analysis, Threshold GHG-2, “Potential to Conflict with SCAG’s RTP/SCS (Connect SoCal),” page 4.1-36
In April 2024, SCAG adopted the 2024–2050 RTP/SCS, also referred to as Connect SoCal 2024 which builds upon the prior RTP/SCS. Connect SoCal 2024 includes regional planning policies in the following categories: Mobility, Communities, Environment, and Economy. A key component of Connect SoCal is the strategic location of housing to reduce vehicle miles traveled (VMT) by placing residential development close to jobs, services, and transit.

Consistent with SB 375, the primary objective of the RTP/SCS is to guide future regional growth patterns—including the location of new residential and non-residential land uses—and transportation investments in order to achieve the state’s GHG reduction goals.

CAPCOA transportation-related measures such as T-1 (Increase Residential Density) and T-4 (Integrate Affordable and Below Market Rate Housing) are intended to support these objectives by providing strategies for siting and designing residential projects in a manner that minimizes VMT. These measures focus on increasing housing opportunities near employment centers, transit, and services, thereby reducing auto dependency. While Connect SoCal emphasizes the importance of strategically located housing at a regional level, Connect SoCal 2024 does not require the inclusion of housing within commercially designated areas for a project to be deemed consistent.

Furthermore, CAPCOA Measures T-1 and T-4 are explicitly applicable to residential development and do not require or obligate commercial projects to incorporate housing uses. Because the Proposed Project is a commercial project, these residential-focused measures are not applicable. The primary objective of the RTP/SCS is to provide guidance for future regional growth (i.e., the location of new residential and non-residential land uses) and transportation patterns throughout the region, as stipulated under SB 375 to achieve compliance with the State’s GHG reduction goals. The Connect SoCal 2024 policies are evaluated in Table 4.1-6 below. 579
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Section 4.1.7, Impacts Analysis, Threshold GHG-2, “Potential to Conflict with SCAG’s RTP/SCS (Connect SoCal),” Table 4.1-6, Table Subheading “Transportation System Management,” Policy No. 12, Column “Potential to Conflict,” page 4.1-37 Not applicable. This transportation system operational improvement policy is designed to be implemented at a regional scale and requires coordination among multiple jurisdictions, agencies, and stakeholders. As such this policy does not apply to a single project applicant like the Project applicantApplicant.

Section 4.1.7, Impacts Analysis, Threshold GHG-2, “Potential to Conflict with SCAG’s RTP/SCS (Connect SoCal),” Table 4.1-6, Table Subheading “Priority Development Areas,” Policy No. 32, Column “Potential to Conflict,” page 4.1-41 No conflict. The Project is located on an infill site that is zoned for commercial use. The inclusion of housing within a commercial-designated area is not required by Connect SoCal to be deemed consistent. The Project would provide employment opportunities along a major transportation corridor near existing transit.

The inclusion of housing within a commercial-designated area is not required by Connect SoCal to be deemed consistent. The Project would offer employment opportunities near a major transportation corridor near existing transit consistent with the General Plan. The City’s General Plan designates other areas within the City to satisfy local and regional housing needs.

Section 4.1.7, Impacts Analysis, Threshold GHG-2, “Potential to Conflict with SCAG’s RTP/SCS (Connect SoCal),” Table 4.1-6, Table Subheading “Housing the Region,” Policy No. 37, Column “Potential to Conflict,” page 4.1-42-43
Not applicable. This policy is designed to be implemented at a regional scale and requires coordination among multiple jurisdictions, agencies, and stakeholders. The inclusion of affordable housing within a commercialdesignated area is not required by Connect SoCal to be deemed consistent. The Project is located on an infill site that is General Plan designated for the visitor serving uses contemplated by the Project. The City’s General Plan designates other areas within the City to satisfy local and regional housing needs. 580
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Section 4.1.7, Impacts Analysis, Threshold GHG-2, “Potential to Conflict with SCAG’s RTP/SCS (Connect SoCal),” Table 4.1-6, Table Subheading “Housing the Region,” Policy No. 38, Column “Potential to Conflict,” page 4.1-43
Not applicable. This policy is designed to be implemented at a regional scale and requires coordination among multiple jurisdictions, agencies, and stakeholders. The Project does not require the displacement of existing housing, and the Project site is General Plan designated for the visitor serving uses contemplated by the Project.

The inclusion of housing within a commercial-designated area is not required by Connect SoCal to be deemed consistent. The City’s General Plan designates other areas within the City to satisfy local and regional housing needs.

Section 4.1.7, Impacts Analysis, Threshold GHG-2, “Potential to Conflict with SCAG’s RTP/SCS (Connect SoCal),” Table 4.1-6, Table Subheading “Housing the Region,” Policy No. 41, Column “Potential to Conflict,” page 4.1-43
Not applicable. This policy is more aspirational rather than an enforceable standard or requirement for individual projects. This policy is designed to be implemented at a regional scale and requires coordination among multiple jurisdictions, agencies, and stakeholders. The Project is located on an infill site that is General Plan designated for the visitor serving uses contemplated by the Project. The inclusion of housing within a commercial-designated area is not required by Connect SoCal to be deemed consistent. The City’s General Plan designates other areas within the City to satisfy local and regional housing needs.
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Section 4.1.7, Impacts Analysis, Threshold GHG-2, “Potential to Conflict with SCAG’s RTP/SCS (Connect SoCal),” Table 4.1-6, Table Subheading “15-Minute Commutes,” Policy No. 43, Column “Potential to Conflict,” page 4.1-43
Not applicable. This policy is designed to be implemented at a regional scale and requires coordination among multiple jurisdictions, agencies, and stakeholders. It is also more aspirational rather than an enforceable standard or requirement for individual projects. The Project is located on an infill site that is General Plan designated for the visitor serving uses contemplated by the Project. The Project would offer employment opportunities near a major transportation corridor near existing transit. The inclusion of housing within a commercial-designated area is not required by Connect SoCal to be deemed consistent.

Section 4.1.7, Impacts Analysis, Threshold GHG-2, “Potential to Conflict with SCAG’s RTP/SCS (Connect SoCal),” Table 4.1-6, Table Subheading “Climate Resilience,” Policy No. 68, Column “Potential to Conflict,” page 4.1-43
Not applicable. This policy is designed to be implemented at a regional scale and requires coordination among multiple jurisdictions, agencies, and stakeholders. As such they are beyond the control of a single project applicant.

The Project does not preclude SCAG’s ability to support integrated planning approaches for developing more housing in drier environments. The inclusion of housing within a commercial-designated area is not required by Connect SoCal to be deemed consistent. The Project is located within a commercial district specifically designated as a location for visitor serving uses like the Project. Additionally, the Project includes water conservation measures such as MM-GHG-10, which would support this policy.

Section 4.1.7, Impacts Analysis, Threshold GHG-2, “Potential to Conflict with SCAG’s RTP/SCS (Connect SoCal),” Table 4.1-6, Table Subheading “Clean Transportation,” Policy No. 55, Column “Potential to Conflict,” page 4.1-47
Not applicable. This is a region wide measure,; however, the Project would not limit SCAG’s ability to promote the equitable use of and access to clean transportation technologies.

Section 4.1.7, Impacts Analysis, Threshold GHG-2, “Potential to Conflict with SCAG’s RTP/SCS (Connect SoCal),” Table 4.1-6, Table Subheading “Clean Transportation,” Policy No. 56, Column “Potential to Conflict,” page 4.1-47
Not applicable. This policy is designed to be implemented at a regional scale and requires coordination among multiple jurisdictions, agencies, and stakeholders. As such they are beyond the control of a single project applicant.

Section 4.1.7, Impacts Analysis, Threshold GHG-2, “Potential to Conflict with State Reduction Targets and CARB’s Scoping Plan,” Table 4.1-7, Table Subheading “Sector”, Transportation,” Smart Growth/VMT, Column “Potential to Conflict,” page 4.1-58 No conflict with mitigation. The VMT goals outlined in the Scoping Plan are being pursued through a multi-prong approach that includes transforming land use and mobility options. The State is encouraging compact, infill development near high quality transit corridors to reduce VMT. The Scoping Plan does not require housing to be included within commercially zoned areas for development to be consistent with these goals. Rather, it supports a 582
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mix of land uses across the region that collectively reduce travel demand. The Project would not obstruct or interfere with agency efforts to meet this regional VMT reduction goal, including through implementation of SB 375.

The Project is a General Plan land use consistent infill commercial development within a TPA [it is located within half a mile of a major transit stop (Harbor Boulevard and Chapman Avenue intersection), based on the frequency of bus services in the City]. These characteristics would be considered smart growth and supportive of the State’s approach for achieving these VMT targets. However, as disclosed in Section 4.2 of the SEIR, the Project would have a potentially significant VMT impact which would result in a potential conflict with this strategy. The Project would implement TRA-1 and TRA-2 to reduce the VMT impact to a less than significant level. With the implementation of these mitigation measures, the Project would not conflict with this strategy.

Section 4.1.7, Impacts Analysis, Threshold GHG-2, “Potential to Conflict with City of Garden Grove General Plan,” Table 4.1-8, Table Subheading “Air Quality Element”, “Goal AQ-5,”, Column “Potential to Conflict,” page 4.1-54-55
No conflict with mitigation. The Project would construct a new resort hotel use within an infill developed area that is General Plan designated for such a visitor serving use within a TPA. These characteristics would support this goal, however without the inclusion of measures to reduce GHG emissions, the Project would potentially conflict with this goal.

The Project incorporates project design features and MM-GHG-1 through MM-GHG-14 to reduce emissions from construction and operation of the Project. With implementation of these measures, the Project would not conflict with this policy.

Section 4.1.7, Impacts Analysis, Threshold GHG-2, “Potential to Conflict with City of Garden Grove General Plan,” Table 4.1-8, Table Subheading “Air Quality Element”, “Policy AQ-5.6,”, Column “Potential to Conflict,” page 4.1-54-55
No conflict. The Project would construct a new commercial use near existing transit lines and major arterial corridors.

Section 4.1.7, Impacts Analysis, Threshold GHG-2, “Potential to Conflict with City of Garden Grove General Plan,” Table 4.1-8, Table Subheading “Safety Element”, “Policy SAF-10.10,”, Column “Potential to Conflict,” page 4.1-68-69
No conflict. The Project does not interfere with the City’s ability to implement this policy. While the Project is not mixed use, it does include jobs near existing transit within an infill urban area near residential and other commercial uses.

The City’s General Plan designates other areas within the City to satisfy local and regional housing needs, thus not including housing as part of the Project does not result in an inconsistency with the General Plan. 583
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Section 4.1.7, Impacts Analysis, Threshold GHG-2, “Potential to Conflict with City of Garden Grove General Plan,” Table 4.1-8, Table Subheading “Circulation Element”, “Policy CIR-4.1,”, Column “Potential to Conflict,” page 4.1-70
No conflict. The Project would not interfere with the City’s ability to implement this goal.

The Project would develop visitor serving uses on appropriately designated land within a TPA on a previously developed infill site. These Project characteristics would be supportive of this policy and thus would not conflict.

Section 4.1.8, Mitigation Measures, Introduction, page 4.1-75 Mitigation measures (MM) under CEQA are selected based on their ability to substantially lessen or avoid significant environmental impacts while considering feasibility. In CEQA, “feasible” means capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, and technological factors. The goal is to balance effective environmental protection with realistic implementation. A notation in italics is provided where these mitigation measures are attributable to a CAPCOA measure included in CalEEMod.

CAPCOA is a nonprofit professional association of air pollution control and air quality management district officers.

It is not a state agency and does not have any regulatory authority. For this reason, CAPCOA measures are voluntary guidance tools, not mandatory regulatory requirements. The CAPCOA Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity (CAPCOA 2024) is a resource that lead agencies and project applicants may consult when identifying and quantifying potential GHG emission reductions for CEQA compliance purposes, but it does not establish any legal or regulatory standards.

Neither CEQA nor any state regulation requires a project to evaluate its consistency with, or to adopt measures in, CAPCOA’s guidance.

Section 4.1.8, Mitigation Measures, “Construction (On-Site) Mitigation Measures,” page 4.1-76 MM-GHG-1. Construction Equipment Electrification.Electric Construction Equipment. Prior to issuance of building permits, the Project applicant Applicant’s or designee’s contractor shall submit a Construction Equipment Emissions Minimization Plan for City of Garden Grove (City) approval that:
(1) Identifies all off-road equipment anticipated by phase. (2) Requires generators, cranes, electric scissor/boom lifts, forklifts/telehandlers (where feasible), welders (where feasible), and electric/solar light towers when commercially available. (3) Requires grid power for temporary construction power. (4) Where electric equipment is not available for a listed task, documents non-availability (size/class, delivery lead time, site constraints) and requires the cleanest feasible alternative (Tier 4 Final/zero-emission alternatives as available).

In addition, the Project shall limit air compressors used during the architectural coating/painting phase to equipment that is electric-powered Compliance shall be demonstrated through equipment lists, rental records, and weekly logs and shall be summarized in a post-construction compliance 584
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memo for the Supplemental Mitigation Monitoring and Reporting Program (Supplemental MMRP) file. shall submit documentation to the City of Garden that temporary power will be established to the Project site during vertical construction. All generator(s) and crane(s) shall be electric-powered.

In addition, the Project shall limit air compressors used during the architectural coating/painting phase to equipment that is electric-powered. (CAPCOA Measure C-1-A) MM-GHG-1 is quantified in the construction analysis. Because this is a conservative measure, only the generators, cranes, and air compressors are presumed to be electric to estimate potential emission reductions.

Section 4.1.8, Mitigation Measures, pages 4.1-76 through 4.1-82 MM-GHG-3. Construction Debris Recycling. Prior to the start of construction, the Project’s contractor shall develop a Construction Waste Management Plan (Plan) for submittal and approval to the City of Garden Grove. The Construction Waste Management Plan Plan shall recycle or salvage nonhazardous construction debris, such that a minimum target of 75% is achieved. including but not limited to wood, metal, concrete, asphalt, and other reusable materials generated during construction activities. The contractor shall implement the Plan to achieve a minimum diversion target of 75% of non-hazardous construction and demolition debris from landfills, exceeding the City’s current 65% diversion requirement. This will exceed the City’s current target of 65% diversion. (CAPCOA Measure S-4)
MM-GHG-3 is not quantified in the construction analysis.

Operational (On-siteSite) Mitigation Measures
MM-GHG-4. Electric Vehicle Charging Infrastructure. Prior to issuance of building permits, the Project applicant Applicant or designee shall submit a site plan to the City of Garden Grove for approval noting the location of electric vehicle infrastructure and charging stations. Prior to issuance of the final certificate of occupancy, the Project applicantApplicant or designee shall provide electric vehicle (EV) charging infrastructure within the Project site as required by the applicable California Green Building Standards Code, but that, at a minimum, meets or exceeds 2022 California Green Building Standards Code, Tier 2 standards. Tier 2 requires approximately 225 parking spaces to be EV capable, and 75 spaces to be equipped with EV Supply Equipment (EVSE). The Project shall install a minimum of 225 EV capable spaces and 100 EVSE spaces. (CAPCOA Measure T-14) MM-GHG-4 is not quantified in the operational analysis.

MM-GHG-5. Guest Vehicle Trip Reductions. Prior to issuance of building permits, the Project applicant Applicant shall submit a site plan to the City of Garden Grove for approval identifying where pedestrian and bicycle connections to adjacent facilities will be provided and where bicycle parking spaces will be provided. The City shall verify the inclusion of pedestrian and bicycle infrastructure prior to the issuance of the final certificate of occupancy. The Project applicantApplicant or designee shall ensure that, at a minimum, the following trip reduction measures are implemented during Project operations to reduce the number of auto-based trips generated by the Project and to encourage the use of transit, bicycling, and walking. 585
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▪ Improve the walkability and design of the Project by providing pedestrian and bicycling connections within the Project site and to adjacent off-site facilities (i.e.g., sidewalks, crosswalks, wayfinding signage, etc.).
▪ Provide secure on-site bicycle racks to accommodate a minimum of 38 bicycle parking spaces and provide bicycle rentals for hotel guests.
▪ Alternative transportation services such bike rentals and transit information shall be seamlessly integrated into the guest experience, making alternative modes of travel easy to understand, access, and use.
▪ Hotel management/concierge should provide information that promotes walking, bicycling and public transit options to nearby attractions. This should include real-time transit information provided through dedicated monitors, interactive electronic displays, websites, or mobile applications identifying on local bus routes and schedules, and as well as wayfinding to the existing transit stops along Harbor Boulevard within the Project vicinity. ▪ Provide a dedicated shuttle service linking the hotel to nearby shopping and entertainment destinations, prioritizing battery‑electric vehicles where route length and charging logistics allow; the program may be operated under a vendor contract with scheduled runs during peak guest activity and on-demand service for special events. ▪ Hotel management will make available transit passes for purchase and provide clear wayfinding to public transit and shuttle services.
▪ Qualitative assessments (e.g., user satisfaction surveys, walk audits, guest feedback) shall be regularly conducted to evaluate the effectiveness of trip reduction strategies. ▪ An annual report summarizing how transportation options are being used, guest perceptions, and planned improvements shall be submitted to the City. (CAPCOA Measures T-34, T-38, T-43, and T-44)
MM-GHG-5 is not quantified in the operational analysis.

MM-GHG-6. Limit Large Diesel Trucks During Operation. Prior to issuance of certificate of occupancy, the Project applicant Applicant or designee shall submit a Truck Delivery Management Plan to the City of Garden Grove that documents how truck deliveries will be restricted and monitored. The Project applicantApplicant or designee shall implement a monitoring program to restrict the number of large diesel trucks coming to the site (i.e., for deliveries, trash collection, or other services) to an average of 10 trucks per day or less. This restriction is specifically applicable to trucks classified as medium-heavy duty and heavy-heavy duty with gross vehicle weight (GVW) greater than 19,500 pounds. Annual reports summarizing heavy-duty truck trips shall be provided to the City of Garden Grove. (CAPCOA Measure C-2)
MM-GHG-6 is quantified in the operational analysis.

MM-GHG-7. Building Energy Efficiency Measures. Prior to issuance of building permits, the Project applicant Applicant or designee shall submit documentation of building energy efficiency measures to the City of Garden Grove, such that a minimum of 15% above 2022 Title 24 Building Envelope Energy Efficiency Standards is achieved. Energy efficiency measures shall include, at a minimum, the following:
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1. LED Lighting – High-lumen LED light fixtures shall be used exclusively for the lighting of spaces throughout the Project that require 8 to 10 watts per fixture.

2. Energy efficient lighting shall be incorporated into all on-site lighting and energy-efficient appliances shall be incorporated into Project operations.

3. HVAC Optimization – The HVAC system shall include the following:
a. Electric heat pumps will be used for space heating and domestic hot water, with all systems integrated and monitored by the Project Building Management System for performance optimization, fault detection, and energy tracking.to heat spaces and water using a heat exchanger and will be monitored by the Project Building Management System (BMS). b. Smart thermostats, which include a motion sensor detector and door/window open sensors, will be installed in each guest room.
c. The central plant will utilize a Combination Plant with SmartPlate EV.

4. Glazing – All glazing for the tower and exterior public spaces shall be installed with Low-E glass [U-factor (thermal transmittance) ≤ 0.28 and Solar Heat Gain Coefficient (SHGC) ≤ 0.23.

5. Energy Management System – The Project shall use advanced systems to monitor and optimize energy use in real time.

6. Benchmarking and Monitoring – The Project shall incorporate an Energy Star Portfolio Management system to track and manage energy consumption.

7. Third-Party Verification/LEED Certification – The Project shall obtain third-party HVAC commissioning verification or LEED certification of Gold to Platinum to verify energy savings.

MM-GHG-8. Cool Roof/Deck. Prior to issuance of building permits, the Project applicant Applicant or designee shall submit plans to the City for approval that require cool roof and cool deck surfaces to be included as part of the Project for the podium and tower consistent with the specifications provided below.
▪ Cool Roof Installation: All roofing materials shall meet or exceed the California Title 24, Part 6 requirements for cool roofs, based on roof slope:
- Low-sloped roofs (≤ 2:12 pitch):
- Aged Solar Reflectance (SR) ≥ 0.63
- Thermal Emittance (TE) ≥ 0.75
- Or Solar Reflectance Index (SRI) ≥ 75
- Steep-sloped roofs (> 2:12 pitch):
- Aged SR ≥ 0.20
- TE ≥ 0.75
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- Or SRI ≥ 16
▪ Cool Deck Surfaces: All exterior hardscape surfaces exposed to sunlight (e.g., pool decks, patios, walkways) shall use high-albedo materials or cool surface coatings with:
- Minimum SR of 0.29 or higher
- Or materials with a demonstrated surface temperature reduction of at least 10°F compared to conventional concrete or asphalt
To meet the above standards, the pProject aApplicant may implement one or more of the following:
▪ Use Energy Star®-rated roofing products or materials listed in the Cool Roof Rating Council (CRRC) directory.
▪ Apply reflective coatings or single-ply membranes with compliant SR and TE values. ▪ Install light-colored or permeable pavers, cool concrete, or coated surfaces for decks and walkways, such as permeable interlocking concrete pavers, porous asphalt, permeable concrete, geocell systems, or bio-asphalt.
▪ Incorporate green roofs or vegetated shading structures as alternative compliance pathways (subject to City approval).

MM-GHG-9. Renewable Energy. The Project Applicant or designee shall install a solar photovoltaic system capable of generating a minimum of 267,000 kilowatt hours (kWh) per year prior to issuance of certificate of occupancy. (CAPCOA Measure E-10-B)
MM-GHG-9 is quantified in the operational analysis.

MM-GHG-10. Water Conservation. Prior to receiving the final certificate of occupancy, the Project applicant Applicant or designee shall submit a Water Conservation Compliance Report to the City of Garden Grove for review and approval. The Project shall achieve a minimum 10% reduction in total water use compared to the baseline of 167 gallons per room per day as identified in the Water Supply Assessment (Psomas 2022). This equates to a target of no more than 150.3 GPCD at full occupancy. The Water Conservation Compliance Report shall include product specifications for all water-saving fixtures and systems, landscape and irrigation plans, greywater system design and capacity documentation, post-occupancy water use monitoring plan for the first 12 months after occupancy. To meet or exceed the performance standard, the Project may implement a combination of the following water conservation strategies:
▪ Low-Flow Water Fixtures for guest rooms and public areas. 588
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▪ Smart Irrigation System – outdoor landscaping shall include weather-based irrigation controllers and drought-resistant landscaping to minimize outdoor water use. ▪ Greywater Recycling.
(CAPCOA Measures W-2, W-5, and W-7)
MM-GHG-10 is quantified in the operational analysis.

MM-GHG-11. Waste Reduction. Prior to issuance of the final certificate of occupancy, the Project applicant Applicant or designee shall submit a Waste Management, Recycling, and Composting Plan to the City of Garden Grove for review and approval. The program shall be implemented on site at the Project location and apply to all operational areas, including guest services, food and beverage operations, maintenance, and administrative functions. The waste reduction program shall be fully implemented during Project operations. The Plan shall specify a minimum diversion of 25% of municipal solid waste, including organics, generated on site from landfill disposal. The Waste Management, Recycling, and Composting Plan may include but not be limited to the following:
▪ Recycling Program
- Provide Llabeled bins for recyclables and certified hauler contracts. - Promote recycled paper and other products like soap.
▪ Organics and Composting Program
- Collection of food scraps and compostables.
▪ Source Reduction Measures
- Reduce single-use items and paper use.
- Ban disposable (i.e., designed to be used once and discarded) foodware items and accessories.
- Allow customers to bring their own reusable items.
- Require hand soap in refillable containers.
- Do not provide water in plastic bottles or disposable single-use cups. - Do not use expanded polystyrene (i.e., Styrofoam).
- Require reusable napkins and tablecloths with recyclable disposable napkins only for takeout.
- Provide hand dryers in areas accessible to customers. - Require reusable laundry bags.
- Require reusable dishware for room service.
- Offer toiletries on request rather than automatically. - Provide key cards made of non-plastic materials, including traditional metal keys or wood, bamboo, and paper options for chip-based cards.
- Incentivize returning keys to discourage waste.
- Provide non-plastic shower caps, razors, shaving cream, slippers, eye masks, and ear plugs.
- Remove minifridge items that use plastic.
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- Eliminate the use of garbage bags if possible, or use garbage bags made of compostable material.
- Serve employee meals with reusable dishware and cutlery and provide reusable water bottles for all employees with accessible water bottle refill stations. - Replace paper towels with reusable dish rags.
▪ Employee and Guest Education
- Provide staff Staff training and signage for guests.
▪ Monitoring and Reporting
- Track waste and submit Annual Waste Diversion Report to the City of Garden Grove.

MM-GHG-12. Zero Emission Landscape Equipment. During Project operations, the Project Applicant or designee shall ensure zero-emission landscape equipment (defined as equipment that does not emit tailpipe emissions during operation) is utilized. The Project applicant Applicant or designee shall be responsible for ensuring that all landscape maintenance contractors and staff comply with this measure. All landscape maintenance activities associated with the Project shall utilize zero-emission landscaping equipment, such as electric-powered or battery-operated tools. This requirement applies to all landscaped areas within the Project site, including but not limited to courtyards, green spaces, perimeter landscaping, and rooftop gardens. The requirement shall be implemented prior to the commencement of landscape maintenance operations. To meet or exceed the performance standard, the Project may implement a combination of the following strategies:

Electric-Powered Equipment
▪ Use of electric or battery-powered:
- Leaf blowers.
- Lawn mowers.
- Hedge trimmers.
- Edgers.
- Chainsaws.

Contractor Requirements
▪ Include zero-emission equipment requirements in all landscape maintenance contracts. ▪ Require contractors to provide documentation of equipment type and compliance. 590
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On-Site Charging Infrastructure
▪ Install dedicated charging stations or outlets for landscape equipment.

Equipment Inventory and Tracking
▪ Maintain an inventory of all landscape equipment used on site-site. ▪ Submit an annual compliance report to the City of Garden Grove verifying that only zeroemission equipment is in use.

MM-GHG-13. Prohibit Woodburning dDevices, Natural Gas Fireplaces, and Fire Pits. Prior to the issuance of building permits, the Project applicant Applicant or designee shall submit building design plans for approval of the City showing the prohibition of on-site woodburning devices, natural gas fireplaces, fire pits, or other decorative combustion features throughout the Project site. Prior to the issuance of the final certificate of occupancy, the City shall confirm that this prohibition has been implemented.

MM -GHG-13 is not quantified in the operational analysis.

MM-GHG-14. Refrigerant Management Program. Prior to issuance of mechanical permits, the Project Applicant or designee shall develop and submit a Refrigerant Management Program to the City of Garden for review and approval. The Project applicant Applicant or designee shall be responsible for developing, implementing, and maintaining the refrigerant management program in coordination with HVAC contractors and facility operations staff. The Refrigerant Management Program shall include the use of low-GWP refrigerants (e.g., R-32 or better) and incorporate best management practices to reduce emissions from service, operation, and disposal of refrigerants. This measure shall apply to all refrigeration and HVAC systems installed and operated within the Project site, including guest rooms, common areas, kitchens, and mechanical rooms. The Project shall ensure that:
▪ 100% of installed HVAC and refrigeration systems use refrigerants with a GWP ≤ 750, consistent with California Air Resources Board (CARB) regulations. ▪ The refrigerant management program shall achieve a minimum 10% reduction in potential refrigerant emissions compared to standard industry practices, as demonstrated through leak rate tracking and maintenance logs.
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To meet or exceed the performance standard, the Project may implement a combination of the following strategies:

Mechanical Equipment
▪ Install microchannel heat exchangers in A/C equipment in place of conventional heat exchangers.

Use of Low-GWP Refrigerants
▪ Select refrigerants such as R-32, R-454B, or other CARB-compliant alternatives with GWP ≤ 750. ▪ Avoid high-GWP refrigerants such as R-410A and R-404A.

Leak Detection and Prevention
▪ Install automatic leak detection systems for large-capacity systems. ▪ Conduct quarterly inspections and maintain leak logs.

Refrigerant Recovery and Disposal
▪ Use certified technicians for refrigerant recovery and disposal. ▪ Maintain documentation of recovered and recycled refrigerants.

Training and Certification
▪ Ensure all HVAC technicians are EPA Section 608 certified. ▪ Provide training on low-GWP refrigerant handling and leak prevention.

Third-Party Verification
▪ Obtain third-party verification of refrigerant management practices through programs such as GreenChill or LEED Enhanced Refrigerant Management credit.

Prior to issuance of certificate of occupancy, the City of Garden Grove will verify that the equipment specified in the Refrigerant Management Program has been installed. Ongoing compliance shall be performed by the Project applicant Applicant or their designee. (CAPCOA Measures R-1, R-4, R-5, R-6, and R-7)
MM- GHG-14 is quantified in the operational analysis.
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Section 4.1.8, Mitigation Measures, “Carbon Offsets,” page 4.1-84 ▪ The California Natural Resources Agency’s Final Statement Of Reasons For Regulatory Action for the CEQA Guidelines Amendments (2009) also supports the use of GHG credits: “Proposed subdivision (c)(3) recognizes the availability of various offsite mitigation measures. Such measures could include, among others, the purchase of carbon offsets, community energy conservation projects, and off-site forestry projects.”
For these purposes, the City will require offsets purchased from the following CARB-accredited registries: Climate Action Reserve, the American Carbon Registry, or Verra (formerly, the Verified Carbon Standard); as well as credits issued for projects listed on the California Carbon Sequestration and Climate Resiliency Project Registry, which is maintained by the California Natural Resources Agency to be adequate to meet the offset requirements described herein.

Verra’s Verified Carbon Units (VCUs) are issued only after projects undergo a rigorous validation and verification process. Each VCU represents one ton of CO₂e-equivalent emissions reduced or removed and must meet quality assurance principles ensuring that reductions are real, measurable, additional, permanent, independently verified, conservatively estimated, uniquely numbered, and transparently listed.

Section 4.1.8, Mitigation Measures, “Carbon Offsets,” pages 4.1-84 through 4.1-89 MM-GHG-15. Carbon Offsets – The Project Applicant (or its designee) shall implement the following carbon offsets in accordance with the Project’s construction and operational phases as outlined below.

Operation
Prior to issuance of the final certificate of occupancy, the Project Applicant or its designee shall purchase and retire carbon offsets in a quantity sufficient to offset, for a 30-year period following occupancy of the Project, the construction and operational GHG emissions from the Project to the 1,400 MT CO2e per year threshold, consistent with the quantification, performance standards and requirements set forth below. Alternatively, the Project Applicant or its designee may purchase and retire annual operational GHG offsets for a period of 30 years by December 31 of the year preceding each new year after the issuance of the final certificate of occupancy. Annual operational GHG emission offsets shall also be subject to the same quantification, performance standards, and requirements set forth below.
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Quantification of GHG Emissions and Reductions Required Construction
The estimated total construction GHG emissions to be offset are 3,362.30 MT CO2e if purchased in a lump sum. If purchased on an annual basis, the following schedule provides the estimated annual emissions and date of compliance.

Note: MT CO2e = metric tons of carbon dioxide equivalent.

Carbon Offset Standards – Eligible Registries, Acceptable Protocols, Defined Terms, and Geographic Priorities
“Carbon offset” shall mean an instrument, credit or other certification verifying the reduction of GHG emissions issued by the following CARB-accredited registries: Climate Action Reserve, the American Carbon Registry, or Verra (formerly, the Verified Carbon Standard); as well as credits issued for projects listed on the California Carbon Sequestration and Climate Resiliency Project Registry, which is maintained by the California Natural Resources Agency and may provide additional offsets. This shall include, but is not limited to, an instrument, credit or other certification issued by these registries for GHG reduction activities. The Project shall neither purchase offsets 594
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from the Clean Development Mechanism registry nor purchase offsets generated under Clean Development Mechanism protocols.

2. Oversight of the implementation of protocols and methodologies that define the eligibility of carbon offset projects and set forth standards for the estimation, monitoring and verification of GHG reductions achieved from such projects. The protocols and methodologies shall:
a. Be developed by the registries through a transparent public and expert stakeholder review process that affords an opportunity for comment and is informed by science; b. Incorporate standardized offset crediting parameters that define whether and how much emissions reduction credit a carbon offset project should receive, having identified conservative project baselines and the length of the crediting period and considered potential leakage and quantification uncertainties;
c. Establish data collection and monitoring procedures, mechanisms to ensure permanency in reductions, and additionality and geographic boundary provisions; and, d. Adhere to the principles set forth in the program manuals of each of the aforementioned registries, as such manuals are updated from time to time. The current registry documentation, includes the Climate Action Reserve’s Reserve Offset Program Manual8 (April 2024) and Climate Forward Program Manual9 (December 2021); the American Carbon Registry’s The ACR Standard, Requirements and Specifications for the Quantification, Monitoring, Reporting, Verification, and Registration of Project-Based GHG Emissions Reductions and Removals10 (July 2023); and, Verra’s VCS Standard, Program Guide11 (August 2023), and Methodology Requirements12 (October 2023).

The carbon offsets purchased to satisfy this measure must represent the reduction or sequestration of one MT CO2e that is “not otherwise required” (CEQA Guidelines Section 15126.4([c)(][3)]). The carbon offsets must achieve the standard of additional, real, permanent, quantifiable, verifiable, and enforceable reductions, which are defined for purposes of this 8 https://climateactionreserve.org/wp-content/uploads/2024/04/Reserve-Program-Manual-v9.2.pdf. 9 https://climateforward.org/wp-content/uploads/2021/12/Climate-Forward-Program-Manual-December-2021_12-FINAL.pdf. 10 https://acrcarbon.org/wp-content/uploads/2023/10/ACR-Standard-v8.0.pdf. 11 https://verra.org/documents/vcs-program-guide-v4-4/. 12 https://verra.org/documents/vcs-methodology-requirements-v4-4/. 595
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mitigation measure as follows consistent with the applicable provisions in the California Code of Regulations, Title 17:

1. “Additional” means that the carbon offset is not otherwise required by law or regulation, and not any other GHG emissions reduction that otherwise would occur.

3. “Verifiable” means that the GHG reduction underlying the carbon offset is well documented, transparent, and set forth in a document prepared by an independent verification body that is accredited through the American National Standards Institute (ANSI).

6. “Enforceable” means that the implementation of the GHG reduction activity must represent the legally binding commitment of the offset project developer to undertake and carry it out.

The City has reviewed and determined that methodologies and protocols established by American Climate Registry, Climate Action Reserve, and Verra establish and require carbon offset projects to comply with standards designed to achieve additional, real, permanent, quantifiable, verifiable, and enforceable reductions. Additionally, the “Reporting and Enforcement Standards” below shall ensure that the requirements of this mitigation measure will be enforced, as the City has authority to hold the applicantApplicant accountable and to take appropriate corrective action if it determines that any carbon offsets do not comply with the requirements herein.

Carbon offsets secured from the CARB-accredited registries shall be prioritized in accordance with the following criteria: (1) offsets within the City; (2) offsets within the County, only if in-City offsets are unavailable; (3) offsets within the State of California, only if in-county offsets are unavailable; (3) offsets within the United States, only if in-state offsets are unavailable.13 The above definitions are provided as criteria and performance standards associated with the use of carbon offsets. Such criteria and performance standards are intended only to further construe the standards under CEQA for mitigation related to GHG emissions (see, e.g., State CEQA Guidelines 13 For purposes of this provision, offset credits will be deemed “unavailable” if they are either unobtainable generally from the CARBaccredited registries, or if on a per-unit basis if such a credit is otherwise available: (a) for offset credits within the City of Garden Grove, more than 2 times as costly as offset credits within the County of Orange, but not within the City of Garden Grove; (b) for offset credits within the County of Orange, more than 5 times as costly as offset credits within California, but not within the County of Orange; or (c) for offset credits within the United States, sufficient offset credits within California are not available for purchase at any cost.
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3 – CHANGES TO THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-35
Section 15126.4([a)], ([c)]), and are not intended to apply or incorporate the requirements of any other statutory or regulatory scheme not applicable to the Project (e.g., the Cap-and-Trade Program).

3.2.5 Changes to Section 4.2, Transportation
Section 4.2.5, Mitigation Measures, pages 4.2.17 and 4.2.18 To reduce the Project- Ggenerated VMT per Eemployee under baseline conditions, applicable VMT reduction measures from the Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity, California Air Pollution Control Officers Association (CAPCOA), October 2024 were reviewed. The VMT reduction was calculated using the percentages recommended in the CAPCOA Handbook for the transportation-sector-related measures for the Project. The following mitigation measures have been incorporated to reduce the Project- Ggenerated VMT per employee:

MM-TRA-1 Implement Commute Trip Reduction Marketing (T-7): The Project applicant Applicant shall implement a marketing strategy to promote the Project site employer’s Commute Trip Reduction (CTR) program. Information sharing and marketing promote and educate employees about their travel choices to the employment location beyond driving such as carpooling, taking transit, walking, and biking, thereby reducing VMT and GHG emissions.

However, to ensure that CTR achieves VMT reduction of at least 4%, the following measures will be incorporated:
a) The Applicant applicant shall provide on- site or online commuter information services to employees. The Applicant applicant shall also distribute a quarterly newsletter with tips, success stories, and updates to ensure education and encouragement for the CTR program.
b) The CTR shall require the Project Applicantapplicant or their designee to appoint a Commute Program Coordinator to oversee the implementation and management of the marketing strategy.
c) The Applicantapplicant shall ensure on-site or online subsidized transit pass sales are available to all employees.
d) The Applicantapplicant shall provide guaranteed ride home service by matching employees with other employees or providing access to platforms such as Rideharing.com and Lyft which that connect riders for daily commutes with nearby drivers. e) A minimum of 10 preferential parking spaces for carpools/vanpools shall be provided. (CAPCOA Measures T-7 and T-9-B)
MM-TRA-2 Provide End-of-Trip Bicycle Facilities (T-10): The Project shall install and maintain end-of-trip bicycle facilities for employee use. End-of-trip facilities include bike parking, bike lockers, showers, and personal lockers. The provision and maintenance of secure bike parking and related facilities encourages commuting by bicycle, thereby reducing VMT and GHG emissions. The Project design includes on-site bicycle racks to accommodate a minimum of 38 short-term bicycle parking spaces and provide bicycle rentals for hotel guests on the ground level and 32 secure long-term bicycle parking spaces for employees; and additionally, locker and shower facilities will be provided for employees. (CAPCOA Measure T-10)
The implementation of MM-TRA-1 results in the reduction of VMT per employee under baseline conditions from

15.3 to 14.69, and the implementation of MM-TRA-2 further reduces the VMT per employee from 14.69 to 14.55. 598
3 – CHANGES TO THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-37
This results in Project- Ggenerated VMT per employee below the threshold of 14.60. These measures would also reduce the cumulative year VMT per employee, which is below the threshold of significance without any mitigation measures. Table 4.2.-4 provides a summary for VMT reduction for the Project- Ggenerated VMT per employee under Bbaseline plus Project conditions.

Table 4.2-4. VMT Reduction for Project- Generated VMT per Employee Criteria Value
Project- Generated VMT per Employee 15.30
County’s Baseline VMT Threshold 14.65
% VMT Reduction Required 4.25%
MM-TRA-1 (a,b,d,e): Commute Trip Reduction and Marketing VMT Reduction 4.0% MM-TRA-2: End-of-Trip Bicycle Facilities VMT Reduction 0.75% % VMT Reduction1 aAchieved with MM-TRA-1 (a,b,d,e) and MM-TRA-2 4.72% Project Generated VMT per Employee with VMT Reduction 14.58 Less than Significant Impact with MM Incorporated Yes
Additional VMT Reduction aAchieved by MM-TRA-1 (c)
MM-TRA-1(c): Implement Subsidized or Discounted Transit Program 0.17% % VMT Reduction1 aAchieved with MM-TRA-1 (a,b,c,d,e) and MM-TRA-2 4.88% Project- Generated VMT per Employee with VMT Reduction 14.55 Source: VMT Reduction from Mitigation Measures, Appendix D.

Notes: VMT = vehicle miles traveled.
1 VMT Reduction % = 1 – [(1 – 4%) ∗ (1 – 0.75%)] = 4.72% 2 VMT Reduction % = 1 – [(1 – 4%) ∗ (1 – 0.75%) ∗ (1 – 0.17%)] = 4.88% Table 4.2-4 demonstrates the amount of reduction required for the Project to result in a less than significant impact with mitigation under the Bbaseline Project- Ggenerated VMT per employee. The reduction in VMT achieved by the mitigation measures would exceed the 4.25% reduction required and achieve a reduction of at least 4.72% as identified in Table 4.2-4. With the implementation of MM-TRA-1(c), the VMT reduction achieved by the Pproject would be 4.88%.

Section 4.2.6, Level of Significance After Mitigation, page 4.2.18 With the implementation of MM-TRA-1 and MM-TRA-2, the Project- Ggenerated VMT per employee under Bbaseline conditions would result in a less than significant impact. As disclosed in Section 4.2.4 above, no mitigation is required for the pProject to have less than significant impacts with respect to the Project- Ggenerated VMT per service population under baseline and cumulative conditions, Project- Ggeneratedion VMT per employee under cumulative conditions, and Project effect on VMT under baseline and cumulative conditions. 599
3 – CHANGES TO THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-38

INTENTIONALLY LEFT BLANK
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FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-1
4 Supplemental Mitigation Monitoring
and Reporting Program

4.1 Introduction
California Public Resources Code (PRC) Section 21081.6 requires that, upon certification of an environmental impact report (EIR), “the public agency shall adopt a reporting or monitoring program for the changes made to the project or conditions of project approval, adopted in order to mitigate or avoid significant effects on the environment. The reporting or monitoring program shall be designed to ensure compliance during project implementation” (PRC Sections 21000–21177).

This Supplemental Mitigation Monitoring and Reporting Program (MMRP) was developed in compliance with PRC Section 21081.6 and Section 15097 of the California Environmental Quality Act (CEQA) Guidelines (14 CCR 15000– 15387), and includes the following information:
▪ A list of mitigation measures
▪ The timing for implementation of the mitigation measures ▪ The party responsible for implementing or monitoring the mitigation measures ▪ The date of completion of monitoring
The City of Garden Grove must adopt this Supplemental MMRP, or an equally effective program, if it approves the proposed Site B-2 Hotel Project (Project) with the mitigation measures that were adopted or made conditions of Project approval.

4.2 Supplemental MMRP Table
Table 4-1 presents the Supplemental MMRP, including the mitigation measures, timing for their implementation, the party or parties responsible for implementing or monitoring the mitigation measures, and date of completion.

Each mitigation measure includes the corresponding California Air Pollution Control Officers’ Association (CAPCOA) measure in italics immediately following the mitigation text to indicate alignment with recognized VMT and GHG best practices. Project design features (PDFs) that are incorporated into the Project relative to the analysis in the Draft Supplemental EIR are also provided in the table.
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4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-2
Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measures/Project Design Features Implementation Timing Agency
Responsible for
Monitoring Initials
Date of
Completion
Greenhouse Gas Emissions
Mitigation Measures
MM-GHG-1: Construction Equipment Electrification. Prior to issuance of building permits, the Project Applicant’s or designee’s contractor shall submit a Construction Equipment Emissions Minimization Plan for City of Garden Grove (City) approval that:
(1) Identifies all off-road equipment anticipated by phase. (2) Requires generators, cranes, electric scissor/boom lifts, forklifts/telehandlers (where feasible), welders (where feasible), and electric/solar light towers when commercially available. (3) Requires grid power for temporary construction.
(4) Where electric equipment is not available for a listed task, documents non-availability (size/class, delivery lead time, site constraints) and requires the cleanest feasible alternative (Tier 4 Final/zero-emission alternatives as available).

In addition, the Project shall limit air compressors used during the architectural coating/painting phase to equipment that is electricpowered Compliance shall be demonstrated through equipment lists, rental records, and weekly logs and shall be summarized in a postconstruction compliance memo for the Supplemental Mitigation Monitoring and Reporting Program (Supplemental MMRP) file. (CAPCOA Measure C-1-A)
Prior to the issuance of
building permits
City of Garden
Grove
MM-GHG-2: Construction Office Energy Efficiency. Prior to issuance of building permits, the Applicant or designee shall submit documentation to the City of Garden Grove that temporary construction field office(s) are equipped with energy efficient lighting such as compact fluorescent or LEDs and that heating and cooling units are Energy Star certified.

Prior to the issuance of
building permits
City of Garden
Grove
MM-GHG-3: Construction Debris Recycling. Prior to the start of construction, the Project’s contractor shall develop a Construction Waste Management Plan (Plan) for submittal and approval to the City Prior to the start of
construction
City of Garden
Grove
602
4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-3
Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measures/Project Design Features Implementation Timing Agency
Responsible for
Monitoring Initials
Date of
Completion
of Garden Grove. The Plan shall recycle or salvage non-hazardous construction debris including but not limited to wood, metal, concrete, asphalt, and other reusable materials generated during construction activities. The contractor shall implement the Plan to achieve a minimum diversion target of 75% of non-hazardous construction and demolition debris from landfills, exceeding the City’s current 65% diversion requirement. (CAPCOA Measure S-4)
MM-GHG-4: Electric Vehicle Charging Infrastructure. Prior to issuance of building permits, the Project Applicant or designee shall submit a site plan to the City of Garden Grove for approval noting the location of electric vehicle infrastructure and charging stations. Prior to issuance of the final certificate of occupancy, the Project Applicant or designee shall provide electric vehicle (EV) charging infrastructure within the Project site as required by the applicable California Green Building Standards Code, but that, at a minimum, meets or exceeds 2022 California Green Building Standards Code Tier 2 standards. Tier 2 requires approximately 225 parking spaces to be EV capable, and 75 spaces to be equipped with EV Supply Equipment (EVSE). The Project shall install a minimum of 225 EV capable spaces and 100 EVSE spaces. (CAPCOA Measure T-14)
Prior to the issuance of
building permits
City of Garden
Grove
MM-GHG-5: Guest Vehicle Trip Reductions. Prior to issuance of building permits, the Project Applicant shall submit a site plan to the City of Garden Grove for approval identifying where pedestrian and bicycle connections to adjacent facilities will be provided and where bicycle parking spaces will be provided. The City shall verify the inclusion of pedestrian and bicycle infrastructure prior to the issuance of the final certificate of occupancy. The Project Applicant or designee shall ensure that, at a minimum, the following trip reduction measures are implemented during Project operations to reduce the number of auto-based trips generated by the Project and to encourage the use of transit, bicycling, and walking.

Prior to the issuance of a
building permits
City of Garden
Grove
603
4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-4
Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measures/Project Design Features Implementation Timing Agency
Responsible for
Monitoring Initials
Date of
Completion
▪ Improve the walkability and design of the Project by providing pedestrian and bicycling connections within the Project site and to adjacent off-site facilities (i.e., sidewalks, crosswalks, wayfinding signage, etc.).
▪ Provide secure on-site bicycle racks to accommodate a minimum of 38 bicycle parking spaces and provide bicycle rentals for hotel guests.
▪ Alternative transportation services such bike rentals and transit information shall be seamlessly integrated into the guest experience, making alternative modes of travel easy to
understand, access, and use.
▪ Hotel management/concierge should provide information that promotes walking, bicycling and public transit options to nearby attractions. This should include real-time transit information provided through dedicated monitors, interactive electronic displays, websites, or mobile applications identifying local bus routes and schedules, as well as wayfinding to the existing transit stops within the Project vicinity.
▪ Provide a dedicated shuttle service linking the hotel to nearby shopping and entertainment destinations, prioritizing
battery‑electric vehicles where route length and charging logistics allow; the program may be operated under a vendor contract with scheduled runs during peak guest activity and on‑demand service for special events.
▪ Hotel management will make available transit passes for purchase and provide clear wayfinding to public transit and shuttle services.
▪ Qualitative assessments (e.g., user satisfaction surveys, walk audits, guest feedback) shall be regularly conducted to evaluate the effectiveness of trip reduction strategies.
▪ An annual report summarizing how transportation options are being used, guest perceptions, and planned improvements shall be submitted to the City.
604
4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-5
Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measures/Project Design Features Implementation Timing Agency
Responsible for
Monitoring Initials
Date of
Completion
(CAPCOA Measures T-34, T-38, T-43, and T-44)
MM-GHG-6: Limit Large Diesel Trucks During Operation. Prior to issuance of certificate of occupancy, the Project Applicant or designee shall submit a Truck Delivery Management Plan to the City of Garden Grove that documents how truck deliveries will be restricted and monitored. The Project Applicant or designee shall implement a monitoring program to restrict the number of large diesel trucks coming to the site (i.e. for deliveries, trash collection, or other services) to an average of 10 trucks per day or less. This restriction is specifically applicable to trucks classified as medium-heavy duty and heavy-heavy duty with gross vehicle weight (GVW) greater than 19,500 pounds. Annual reports summarizing heavy-duty truck trips shall be provided to the City of Garden Grove. (CAPCOA Measure C-2) Prior to the issuance of a
certificate of occupancy
City of Garden
Grove
MM-GHG-7: Building Energy Efficiency Measures. Prior to issuance of building permits, the Project Applicant or designee shall submit documentation of building energy efficiency measures to the City of Garden Grove, such that a minimum of 15% above 2022 Title 24 Building Envelope Energy Efficiency Standards is achieved. Energy efficiency measures shall include, at a minimum, the following:

1. LED Lighting – High-lumen LED light fixtures shall be used exclusively for the lighting of spaces throughout the Project that require 8 to 10 watts per fixture

2. Energy efficient lighting shall be incorporated into all on-site lighting and energy efficient appliances shall be incorporated into Project operations.

Prior to the issuance of
building permits
City of Garden
Grove
605
4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-6
Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measures/Project Design Features Implementation Timing Agency
Responsible for
Monitoring Initials
Date of
Completion
b. Smart thermostats, which include a motion sensor detector and door/window open sensors, will be installed in each guest room.
c. The central plant will utilize a Combination Plant with SmartPlate EV

4. Glazing – All glazing for the tower and exterior public spaces shall be installed with Low-E glass [U-factor (thermal transmittance) ≤

0.28 and Solar Heat Gain Coefficient (SHGC) ≤ 0.23.

5. Energy Management System – The Project shall use advanced systems to monitor and optimize energy use in real time.

6. Benchmarking and Monitoring – The Project shall incorporate an Energy Star Portfolio Management system to track and manage energy consumption

7. Third-Party Verification/LEED Certification – The Project shall obtain third-party HVAC commissioning verification or LEED certification of Gold to Platinum to verify energy savings.

All roofing materials shall meet or exceed the California Title 24, Part 6 requirements for cool roofs, based on roof slope:

Prior to the issuance of
building permits
City of Garden
Grove
606
4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-7
Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measures/Project Design Features Implementation Timing Agency
Responsible for
Monitoring Initials
Date of
Completion
▪ Low-sloped roofs (≤ 2:12 pitch):
- Aged Solar Reflectance (SR) ≥ 0.63
- Thermal Emittance (TE) ≥ 0.75
- Or Solar Reflectance Index (SRI) ≥ 75
▪ Steep-sloped roofs (> 2:12 pitch):
- Aged SR ≥ 0.20
- TE ≥ 0.75
- Or SRI ≥ 16
▪ Cool Deck Surfaces:

All exterior hardscape surfaces exposed to sunlight (e.g., pool decks, patios, walkways) shall use high-albedo materials or cool surface coatings with:
- Minimum SR of 0.29 or higher
- Or materials with a demonstrated surface temperature
reduction of at least 10°F compared to conventional concrete or asphalt
To meet the above standards, the Project Applicant may implement one or more of the following:
▪ Use Energy Star®-rated roofing products or materials listed in the Cool Roof Rating Council (CRRC) directory.
▪ Apply reflective coatings or single-ply membranes with compliant SR and TE values.
▪ Install light-colored or permeable pavers, cool concrete, or coated surfaces for decks and walkways, such as permeable interlocking concrete pavers, porous asphalt, permeable concrete, geocell systems, or bio-asphalt.
▪ Incorporate green roofs or vegetated shading structures as alternative compliance pathways (subject to City approval).

Monitoring and Reporting shall include:
607
4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-8
Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measures/Project Design Features Implementation Timing Agency
Responsible for
Monitoring Initials
Date of
Completion
▪ Submittal of roofing and hardscaping material specifications to the City of Garden Grove Building Division prior to issuance of building permits.
▪ City inspectors shall verify installation during final inspection and prior to issuance of the final certificate of occupancy. (CAPCOA Measure E-21)
MM-GHG-9: Renewable Energy. The Project Applicant or designee shall install a solar photovoltaic system capable of generating a minimum of 267,000 kilowatt hours (kWh) per year prior to issuance of certificate of occupancy. (CAPCOA Measure E-10-B)
Prior to the issuance of a
certificate of occupancy
City of Garden
Grove
MM-GHG-10: Water Conservation. Prior to receiving the final certificate of occupancy, the Project Applicant or designee shall submit a Water Conservation Compliance Report to the City of Garden Grove for review and approval. The Project shall achieve a minimum 10% reduction in total water use compared to the baseline of 167 gallons per room per day as identified in the Water Supply Assessment (Psomas 2022). This equates to a target of no more than 150.3 GPCD at full occupancy. The Water Conservation Compliance Report shall include product specifications for all water-saving fixtures and systems, landscape and irrigation plans, greywater system design and capacity documentation, post-occupancy water use monitoring plan for the first 12 months after occupancy. To meet or exceed the performance standard, the Project may implement a combination of the following water conservation strategies:
▪ Low-Flow Water Fixtures for guest rooms and public area ▪ Smart Irrigation System – outdoor landscaping shall include weather-based irrigation controllers and drought-resistant landscaping to minimize outdoor water use
▪ Greywater Recycling
(CAPCOA Measures W-2, W-5, and W-7)
Prior to receiving the final
certificate of occupancy
City of Garden
Grove
608
4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-9
Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measures/Project Design Features Implementation Timing Agency
Responsible for
Monitoring Initials
Date of
Completion
MM-GHG-11: Waste Reduction. Prior to issuance of the final certificate of occupancy, the Project Applicant or designee shall submit a Waste Management, Recycling, and Composting Plan to the City of Garden Grove for review and approval. The program shall be implemented on-site at the Project location and apply to all operational areas, including guest services, food and beverage operations, maintenance, and administrative functions. The waste reduction program shall be fully implemented during Project operations. The Plan shall specify a minimum diversion of 25% of municipal solid waste, including organics, generated on site from landfill disposal. The Waste Management, Recycling, and Composting Plan may include but not be limited to the following:
▪ Recycling Program
- Provide labeled bins for recyclables and certified hauler contracts.
- Promote recycled paper and other products like soap.
▪ Organics and Composting Program
- Collect food scraps and compostables.
▪ Source Reduction Measures
- Reduce single-use items and paper use.
- Ban disposable (i.e., designed to be used once and discarded) foodware items and accessories.
- Allow customers to bring their own reusable items.
- Require hand soap in refillable containers.
- Do not provide water in plastic bottles or disposable single-use cups.
- Do not use expanded polystyrene (i.e., Styrofoam).
- Require reusable napkins and tablecloths with recyclable disposable napkins only for takeout.
- Provide hand dryers in areas accessible to customers. - Require reusable laundry bags.
- Require reusable dishware for room service.

Prior to issuance of the
final certificate of
occupancy
City of Garden
Grove
609
4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-10
Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measures/Project Design Features Implementation Timing Agency
Responsible for
Monitoring Initials
Date of
Completion
- Offer toiletries on request rather than automatically. - Provide key cards made of non-plastic materials, including traditional metal keys or wood, bamboo, and paper options for chip-based cards.
- Incentivize returning keys to discourage waste.
- Provide non-plastic shower caps, razors, shaving cream, slippers, eye masks, and ear plugs.
- Remove minifridge items that use plastic.
- Eliminate the use of garbage bags if possible, or use garbage bags made of compostable material.
- Serve employee meals with reusable dishware and cutlery and provide reusable water bottles for all employees with
accessible water bottle refill stations.
- Replace paper towels with reusable dish rags.
▪ Employee and Guest Education
- Provide staff training and signage for guests.
▪ Monitoring and Reporting
- Track waste and submit Annual Waste Diversion Report to the City of Garden Grove.

In addition, if the hotel/operations qualify as a covered edible food generator, the Project will contract with a food recovery organization/service and keep required records. If not covered, the Project will evaluate a partnership during operator onboarding and implement if feasible.
(CAPCOA Measure S-1/S-2) (CAPCOA Measure S-3 is a qualitative measure in CalEEMod and is not quantified in the operational analysis)
MM-GHG-12: Zero Emission Landscape Equipment. During Project operations, the Project Applicant or designee shall ensure zeroemission landscape equipment (defined as equipment that does not emit tailpipe emissions during operation) is utilized. The Project Applicant or designee shall be responsible for ensuring that all During operations City of Garden
Grove
610
4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-11
Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measures/Project Design Features Implementation Timing Agency
Responsible for
Monitoring Initials
Date of
Completion
landscape maintenance contractors and staff comply with this measure. All landscape maintenance activities associated with the Project shall utilize zero-emission landscaping equipment, such as electric-powered or battery-operated tools. This requirement applies to all landscaped areas within the Project site, including but not limited to courtyards, green spaces, perimeter landscaping, and rooftop gardens. The requirement shall be implemented prior to the commencement of landscape maintenance operations. To meet or exceed the performance standard, the Project may implement a combination of the following strategies:

Electric-Powered Equipment
▪ Use electric or battery-powered:
- Leaf blowers.
- Lawn mowers.
- Hedge trimmers.
- Edgers.
- Chainsaws.

Contractor Requirements
▪ Include zero-emission equipment requirements in all landscape maintenance contracts.
▪ Require contractors to provide documentation of equipment type and compliance.

On-Site Charging Infrastructure
▪ Install dedicated charging stations or outlets for landscape equipment.

Equipment Inventory and Tracking
▪ Maintain an inventory of all landscape equipment used on site. ▪ Submit an annual compliance report to the City of Garden Grove verifying that only zero-emission equipment is in use.

Training and Education
▪ Provide training to landscape maintenance staff on the proper use and maintenance of electric equipment.
611
4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-12
Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measures/Project Design Features Implementation Timing Agency
Responsible for
Monitoring Initials
Date of
Completion
▪ Display signage or include information in sustainability reports to promote awareness.
(CAPCOA Measure LL-1)
MM-GHG-13: Prohibit Woodburning Devices, Natural Gas Fireplaces, and Fire Pits. Prior to the issuance of building permits, the Project Applicant or designee shall submit building design plans for approval of the City showing the prohibition of on-site woodburning devices, natural gas fireplaces, fire pits, or other decorative combustion features throughout the Project site. Prior to the issuance of the final certificate of occupancy, the City shall confirm that this prohibition has been implemented.

Prior to the issuance of
building permits
City of Garden
Grove
MM-GHG-14: Refrigerant Management Program. Prior to issuance of mechanical permits, the Project Applicant or designee shall develop and submit a Refrigerant Management Program to the City of Garden for review and approval. The Project Applicant or designee shall be responsible for developing, implementing, and maintaining the refrigerant management program in coordination with HVAC contractors and facility operations staff. The Refrigerant Management Program shall include the use of low-GWP refrigerants (e.g., R-32 or better) and incorporate best management practices to reduce emissions from service, operation, and disposal of refrigerants. This measure shall apply to all refrigeration and HVAC systems installed and operated within the Project site, including guest rooms, common areas, kitchens, and mechanical rooms. The Project shall ensure that:
▪ 100% of installed HVAC and refrigeration systems use refrigerants with a GWP ≤ 750, consistent with California Air Resources Board (CARB) regulations.
▪ The refrigerant management program shall achieve a minimum 10% reduction in potential refrigerant emissions compared to standard industry practices, as demonstrated through leak rate tracking and maintenance logs.

Prior to the issuance of
mechanical permits
City of Garden
Grove
612
4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-13
Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measures/Project Design Features Implementation Timing Agency
Responsible for
Monitoring Initials
Date of
Completion
To meet or exceed the performance standard, the Project may implement a combination of the following strategies:

Mechanical Equipment
▪ Install microchannel heat exchangers in A/C equipment in place of conventional heat exchangers.

Use of Low-GWP Refrigerants
▪ Select refrigerants such as R-32, R-454B, or other CARBcompliant alternatives with GWP ≤ 750. ▪ Avoid high-GWP refrigerants such as R-410A and R-404A.

Leak Detection and Prevention
▪ Install automatic leak detection systems for large-capacity systems.
▪ Conduct quarterly inspections and maintain leak logs.

Refrigerant Recovery and Disposal
▪ Use certified technicians for refrigerant recovery and disposal. ▪ Maintain documentation of recovered and recycled refrigerants.

Preventive Maintenance Program
▪ Implement a scheduled maintenance plan to inspect and service HVAC and refrigeration systems.
▪ Include refrigerant charge optimization and system performance checks.

Training and Certification
▪ Ensure all HVAC technicians are EPA Section 608 certified. ▪ Provide training on low-GWP refrigerant handling and leak prevention.

Third-Party Verification
▪ Obtain third-party verification of refrigerant management practices through programs such as GreenChill or LEED Enhanced Refrigerant Management credit.

Prior to issuance of certificate of occupancy, the City of Garden Grove will verify that the equipment specified in the Refrigerant 613
4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-14
Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measures/Project Design Features Implementation Timing Agency
Responsible for
Monitoring Initials
Date of
Completion
Management Program has been installed. Ongoing compliance shall be performed by the Project Applicant or their designee. (CAPCOA Measures R-1, R-4, R-5, R-6, and R-7)
MM-GHG-15: Carbon Offsets – The Project Applicant (or its designee) shall implement the following carbon offsets in accordance with the Project’s construction and operational phases as outlined below.

Operation
Prior to issuance of the final certificate of occupancy, the Project Applicant or its designee shall purchase and retire carbon offsets in a quantity sufficient to offset, for a 30-year period following occupancy of the Project, the construction and operational GHG emissions from the Project to the 1,400 MT CO2e per year threshold, consistent with the quantification, performance standards and requirements set forth below. Alternatively, the Project Applicant or its designee may purchase and retire annual operational GHG offsets for a period of 30 years by December 31 of the year preceding each new year after the issuance of the final certificate of occupancy. Annual operational GHG 614
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Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measures/Project Design Features Implementation Timing Agency
Responsible for
Monitoring Initials
Date of
Completion
emission offsets shall also be subject to the same quantification, performance standards, and requirements set forth below.

Quantification of GHG Emissions and Reductions Required Construction
The estimated total construction GHG emissions to be offset are 3,362.30 MT CO2e if purchased in a lump sum. If purchased on an annual basis, the following schedule provides the estimated annual emissions and date of compliance.

Year
Offsets Required
(MT CO2e)
Purchase and
Retirement Deadline
1 402.52 Prior to issuance of
grading permits
2 1,434.02 December 31 of Year 1
3 1,410.81 December 31 of Year 2
4 114.95 December 31 of Year 3
Total 3,362.30
Notes: MT CO2e = metric tons of carbon dioxide equivalent; N/A = not applicable.

Operation
The estimated operational emissions are 7,408.02 MT CO2e. To mitigate operational emissions below the 1,400 MT CO2e per year threshold, the Project would purchase and retire one lump sum of 180,270.60 MT CO2e of offsets (7,408.02 MT CO2e − 6,009.02 [offsets] = 1,399 MT CO2e remaining); 6,009.02 MT CO2e × 30-year life = 180,270.60 MT CO2e; or that same total amount of credits in increments over the 30 years. The following schedule provides the estimated offset emissions and dates of compliance under the scenarios where credits are purchased and retired in a lump sum or on an annual basis.
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Scenario
Offsets
Required (MT CO2e
)
Purchase and Retirement
Deadline
Lump sum 180,270.60 Prior to issuance of certificate of occupancy
Annual basis
30-year term
6,009.02 Prior to issuance of certificate of
occupancy for Year 1 and
December 31 of preceding year
Notes: MT CO
2e = metric tons of carbon dioxide equivalent; N/A = not applicable.

Carbon Offset Standards – Eligible Registries, Acceptable Protocols, Defined Terms, and Geographic Priorities
“Carbon offset” shall mean an instrument, credit or other certification verifying the reduction of GHG emissions issued by the following CARB-accredited registries: Climate Action Reserve, the American Carbon Registry, or Verra (formerly, the Verified Carbon Standard); as well as credits issued for projects listed on the California Carbon Sequestration and Climate Resiliency Project Registry, which is maintained by the California Natural Resources Agency and may provide additional offsets. This shall include, but is not limited to, an instrument, credit or other certification issued by these registries for GHG reduction activities. The Project shall neither purchase offsets from the Clean Development Mechanism registry nor purchase offsets generated under Clean Development Mechanism protocols.

1. Adherence to established GHG accounting principles set forth in the International Organization for Standardization (ISO) 14064, 616
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Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measures/Project Design Features Implementation Timing Agency
Responsible for
Monitoring Initials
Date of
Completion
Part 2 or the World Resources Institute/World Business Council for Sustainable Development (WRI/WBCSD) Greenhouse Gas Protocol for Project Accounting; and

2. Oversight of the implementation of protocols and methodologies that define the eligibility of carbon offset projects and set forth standards for the estimation, monitoring and verification of GHG reductions achieved from such projects. The protocols and methodologies shall:
a. Be developed by the registries through a transparent public and expert stakeholder review process that affords an
opportunity for comment and is informed by science;
b. Incorporate standardized offset crediting parameters that define whether and how much emissions reduction credit a carbon offset project should receive, having identified conservative project baselines and the length of the crediting period and considered potential leakage and quantification uncertainties;
c. Establish data collection and monitoring procedures, mechanisms to ensure permanency in reductions, and
additionality and geographic boundary provisions; and
d. Adhere to the principles set forth in the program manuals of each of the aforementioned registries, as such manuals are updated from time to time. The current registry documentation includes the Climate Action Reserve’s Reserve Offset Program Manual1 (April 2024) and Climate Forward Program Manual2 (December 2021); the American Carbon Registry’s The ACR Standard, Requirements and Specifications for the
Quantification, Monitoring, Reporting, Verification, and Registration of Project-Based GHG Emissions Reductions and 1 https://climateactionreserve.org/wp-content/uploads/2024/04/Reserve-Program-Manual-v9.2.pdf. 2 https://climateforward.org/wp-content/uploads/2021/12/Climate-Forward-Program-Manual-December-2021_12-FINAL.pdf. 617
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Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measures/Project Design Features Implementation Timing Agency
Responsible for
Monitoring Initials
Date of
Completion
Removals3 (July 2023); and Verra’s VCS Standard, Program Guide4 (August 2023), and Methodology Requirements5
(October 2023).

The City has reviewed the registries’ methodologies and has determined that protocols established pursuant to such
methodologies – including updates to those protocols and methodologies as may occur from time to time by the registries in accordance with the registry documentation listed in the prior paragraph to ensure the continuing efficacy of the reduction activities – are eligible for use under this mitigation measure.

1. “Additional” means that the carbon offset is not otherwise required by law or regulation, and not any other GHG emissions reduction that otherwise would occur.

2. “Real” means that the GHG reduction underlying the carbon offset results from a demonstrable action or set of actions, and is quantified under the protocol or methodology using appropriate, accurate, and conservative methodologies that account for all GHG emissions sources and sinks within the boundary of the applicable carbon offset project, uncertainty, and the potential for activity-shifting leakage and market-shifting leakage.
3 https://acrcarbon.org/wp-content/uploads/2023/10/ACR-Standard-v8.0.pdf. 4 https://verra.org/documents/vcs-program-guide-v4-4/.
5 https://verra.org/documents/vcs-methodology-requirements-v4-4/. 618
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Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measures/Project Design Features Implementation Timing Agency
Responsible for
Monitoring Initials
Date of
Completion

6. “Enforceable” means that the implementation of the GHG reduction activity must represent the legally binding commitment of the offset project developer to undertake and carry it out.

Additionally, the “Reporting and Enforcement Standards” below shall ensure that the requirements of this mitigation measure will be enforced, as the City has authority to hold the Applicant accountable and to take appropriate corrective action if it determines that any carbon offsets do not comply with the requirements herein.

Carbon offsets secured from the CARB-accredited registries shall be prioritized in accordance with the following criteria: (1) offsets within the City; (2) offsets within the County, only if in-City offsets are unavailable; (3) offsets within the State of California, only if in-county 619
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Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measures/Project Design Features Implementation Timing Agency
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Monitoring Initials
Date of
Completion
offsets are unavailable; (3) offsets within the United States, only if instate offsets are unavailable.6 The above definitions are provided as criteria and performance standards associated with the use of carbon offsets. Such criteria and performance standards are intended only to further construe the standards under CEQA for mitigation related to GHG emissions (see, e.g., State CEQA Guidelines Section 15126.4[a], [c]), and are not intended to apply or incorporate the requirements of any other statutory or regulatory scheme not applicable to the Project (e.g., the Cap-and-Trade Program).

Monitoring, Reporting, and Enforcement Standards
Prior to the timeline identified in the initial section of this mitigation measure, the Project Applicant or its designee shall submit documentation in the form of a report to the City that identifies the quantity of emission reductions required by this mitigation measure, as well as the carbon offset proposed for acquisition to achieve compliance with this measure. For purposes of demonstrating that each offset is additional, real, permanent, quantifiable, verifiable and enforceable, the reports shall include: (i) the applicable protocol(s) and methodologies associated with the carbon offsets, (ii) the thirdparty verification report(s) and statement(s) affiliated with the carbon offset projects, (iii) the unique serial numbers assigned by the registry(ies) to the carbon offset, which serves as evidence that the registry has determined the carbon offset project to have been implemented in accordance with the applicable protocol or methodology and ensures that the offsets cannot be further used in any manner, and (iv) the carbon offset meets the locational attributes 6 For purposes of this provision, offset credits will be deemed “unavailable” if they are either unobtainable generally from the CARB accredited registries, or if on a per-unit basis if such a credit is otherwise available: (a) for offset credits within the City of Garden Grove, more than 2 times as costly as offset credits within the County of Orange, but not within the City of Garden Grove; (b) for offset credits within the County of Orange, more than 5 times as costly as offset credits within California, but not within the County of Orange; or (c) for offset credits within the United States, sufficient offset credits within California are not available for purchase at any cost. 620
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Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measures/Project Design Features Implementation Timing Agency
Responsible for
Monitoring Initials
Date of
Completion
as specified by this mitigation measure and verified through a market survey report prepared by a carbon offset broker that identifies the carbon registry listings reviewed for carbon offset availability, including the related date of inquiry.

If the City determines that the Project’s carbon offsets at issue in the Project Applicant’s (or their designee’s) submission meet the requirements of this mitigation measure, the offsets required to be acquired by the Project will be proportionally reduced. Upon an affirmative finding from the City that the Project’s carbon offsets are eligible for use under this measure, and within the applicable timeframe required by the first section of this mitigation measure, the Project Applicant (or their designee) shall provide to the City copies of the relevant portions of the GHG offset contracts demonstrating the applicable carbon offsets have been acquired. This will serve as the final documentation required to demonstrate compliance with this mitigation measure.
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Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measures/Project Design Features Implementation Timing Agency
Responsible for
Monitoring Initials
Date of
Completion
If the City determines that the Project’s carbon offsets do not meet the requirements of this mitigation measure, the City shall provide a detailed explanation of the basis for the City’s determination. Carbon offsets not approved by the City as meeting the requirements of this mitigation measure cannot be used to reduce Project GHG emissions and the Applicant will be required to submit qualifying carbon offsets accepted by the City prior to the applicable timeframe specified in the first section of this mitigation measure.
(CAPCOA Measure M-2)
Project Design Features
PDF-4: Construction equipment should be maintained in proper tune. During construction City of Garden Grove
PDF-5: All construction vehicles should be prohibited from excessive idling. Excessive idling is defined as 5 minutes or longer.

During construction City of Garden
Grove
PDF-8: For construction activities other than those addressed by MMGHG-1 and MM-GHG-2, establish an electricity supply to the construction site and use electric powered equipment instead of diesel-powered equipment or generators, where feasible.

During construction City of Garden
Grove
PDF-10: Use haul trucks with on-road engines instead of off-road engines for on-site hauling.

During construction City of Garden
Grove
PDF-11: The Project will comply with the mandatory requirements of the latest California Building Standards Code, Title 24, Part 6 (Energy Code) and Part 11 (California Green Building Standards Code [CALGreen]), including the provisions for bicycle parking, electric vehicle charging stations, energy efficiency, material conservation, and water/waste reduction.

During operations. City of Garden
Grove
PDF-12: Install signage at loading docks requiring trucks to limit engine idling times to 5 minutes or less.

During operations City of Garden
Grove
PDF-21: Engine idling time for all delivery vehicles and trucks must be limited to 5 minutes or less. Signage should be posted in the designated loading areas reflecting the idling restrictions.

During operations City of Garden
Grove
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Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measures/Project Design Features Implementation Timing Agency
Responsible for
Monitoring Initials
Date of
Completion
PDF-27: Sustainable Building Materials and Contracting. The Project will prioritize low-impact, sustainably sourced, and recyclable materials across construction and interior finishes, including low-VOC paints, Forest Stewardship Council-certified wood, and recycledcontent flooring. The Project is also implementing vendor standards that require environmental product declarations and third-party certifications to verify material sustainability. Materials shall be selected not only for their initial environmental footprint but also for durability and long-term performance, reducing the need for frequent replacement and associated waste.

During construction City of Garden
Grove
PDF-28: The Project amenities shall be available to registered hotel guests only. There will be no day passes allowed.

Prior to project opening City of Garden
Grove
PDF-29: The Project amenities include a self-service bicycle repair station adjacent to the guest and employee bicycle parking spaces.

During project construction
for installation and during
project operation for
maintenance and provision
of bicycle repair.

City of Garden
Grove
Transportation
Mitigation Measures
MM-TRA-1: Implement Commute Trip Reduction Marketing: The Project Applicant shall implement a marketing strategy to promote the Project site employer’s Commute Trip Reduction (CTR) program.

Information sharing and marketing promote and educate employees about their travel choices to the employment location beyond driving such as carpooling, taking transit, walking, and biking, thereby reducing VMT and GHG emissions.

Prior to project opening. City of Garden
Grove
623
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Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measures/Project Design Features Implementation Timing Agency
Responsible for
Monitoring Initials
Date of
Completion
However, to ensure that CTR achieves VMT reduction of at least 4%, the following measures will be incorporated:
a) The Applicant shall provide on site or online commuter information services to employees. The Applicant shall also distribute a quarterly newsletter with tips, success stories, and updates to ensure education and encouragement for the CTR program. b) The CTR shall require the Project Applicant or their designee to appoint a Commute Program Coordinator to oversee the
implementation and management of the marketing strategy. c) The Applicant shall ensure on-site or online subsidized transit pass sales are available to all employees.
d) The Applicant shall provide guaranteed ride home service by matching employees with other employees or providing access to platforms such as Rideharing.com and Lyft that connect riders for daily commutes with nearby drivers.
e) A minimum of 10 preferential parking spaces for
carpools/vanpools shall be provided.
(CAPCOA Measures T-7, T-9-B)
MM-TRA-2: Provide End-of-Trip Bicycle Facilities: The Project shall install and maintain end-of-trip bicycle facilities for employee use.

End-of-trip facilities include bike parking, bike lockers, showers, and personal lockers. The provision and maintenance of secure bike parking and related facilities encourages commuting by bicycle, thereby reducing VMT and GHG emissions. The Project design includes on-site bicycle racks to accommodate a minimum of 38 short-term bicycle parking spaces and provide bicycle rentals for hotel guests on the ground level and 32 secure long-term bicycle parking spaces for employees; additionally, locker and shower facilities will be provided for employees. (CAPCOA Measure T-10)
During project construction
for installation and during
project operation for
maintenance and provision
of bicycle rentals.

City of Garden
Grove
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Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measures/Project Design Features Implementation Timing Agency
Responsible for
Monitoring Initials
Date of
Completion
Project Design Features
None. N/A N/A N/A N/A
Notes: LEED = Leadership in Energy and Environmental Design; GPCD = gallons per capita per day; GWP = global warming potential; EPA = U.S. Environmental Protection Agency; GHG = greenhouse gas; MT CO2e = metric tons of carbon dioxide equivalent; VOC = volatile organic compound; N/A = not applicable. 625
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FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 5-1
5 General Responses to Post–Public
Review Comment Letters Received
A large number of comment letters were received after the Public Review period for the Draft Supplemental Environmental Impact Report (SEIR) for the B-2 Site Hotel Project (Project) closed on November 6, 2025.

The California Environmental Quality Act (CEQA) does not require the City of Garden Grove (City) to respond to these letters or include any suggested changes to the Draft SEIR in this Final SEIR. However, in the interest of transparency and full disclosure, general responses to the issues raised in these letters are included in this chapter for informational purposes only.

These letters followed three general formats; therefore, three representative letters were chosen to be included in this chapter for reference, as specified in Table 5-1.

Table 5-1. Representative Comment Letters Received After Close of the Public Review Period
Comment
Letter
Designation Commenter Date Received
1 Marina Joel January 8, 2026
2 Israel Espinoza January 8, 2026
3 Kassidy Nguyen January 8, 2026
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Post–Public Review Comment Letter – Marina Joel (1)
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Response to Post–Public Review Comment Letter 1
Marina Joel
January 8, 2026
The commenter would like to see housing on public land and not another hotel. The comment states that because public land is a limited resource, it matters how it is used.

Holds critical importance for the City for revitalization and economic stimulus purposes. Ideally situated south of the Disneyland Resort district, this area has opportunities to capitalize and expand tourist-based and entertainment-related uses. Full-service hotels and new restaurants have been constructed, predominately at the intersection of Chapman Avenue and Harbor Boulevard. An Economic Impact and Master Plan for the International West Resort Area was prepared to identify strategies to complement established entertainment, hospitality, and sports venues in the surrounding areas by planning for three entertainment centers connected by themed commercial services and retail uses, entertainment venues, hotels, theaters, and parks.

The International West Mixed Use designation allows for a mix of uses, including commercial, entertainment, hotel, and residential uses, and this particular 3.72-acre site is very well situated, with frontage along Harbor Boulevard, for themed entertainment uses within easy driving distance of Disneyland Resort and close to existing tourismbased uses in the City. It is a prime location for a themed hotel, which is consistent with the long-term vision of the City to develop this property with a resort/entertainment/tourism use, as envisioned in the General Plan.

The City has prepared a state-compliant housing element (the 2021–2029 Housing Element, which was adopted on October 10, 2023), which includes a detailed housing site inventory identifying thousands of parcels that could be developed for affordable housing throughout the City. The City specifically has identified more than 2,400 underutilized properties that are not meeting their full economic potential and could be developed for affordable housing. This property is not required to be used for affordable housing and it is not identified as a site for affordable housing in the Housing Element’s site inventory. As such, by building the hotel, it is not reducing or removing properties that have previously been identified for future housing growth in the Housing Element. The sites that have been identified are sufficient to meet the City’s Regional Housing Needs Assessment (RHNA). The project would not minimize the City’s ability to meet its RHNA. 631
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Post–Public Review Comment Letter – Israel Espinoza (2) 633
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Response to Post–Public Review Comment Letter 2
Israel Espinoza
January 8, 2026
The commenter would like the Project to incorporate housing, especially affordable housing. The City has prepared a state-compliant housing element (the 2021–2029 Housing Element, which was adopted on October 10, 2023), which includes a detailed housing site inventory identifying thousands of parcels that could be developed for housing throughout the City. The City has specifically identified more than 2,400 underutilized properties that are not meeting their full economic potential and could be developed for housing. This property is not identified as a site for housing in the Housing Element’s site inventory. Rather, it has long been designated for resort and entertainment uses, consistent with the City’s long-term vision for the International West Mixed Use corridor.

As a matter of public policy, the City has identified this property for entertainment/resort/tourism uses. The Project site is in an area of the City designated as International West Mixed Use (Focus Area A) along Harbor Boulevard, generally between Chapman Avenue on the north and the Garden Grove Freeway (State Route 22) on the south.

According to the Garden Grove General Plan (City of Garden Grove 2008), this area:

As the Draft SEIR analyzed and disclosed, both an exclusively residential and a mixed-use housing alternative are addressed in the “Alternatives Considered but Rejected” section (Draft SEIR, Section 6.3.4, Residential Alternative, p. 6-4, and Section 6.3.6, Mixed-Use Development Alternative, pp. 6-5 and 6-6). The SEIR demonstrates that neither of those options were feasible or capable of meeting the Project’s objectives, nor would the options clearly reduce potentially significant VMT or GHG impacts associated with the Project. The Project site is 3.72 acres in size and would be entirely consumed by a 500-room hotel, themed pool deck, parking garage, and amenities. There is no land available for housing on the Project site without fundamentally reducing the hotel’s size. A reduced hotel size alternative was considered and rejected in the Draft SEIR because it would not meet most of the Project’s basic objectives. A mixed-use alternative that reduces the size of the hotel to accommodate housing would not attain the primary objective of a fully programmed destination resort hotel. 635
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Post–Public Review Comment Letter – Kassidy Nguyen (3)
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Response to Post–Public Review Comment Letter 3
Kassidy Nguyen
January 8, 2026
The commenter believes that the Draft SEIR includes inadequate environmental mitigation for greenhouse gas (GHG) emissions and vehicle miles traveled (VMT) and states that the Draft SEIR does not analyze various components of the proposed hotel that could generate VMT and mobile emissions independently of the hotel use.

The Project was modeled as a single “hotel” land use because all components (e.g., fitness room, theater, swimming pool, restaurant) are ancillary to the hotel use and are limited to registered hotel guests, pursuant to PDFs incorporated into the Supplemental Mitigation Monitoring and Reporting Program (MMRP). Day passes are prohibited. Therefore, it would not be appropriate to estimate trips and VMT from day guests. This is consistent with the Institute of Transportation Engineers (ITE) Trip Generation Manual for Land Use 310, which describes a hotel as “a place of lodging that provides sleeping accommodations and supporting facilities such as full-service restaurant, cocktail lounge, meeting rooms, banquet rooms, and convention facilities. A hotel typically provides a swimming pool or another recreational facility, such as a fitness room” (ITE 2025). This approach aligns with California Emissions Estimator Model (CalEEMod) guidance for mixed-use projects where ancillary facilities do not function as independent destinations. The proposed Project is a unified development under a single entitlement and would operate as an integrated resort hotel. Ancillary amenities are not independent land uses—they are accessory to the primary hotel use and would be available exclusively to registered hotel guests. Accordingly, the CalEEMod modeling reflects the Project’s operational characteristics as a single hotel land use type.

The commenter states that the Draft SEIR’s analysis does not include day visitors or guests. It cites Great Wolf Lodge and Disneyland Resort as comparable examples, where access to the facility is not limited to just registered guests. As explained in Chapter 2, Responses to Comments O2-6 to O2-10, access to all on-site amenities— including the theater, restaurant, and themed pool—is restricted to registered hotel guests pursuant to the PDFs incorporated into the Supplemental MMRP (see Chapter 4, Supplemental Mitigation Monitoring and Reporting Program, of this Final SEIR). Therefore, it would not be appropriate to estimate trips and VMT from day guests because the Project is unlike Disneyland Resort and Great Wolf Lodge in that respect.

The comment states the Draft SEIR’s employee estimate of 446 employees may be an overestimate and may therefore overstate the Project’s transportation efficiency and understate the actual GHG emissions and VMT impacts, thereby underestimating the level of mitigation required. The use of 446 employees results in a conservative estimate of the Project’s VMT impacts. In accordance with the City’s VMT Guidelines, the VMT analysis utilized OCTAM, which is the transportation analysis model maintained by the Orange County Transportation Authority. OCTAM was also used to evaluate the potential VMT impacts of other resort/hotel uses in Orange County, including the DisneylandForward project. As shown in the Project’s VMT analysis in the Draft SEIR and Appendix D to the Draft SEIR, Vehicle Miles Traveled (VMT) Memorandum, the VMT per employee is estimated as 15.3 VMT per employee, which is above the City’s VMT significance threshold of 14.6 VMT per employee and therefore requires mitigation. The VMT analysis recommends two mitigation measures (Mitigation Measure [MM] TRA-1 and MM-TRA-2) that are feasible and would reduce the Project’s VMT impact from its employees to less than significant levels. Additional VMT reduction measures are included as part of MM-GHG-5. As to the GHG emissions analysis, relying on expert analysis, reasonably foreseeable occupancy scenarios, and established methodologies and significance thresholds, the Draft SEIR properly evaluated the proposed Project’s potential GHG emissions. The Draft SEIR discloses that, even with implementation of all feasible on-site mitigation (MM-GHG-1 through MM-GHG-14) and carbon offsets (MM-GHG-15), emissions would remain significant and unavoidable. 639
5 – GENERAL RESPONSES TO POST–PUBLIC REVIEW COMMENT LETTERS RECEIVED FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 5-14
The comment states that the Project does not adequately consider more effective climate strategies. The Draft SEIR analyzed and disclosed the Project’s potentially significant GHG impacts with and without mitigation. That analysis included an evaluation of PDFs and feasible mitigation measures, some of which were based on measures identified in CalEEMod or on CAPCOA recommendations, although CEQA does not require inclusion of any CAPCOA measures for a GHG emissions analysis. The Project’s PDFs and mitigation measures do not mirror CAPCOA language verbatim; rather, they were intentionally tailored to reflect Project-specific design features, construction methods, and operational characteristics. This approach is consistent with CEQA best practice and CAPCOA guidance, which anticipates that lead agencies will adapt recommended measures to suit individual projects. In compliance with CEQA, the Draft SEIR’s analysis documents the basis for any reductions in GHG emissions or impacts based on application of the PDFs and mitigation measures.

The comment states that the Project should incorporate mixed uses. The Draft SEIR included a mixed-use alternative with residential and hotel uses. As the Draft SEIR analyzed and disclosed, both an exclusively residential and a mixed-use housing alternative are addressed in the “Alternatives Considered but Rejected” section (Draft SEIR, Section 6.3.4, Residential Alternative, p. 6-4, and Section 6.3.6, Mixed-Use Development Alternative, pp. 6-5 and 6-6). The Draft SEIR demonstrates that neither of those options is feasible or capable of meeting the Project’s objectives, nor would the options clearly reduce potentially significant VMT or GHG emissions impacts associated with the Project. The Project site is 3.72 acres in size and would be entirely consumed by a 500-room hotel, themed pool deck, parking garage, and amenities. There is no land available for housing on the Project site without fundamentally reducing the hotel’s size. A reduced hotel size alternative was considered and rejected in the Draft SEIR because it would not meet most of the Project’s basic objectives. A mixed-use alternative that reduces site of the hotel to accommodate housing would not attain the primary objective of a fully programmed destination resort hotel.

References
City of Garden Grove. 2008. Garden Grove General Plan. https://ggcity.org/planning/general-plan.

City of Garden Grove. 2023. “2021–2029 Housing Element.” Chapter 12 in Garden Grove General Plan.

Resolution No. 9825-23. Adopted October 10, 2023. https://ggcity.org/sites/default/files/gghea.pdf.

ITE (Institute of Transportation Engineers). 2025. ITE Trip Generation Manual, 12th Edition. August 2025. https://www.ite.org/technical-resources/topics/trip-and-parking-generation-v2/trip-generation-info/. 640
Appendix A
Employee VMT Estimation for Site B-2 Hotel
Project Memorandum
641

MEMORANDUM
To: Priit Kaskla, Monica Covarrubias (City of Garden Grove) From: Sandipan Bhattacharjee (Translutions)
Sabita Tewani, AICP, PTP (Dudek)
Subject: Employee VMT Estimation for Site B-2 Hotel Project Date: May 1, 2026
cc: Rachel Struglia, Dudek
Attachments: Excerpts from U.S. Bureau of Labor Statistics Excerpts from LADOT and DCP 2020
Excerpts from Millennium Hollywood Project, Crain and Associates 2013 Excerpts from SCAG Employment Density Study 2001
The Draft SEIR, including the technical appendices, included substantial evidence supporting the methodology used to estimate the number of employees conducted for the Site B-2 Hotel Project (Project), for purposes of performing the vehicle miles traveled (VMT) and greenhouse gas (GHG) emissions analysis. Comment Letter O2 on the Draft Supplemental Environmental Impact Report (SEIR), received from the Law Office of Jordan R. Sisson for UNITE HERE Local 11 on November 6, 2025, questioned that methodology. This memorandum provides further validation for the rationale and employee VMT estimation methodology applied in the Draft SEIR.

Dudek reviewed the City of Garden Grove (City) Economic Development Report & Analysis B-2 Site (Economic Development Report; Garden Grove 2022). As the Economic Development Report discloses, the City prepared that report for purposes of complying with state law requirements relative to agencies providing public subsidies and disposing of public properties. The Economic Development Report was not prepared for the purposes of California Environmental Quality Act analysis of VMT. Nonetheless, the Economic Development Report provides further validation that the employee estimation used in the Draft SEIR is reasonable. Based on the Job Creation Estimation (page 11 Garden Grove 2022), the Project is estimated to result in 380 full-time equivalent (FTE) hotel jobs. Based on the U.S. Bureau of Labor Statistics, approximately 34% of employees in the hospitality industry work part time.

By applying this percentage split, approximately 66% of 446, or 294 employees, would be full time, and 34%, or 152 employees, would be part time. According to the estimate of hours worked per week from U.S. Bureau of Labor Statistics Accommodation and Food Services: NAICS 72, the average weekly hours for occupations commonly found in accommodation and food services ranges from 23.7 to 25.9 hours (U.S. Bureau of Labor Statistics 2026). This analysis used an average of 25 hours per week for part-time work and 40 hours per week for full-time work; 152 part-time employees would be equivalent to 95 FTE (i.e., 152*25/40). The Project’s FTE would be 294 full-time +95 part-time = 389 employees. Therefore, the Project’s 446 employees would be equivalent to 389 FTE, similar to the 380 FTE identified in the Economic Development Report.

As explained in the Draft SEIR, the closest fit from the SANDAG transportation model (SANDAG Model) maintained by the San Diego Association of Governments (SANDAG) was found to be “High Rise Hotel.” The San Diego region has a number of hospitality uses with features and operations similar to the proposed Project, including several destination and non-destination hotels. The City’s technical experts also consulted SCAG’s Employment Density Study Summary 642

MEMORANDUM
SUBJECT: EMPLOYEE VMT ESTIMATION FOR B-2 SITE HOTEL PROJECT 16294 2
MAY 2026
Report (SCAG 2001). Per Table 6A, p. 19, the average employee per acre for Hotel/Motel is 35.06 employees per acre. Given the Project site is 3.72 acres, use of that approach would result in an estimate of 130 employees. Based on our experience, and after consultation with the Project developer and City staff, it was determined that use of that approach for estimating Project employment was not reasonable or supportable given the nature of the Project. The number of employees was also nowhere near the number calculated using SANDAG’s methodology or the range provided by City of Hotels (2025). The ITE Trip Generation Manual was also consulted (2025), but it does not include a method to estimate the number of employees for this land use. It should be noted that City of Los Angeles VMT calculator uses 0.5 employees per room for both hotel and motel use (LADOT and DCP 2020). However, the space allocated to, and employees required for, ancillary uses such as meeting rooms, retail, and restaurants are not same for hotels and motels. Therefore, using only 0.5 employees per room to estimate the number of employees for the Project was not considered appropriate or realistic.

For a further check on the reliability of the methodology used in the Draft SEIR, we estimated the number of Project employees using City of Los Angeles VMT Calculator documentation for hotel/motel and adding employees for ancillary uses, SCAG Employee Density 2001, and employee ratio derived from ITE trip rates as used in the Millennium Hollywood Project (Crain and Associates 2013). See Tables 1 and 2, With each methodology (including the FTE estimate per economic report), the total number of employees was found to be comparable to the employee estimate used in the Project’s VMT analysis. Based on our experience and the various approaches evaluated, we determined that the SANDAG model provided the most appropriate and reliable basis for estimating the Project’s employee service population.

Table 1. Number of Employees Estimated Using City of Los Angeles VMT Calculator Documentation
Project
Component
Employment
Densitya Emp./Unit
No. of Units
(Rooms or TSF) No. of Employees
Rooms 0.5 per room 0.5 500 rooms 250
Ballroom 2 per TSF 2 9.49 TSF 19
Meeting room 2 per TSF 2 8.225 TSF 16
Food 2 per TSF 4 22.296 TSF 89
Arcade 2 per TSF 2 7.000 TSF 14
Themed amenities 2 per TSF 2 13.238 TSF 26
Spa 2 per TSF 2 8.532 TSF 17
Total employees 431
Source: LADOT and DCP 2020.

Notes: emp. = employees; TSF = thousand square feet.
a Based on LADOT and DCP 2020.
643

MEMORANDUM
SUBJECT: EMPLOYEE VMT ESTIMATION FOR B-2 SITE HOTEL PROJECT 16294 3
MAY 2026
Table 2. Number of Employees Estimated per ITE and SCAG Employee Density Survey Used in the Millennium Hollywood Project
Project
Component
Employment
Density Emp./Unit
No. of Units
(Rooms or TSF) No. of Employees
Rooms 0.57 per rooma 0.57 per room 500 rooms 285
Ballroom 1 per 424 square
feetb

2.35 per TSF 9.49 TSF 22
Meeting room 8.225 TSF 19
Food 22.296 TSF 53
Arcade 7.000 TSF 17
Themed amenities 13.238 TSF 31
Spa 8.532 TSF 20
Total employees 447
Source: Crain and Associates 2013.

Notes: ITE = Institute of Transportation Engineers; SCAG = Southern California Association of Governments; emp. = employees; TSF = thousand square feet.
a Per ITE trip rate conversion used to estimate employee per room ratio in Millennium Hollywood Project. b Per SCAG 2001, Employee Density Study, Table 5A.

References
City of Garden Grove. 2022. City of Garden Grove Economic Development Report & Analysis, B-2 Site: NewAge Garden Grove ll, LLC Nickelodeon Resort Hotel Prepared Pursuant to Government Code Sections §53083 and §52201. August 28, 2022. https://ggcity.org/sites/default/files/economic-development-report-andanalysis.pdf.

City of Hotels. 2025. “Hotel Staff.” Online article. https://www.city-of-hotels.com/165/hotel-staff-en.html.

ITE. 2025. Trip Generation Manual, 12th Edition. August 2025. https://www.ite.org/technical-resources/ topics/trip-and-parking-generation-v2/trip-generation-info/.

LADOT and DCP (Los Angeles Department of Transportation and Los Angeles Department of City Planning). 2020.

City of Los Angeles VMT Calculator Documentation, Version 1.3. May 2020. https://ladot.lacity.gov/ sites/default/files/documents/vmt_calculator_documentation-2020.05.18.pdf.

SANDAG (San Diego Association of Governments). 2023. SANDAG ABM2+ Version 14.2.2. File containing information on land use unit type. Email communication between C. Arellano and S. Tewani.

September 11, 2023.
644

MEMORANDUM
SUBJECT: EMPLOYEE VMT ESTIMATION FOR B-2 SITE HOTEL PROJECT 16294 4
MAY 2026
SCAG (Southern California Association of Governments). 2001. Employment Density Study Summary Report.

U.S. Bureau of Labor Statistics. 2026. “Industries at a Glance: Accommodation and Food Services: NAICS 72.” Accessed April 22, 2026. https://www.bls.gov/iag/tgs/iag72.htm#earnings. 645
Excerpts from US Bureau of Labor Statistics
646
Accommodation and Food Services: NAICS 72 : U.S. Bureau of Labor Statistics https://www.bls.gov/iag/tgs/iag72.htm#earnings
647
Excerpts from LADOT and DCP 2020
648
City of Los Angeles VMT Calculator Documentation
May 2020
City of Los Angeles 10
affordable housing sites in the Los Angeles area. More information on the Affordable Housing rates can be found in Appendix B.
● Multi-Family Dwelling: Use 2002 Multi Family Trip Rates from the San Diego Association of Governments (SANDAG) of six trips per unit2. This Southern California based rate more closely matches rates that were observed in Los Angeles.

Table 1: Land Use and Trip Generation Base Assumptions
Land Use Unit ITE Code Daily Vehicle Trip
Rate A
Population/ Jobs
Per Unit B
Single Family
Residential DU 210 9.52 3.15
Multi-Family
Residential DU NA C 6.00 2.25
Townhouse DU 230 5.81 2.25
Affordable
Housing - Family DU NA D 4.16 3.14
Affordable
Housing - Senior DU NA D 1.72 1.21
Affordable
Housing - Special
Needs
DU NA D 1.49 1.85
Affordable
Housing -
Permanent
Supportive
DU NA D 1.23 1.12
General Retail KSF 820 42.70 2.0
Furniture Store KSF 890 5.06 0.75
Pharmacy/Drugsto
re
KSF 880 90.06 2.0
Supermarket KSF 850 102.24 4.0
Bank KSF 912 148.15 5.0
Health Club KSF 492 32.93 1.0
High-Turnover SitDown Restaurant KSF 932 127.15 E 4.0
Fast-Food
Restaurant KSF 932 127.15 E 6.7
Quality Restaurant KSF 931 89.95 4.0
Auto Repair KSF 942 26.80 1.0
2 San Diego Association of Governments, (Not So) Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region, April 2002.
649
City of Los Angeles VMT Calculator Documentation
May 2020
City of Los Angeles 11
Home
Improvement
Superstore
KSF 862 30.74 2.2
Free-Standing
Discount Store KSF 813 50.75 2.0
General Office KSF 710 Log Equation F 4.0
Medical Office KSF 720 36.13 3.0
Light Industrial KSF 110 6.97 1.0
Manufacturing KSF 140 3.82 0.5
Warehousing/SelfStorage KSF 151 2.50 0.33
Hotel (including
restaurant,
facilities, etc.)
Rooms 310 8.17 0.5
Motel Rooms 320 5.63 0.5
Movie Theater
(Theater with
Matinee)
Seats 444 0.70 0.02
University Students 550 1.71 0.25
High School Students 530 1.71 0.1
Middle School Students 522 1.62 0.1
Elementary School Students 520 1.29 0.1
Private School (K12) Students 534 2.48 0.15
A: Source: Institute of Transportation Engineers, Trip Generation, 9th Edition, 2012, except where otherwise noted.

B: See Section 3.4.

C: Multi-Family uses SANDAG 2002 Multi Family Trip Rates of 6 trips per unit.

D: These rates were determined from vehicle trip counts conducted at 42 affordable housing sites in the City of Los Angeles. Because these local data reflect conditions in Los Angeles more closely than ITE trip rates, the VMT Calculator applies an MXD multiplier to the base rate to improve the MXD model fit for affordable housing uses.

E: Uses the daily ITE 932 rate of 127.15 trips per thousand square feet for Suburban and Suburban Center TBZs. Urban and Compact Infill TBZs are reduced by one standard deviation (41.77 daily trips).

F: General Office uses the ITE 710 Log Equation when office space is of sufficient size (above 206 KSF). When the office space is at or below this size, and the log equation exceeds 11.03 trips per KSF, General Office uses the ITE average rate of 11.03 trips per KSF.

3.2 MXD Reductions

3.2.1 MXD Methodology
The ITE trip generation methodology is primarily based on data collected at suburban, single-use, freestanding sites. These defining characteristics limit ITE’s applicability to mixed-use or multiuse development projects, and may not accurately estimate the project vehicle trip generation.

In response to the limitations in the ITE methodology, and to provide a straightforward and empirically validated method of estimating vehicle trip generation at mixed-use developments, 650
Excerpts from Millennium Hollywood Project,
Crain and Associates 2013
651
Appendix B
Transportation Modeling Procedures and Results
652
Crain and Associates
February 1, 2013
Millennium Hollywood Project
Transportation Modeling Procedures and Results
1 The Traffic Study prepared for the Draft EIR determined that the Project impacts to freeway segments would be less than significant based on the Los Angeles County Congestion Management Program (CMP) criteria. The analysis and the methodology (CMP criteria) were approved by the Los Angeles Department of Transportation (LADOT). Further support is provided by the Hollywood Community Plan Update Environmental Impact Report as the Hollywood Community Plan Update was also determined not to have a significant impact on the freeway system. To further verify these conclusions, an additional model analysis was conducted. The analysis used the current Southern California Association of Governments (SCAG) model for year 2035, as refined by LADOT for use in the City of Los Angeles, for the initial future projections (the Base Model).

To determine the Project impacts based on the Base Model, it was necessary to determine the demographic characteristics of the Project. A set of demographic density rates of the different Project land uses are included in Table 1. The Los Angeles County rates from The Employment Density Study Summary, The Natelson Company, October 31, 2001, prepared for SCAG were used to estimate the employee density in terms of building area for the Project commercial uses (except hotel, which was specified by room, rather than building area). For residential uses, data on daily trip generation from the ITE Land Use Code 220 was reviewed and the weekday trip generation ratio indicated 2.01 persons per unit. To be conservative, ratios of 2.5 persons and 1.2 workers per unit were assumed (e.g., those used in other studies for single family housing units). For hotel rooms, data on daily trip generation from the ITE Land Use Code 310 was reviewed and the weekday trip generation ratio indicated 0.57 employees per room. Table 2 shows the rates utilized and the resulting demographic estimates.

The Project impacts were analyzed using the Base Model rerun for scenarios assuming two different conditions. Those scenarios addressed the case that the Project, or similar land-uses for the Project Site, was included within the Base Model assumptions and, alternatively, the case that the Project was an incremental addition to the Base Model assumptions. The two cases were examined since the Base Model zones each contain a larger area than the Project Site and greater amount of land-uses than the Project. This was further complicated by the Project Site being partially within each of two zones.

Table 3 shows the Model Demographic data split between the two zones.

To create the model demographics input data for the two reruns, 1) the demographics for the Project land uses were subtracted from the Base Model demographics for the Central Hollywood zones that included the Project Site, and 2) the Project demographics were added to the Base Model demographics for the those zones. The results from the model reruns were compared to the Base Model results to determine the Project impact. 653
2 Table 1
Model Demographic Rates and Overall Estimates
Source Land Use ITE Daily Trip Rate Density Rate Size Estimate Residential
ITE LU 220 Apartment [A] 6.65 trips/ dwelling unit
[B] 3.31 trips/ person
[A]/[B] 2.01 person/ dwelling unit 2.5 person/du 1,153 461 persons

1.2 worker/du 553 461 workers
Office
SCAG General Office 1 emp. / 440 sf 601 264,303 other emp.

Other Commercial
SCAG Health/Fitness Club 1 emp. / 424 sf 189 80,000 service emp.

SCAG Retail 1 emp. / 424 sf 100,000 retail emp. 236
SCAG Quality Restaurant 1 emp. / 424 sf 25,000 retail emp. 59 ITE LU 310 Hotel [A] 8.17 trips/ room
[B] 14.3 trips/ employee
[A]/[B] 0.57 employee/ room 0.57 emp./room 145 254 service emp.

Table 2
Demographic Estimates by Model Variable
LU Use/Description Size Units Source TotPop ResdPop Workers Retail Service Other Proposed Uses
220 Apartments 461 MDU 2.5 1.2 ITE 1153 1153 553
310 Hotel 254 rooms 0.6 ITE 145
492 Health/Fitness Club 80,000 bldg sf 1/ 424 SCAG 189
710 General Office 264,303 bldg sf 1/ 440 SCAG 601
820 Retail 100,000 bldg sf 1/ 424 SCAG 236
931 Quality Restaurant 25,000 bldg sf 1/ 424 SCAG 59
Existing Uses
710 General Office 114,303 bldg sf 1/ 440 SCAG 260
Rate(s)
Demographics
Population Employees
The anticipated volumes of the Hollywood freeway segments nearest to, but beyond, the Project access points were compared between the scenarios. The results from the model runs for the most impacted segments (those immediately north and south of the Project Site access) are shown and compared in the Table 4. Table 4 demonstrates that the Project will have lower impacts than the less than significant impacts shown in the Draft EIR (i.e. lower impacts than conservatively analyzed in the Traffic Study and the Draft EIR). 654
3 Table 3
Project Demographic Estimates by Site
2010 to 2035 Minimum Data Increment (Entire Site): County Residential 100% Office 100%
TotPop 1153 TOTHH 461 TotJobs 969 K12Sch 0 Other Com. 100% ResPop 1153 SDU 0 RetJobs 295 ColeNR 0
GRPQ 0 MDU 461 SrvJobs 333
Workers 553 OthJobs 341
2010 to 2035 Minimum Data Increment (East Site): County Residential 40% Office 100%
TotPop 461 TOTHH 184 TotJobs 624 K12Sch 0 Other Com. 45% ResPop 461 SDU 0 RetJobs 133 ColeNR 0
GRPQ 0 MDU 184 SrvJobs 150
Workers 221 OthJobs 341
2010 to 2035 Minimum Data Increment (West Site): County Residential 60% Office 0%
TotPop 692 TOTHH 277 TotJobs 345 K12Sch 0 Other Com. 55% ResPop 692 SDU 0 RetJobs 162 ColeNR 0
GRPQ 0 MDU 277 SrvJobs 183
Workers 332 OthJobs 0
Los Angeles
Los Angeles
Los Angeles
Table 4
Projected Freeway Volumes
Segment Direction Base Model Model Result Project Trips Model Result Project Trips AM Peak Hour
North of Vine St. Northbound 8,336 8,358 -22 8,362 26
Southbound 7,718 7,720 -2 7,717 -1
South of Santa Monica Bl. Northbound 8,534 8,555 -21 8,567 33 Southbound 7,775 7,779 -4 7,783 8
PM Peak Hour
North of Vine St. Northbound 15,031 15,055 -24 15,039 8 Southbound 9,323 9,328 -5 9,322 -1
South of Santa Monica Bl. Northbound 14,476 14,501 -25 14,491 15 Southbound 9,872 9,871 -1 9,892 21
Year 2035 Volumes
Base Minus Project Base Plus Project
In reviewing Table 4, note that the Project is an infill set of land uses that will intercept a proportion of the trips linked to the Project. This, combined with the mixed use and transit oriented nature of the Project, will result in trip reductions on some segments. Thus, even though the Project will add some trips to the regional system, as demonstrated in Table 4, the 655
4 Project will reduce a similar number of trips and will also have limited impacts to the volumes on the regional highway system or trip reductions on some segments. Further, the Project is infill, mixed-use and transit-oriented development as called for by SCAG in the Regional Mobility Plan and the Metropolitan Transportation Authority (Metro) in the Congestion Management Plan (CMP).

In summary, the model demonstrated that the Project will not result in the addition of 150 trips or more to any freeway segment. This analysis verifies that Project traffic impacts on the regional system will be less than significant.
656
Excerpts from SCAG Employment Density Study 2001
657

BROAD POLYGON SELECTION
THE NATELSON COMPANY, INC.

Summary Report - Page 19
Employment Density Study
Table 5A
Derivation of Square Feet per Employee Based on:
--MEDIAN EMPLOYEES PER ACRE
--MEDIAN FAR
ORANGE COUNTY Net/Gross Adjustment Factor: 0.75
# of Employees/ Building Square Feet/
Land Use Category Records FAR Acre Efficiency Employee
Regional Retail 17 0.95 10.68 0.80 2,322
Other Retail/Svc. 234 0.24 14.87 0.85 450
Low-Rise Office 121 0.35 28.87 0.90 352
High-Rise Office 17 0.38 47.61 0.90 235
Hotel/Motel 0 -- 14.01 N/A --
R & D/Flex Space 12 0.36 21.93 0.95 511
Light Manufacturing 245 0.40 15.99 0.95 786
Heavy Manufacuring 0 -- 51.99 N/A --
Warehouse 56 0.46 10.59 0.95 1,350
Government Offices 20 0.37 26.73 0.90 408
Table 6A
Derivation of Square Feet per Employee Based on:
--AVERAGE EMPLOYEES PER ACRE
--AVERAGE FAR
ORANGE COUNTY Net/Gross Adjustment Factor: 0.75
# of Employees/ Building Square Feet/
Land Use Category Records FAR Acre Efficiency Employee
Regional Retail 17 0.78 28.87 0.80 704
Other Retail/Svc. 234 0.26 22.58 0.85 325
Low-Rise Office 121 0.42 43.24 0.90 287
High-Rise Office 17 0.54 72.52 0.90 218
Hotel/Motel 0 -- 35.06 N/A --
R & D/Flex Space 12 0.36 23.92 0.95 466
Light Manufacturing 245 0.41 22.60 0.95 558
Heavy Manufacuring 0 -- 31.09 N/A --
Warehouse 56 0.40 12.63 0.95 979
Government Offices 20 0.31 44.42 0.90 206
658
FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-1
4 Supplemental Mitigation Monitoring
and Reporting Program

EXHIBIT "B" 659
4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-2
Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measures/Project Design Features Implementation Timing Agency
Responsible for
Monitoring Initials
Date of
Completion
Greenhouse Gas Emissions
Mitigation Measures
MM-GHG-1: Construction Equipment Electrification. Prior to issuance of building permits, the Project Applicant’s or designee’s contractor shall submit a Construction Equipment Emissions Minimization Plan for City of Garden Grove (City) approval that:
(1) Identifies all off-road equipment anticipated by phase. (2) Requires generators, cranes, electric scissor/boom lifts, forklifts/telehandlers (where feasible), welders (where feasible), and electric/solar light towers when commercially available. (3) Requires grid power for temporary construction.
(4) Where electric equipment is not available for a listed task, documents non-availability (size/class, delivery lead time, site constraints) and requires the cleanest feasible alternative (Tier 4 Final/zero-emission alternatives as available).

Prior to the issuance of
building permits
City of Garden
Grove
MM-GHG-3: Construction Debris Recycling. Prior to the start of construction, the Project’s contractor shall develop a Construction Waste Management Plan (Plan) for submittal and approval to the City Prior to the start of
construction
City of Garden
Grove
660
4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-3
Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measures/Project Design Features Implementation Timing Agency
Responsible for
Monitoring Initials
Date of
Completion
of Garden Grove. The Plan shall recycle or salvage non-hazardous construction debris including but not limited to wood, metal, concrete, asphalt, and other reusable materials generated during construction activities. The contractor shall implement the Plan to achieve a minimum diversion target of 75% of non-hazardous construction and demolition debris from landfills, exceeding the City’s current 65% diversion requirement. (CAPCOA Measure S-4)
MM-GHG-4: Electric Vehicle Charging Infrastructure. Prior to issuance of building permits, the Project Applicant or designee shall submit a site plan to the City of Garden Grove for approval noting the location of electric vehicle infrastructure and charging stations. Prior to issuance of the final certificate of occupancy, the Project Applicant or designee shall provide electric vehicle (EV) charging infrastructure within the Project site as required by the applicable California Green Building Standards Code, but that, at a minimum, meets or exceeds 2022 California Green Building Standards Code Tier 2 standards. Tier 2 requires approximately 225 parking spaces to be EV capable, and 75 spaces to be equipped with EV Supply Equipment (EVSE). The Project shall install a minimum of 225 EV capable spaces and 100 EVSE spaces. (CAPCOA Measure T-14)
Prior to the issuance of
building permits
City of Garden
Grove
MM-GHG-5: Guest Vehicle Trip Reductions. Prior to issuance of building permits, the Project Applicant shall submit a site plan to the City of Garden Grove for approval identifying where pedestrian and bicycle connections to adjacent facilities will be provided and where bicycle parking spaces will be provided. The City shall verify the inclusion of pedestrian and bicycle infrastructure prior to the issuance of the final certificate of occupancy. The Project Applicant or designee shall ensure that, at a minimum, the following trip reduction measures are implemented during Project operations to reduce the number of auto-based trips generated by the Project and to encourage the use of transit, bicycling, and walking.

Prior to the issuance of a
building permits
City of Garden
Grove
661
4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-4
Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measures/Project Design Features Implementation Timing Agency
Responsible for
Monitoring Initials
Date of
Completion
▪ Improve the walkability and design of the Project by providing pedestrian and bicycling connections within the Project site and to adjacent off-site facilities (i.e., sidewalks, crosswalks, wayfinding signage, etc.).
▪ Provide secure on-site bicycle racks to accommodate a minimum of 38 bicycle parking spaces and provide bicycle rentals for hotel guests.
▪ Alternative transportation services such bike rentals and transit information shall be seamlessly integrated into the guest experience, making alternative modes of travel easy to
understand, access, and use.
▪ Hotel management/concierge should provide information that promotes walking, bicycling and public transit options to nearby attractions. This should include real-time transit information provided through dedicated monitors, interactive electronic displays, websites, or mobile applications identifying local bus routes and schedules, as well as wayfinding to the existing transit stops within the Project vicinity.
▪ Provide a dedicated shuttle service linking the hotel to nearby shopping and entertainment destinations, prioritizing
battery‑electric vehicles where route length and charging logistics allow; the program may be operated under a vendor contract with scheduled runs during peak guest activity and on‑demand service for special events.
▪ Hotel management will make available transit passes for purchase and provide clear wayfinding to public transit and shuttle services.
▪ Qualitative assessments (e.g., user satisfaction surveys, walk audits, guest feedback) shall be regularly conducted to evaluate the effectiveness of trip reduction strategies.
▪ An annual report summarizing how transportation options are being used, guest perceptions, and planned improvements shall be submitted to the City.
662
4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-5
Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measures/Project Design Features Implementation Timing Agency
Responsible for
Monitoring Initials
Date of
Completion
(CAPCOA Measures T-34, T-38, T-43, and T-44)
MM-GHG-6: Limit Large Diesel Trucks During Operation. Prior to issuance of certificate of occupancy, the Project Applicant or designee shall submit a Truck Delivery Management Plan to the City of Garden Grove that documents how truck deliveries will be restricted and monitored. The Project Applicant or designee shall implement a monitoring program to restrict the number of large diesel trucks coming to the site (i.e. for deliveries, trash collection, or other services) to an average of 10 trucks per day or less. This restriction is specifically applicable to trucks classified as medium-heavy duty and heavy-heavy duty with gross vehicle weight (GVW) greater than 19,500 pounds. Annual reports summarizing heavy-duty truck trips shall be provided to the City of Garden Grove. (CAPCOA Measure C-2) Prior to the issuance of a
certificate of occupancy
City of Garden
Grove
MM-GHG-7: Building Energy Efficiency Measures. Prior to issuance of building permits, the Project Applicant or designee shall submit documentation of building energy efficiency measures to the City of Garden Grove, such that a minimum of 15% above 2022 Title 24 Building Envelope Energy Efficiency Standards is achieved. Energy efficiency measures shall include, at a minimum, the following:

Garden Grove City CouncilJune 9, 2026

Garden Grove City Council
June 9, 2026