The proposed Project is expected to provide employment opportunities for a highly skilled workforce, especially opportunities within the trades and construction industries during the construction phase of the Project, with the projected creation of a number of temporary construction jobs, including vendors and haul truckers (Updated Economic Report, p. 9). In addition, the proposed Project is projected to create 380 full- time equivalent operational jobs including management, front desk and concierge, and housekeeping staff (Updated Economic Report, p. 9). Moreover, the proposed Project is expected to ignite other employment opportunities within the City and broader region, leading to a multiplier effect that is anticipated to create an additional 1,790 jobs in the local communit y and region consistent with SCAG and regional growth projections (Updated Economic Report, p. 11).
A. Conclusion
The City of Garden Grove has balanced the Project’s benefits against the Project’s significant unavoidable impacts.
The City Council finds that the proposed Project’s benefits outweigh the Project’s significant unavoidable impacts, and that these impacts, therefore, are considered acceptable in light of the Project’s benefits. The City Council finds that each of the benefits described above is an overriding consideration, independent of the other benefits, which warrants approval of the Project notwithstanding the Project’s significant unavoidable impacts.
Attachment A
Supplemental Mitigation Monitoring and
Reporting Program
ATTACHMENT A / SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM MAY 2026 A-1
Supplemental Mitigation Monitoring and
Reporting Program
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.
2 Supplemental MMRP Table
Table 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 t he analysis in the Draft Supplemental EIR are also provided in the table.
ATTACHMENT A / SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM MAY 2026 A-2
Table 1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/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 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. (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 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 Prior to the start of
construction
City of Garden
Grove
ATTACHMENT A / SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM MAY 2026 A-3
Table 1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/Project Design Features
Implementation
Timing
Agency
Responsible for
Monitoring Initials
Date of
Completion
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.
▪ 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.
Prior to the issuance
of a building permits
City of Garden
Grove
ATTACHMENT A / SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM MAY 2026 A-4
Table 1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/Project Design Features
Implementation
Timing
Agency
Responsible for
Monitoring Initials
Date of
Completion
▪ 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.
(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) Prior to the issuance
of a certificate of
occupancy
City of Garden
Grove
ATTACHMENT A / SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM MAY 2026 A-5
Table 1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/Project Design Features
Implementation
Timing
Agency
Responsible for
Monitoring Initials
Date of
Completion
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 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. 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.
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.
Prior to the issuance
of building permits
City of Garden
Grove
ATTACHMENT A / SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM MAY 2026 A-6
Table 1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/Project Design Features
Implementation
Timing
Agency
Responsible for
Monitoring Initials
Date of
Completion
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 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)
MM-GHG-8: Cool Roof/Deck. Prior to issuance of building permits, the Project 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
- 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 Prior to the issuance
of building permits
City of Garden
Grove
ATTACHMENT A / SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM MAY 2026 A-7
Table 1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/Project Design Features
Implementation
Timing
Agency
Responsible for
Monitoring Initials
Date of
Completion
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:
▪ 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 Prior to receiving the
final certificate of
occupancy
City of Garden
Grove
ATTACHMENT A / SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM MAY 2026 A-8
Table 1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/Project Design Features
Implementation
Timing
Agency
Responsible for
Monitoring Initials
Date of
Completion
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 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.
Prior to issuance of
the final certificate of
occupancy
City of Garden
Grove
ATTACHMENT A / SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM MAY 2026 A-9
Table 1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/Project Design Features
Implementation
Timing
Agency
Responsible for
Monitoring Initials
Date of
Completion
- 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.
- 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)
ATTACHMENT A / SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM MAY 2026 A-10
Table 1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/Project Design Features
Implementation
Timing
Agency
Responsible for
Monitoring Initials
Date of
Completion
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 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 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.
During operations City of Garden
Grove
ATTACHMENT A / SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM MAY 2026 A-11
Table 1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/Project Design Features
Implementation
Timing
Agency
Responsible for
Monitoring Initials
Date of
Completion
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 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
ATTACHMENT A / SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM MAY 2026 A-12
Table 1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/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 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.
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 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)
ATTACHMENT A / SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM MAY 2026 A-13
Table 1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/Project Design Features
Implementation
Timing
Agency
Responsible for
Monitoring Initials
Date of
Completion
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.
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 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.
Quantification of GHG Emissions and Reductions Required Construction
ATTACHMENT A / SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM MAY 2026 A-14
Table 1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/Project Design Features
Implementation
Timing
Agency
Responsible for
Monitoring Initials
Date of
Completion
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 CO 2e)
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.
Scenario
Offsets
Required
(MT CO 2e)
Purchase and Retirement
Deadline
Lump sum 180,270.60 Prior to issuance of certificate of occupancy
ATTACHMENT A / SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM MAY 2026 A-15
Table 1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/Project Design Features
Implementation
Timing
Agency
Responsible for
Monitoring Initials
Date of
Completion
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 CO2e = metric tons of carbon dioxide equivalent; N/A = not applicable.
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.
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.
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
ATTACHMENT A / SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM MAY 2026 A-16
Table 1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/Project Design Features
Implementation
Timing
Agency
Responsible for
Monitoring Initials
Date of
Completion
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 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
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 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/
ATTACHMENT A / SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM MAY 2026 A-17
Table 1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/Project Design Features
Implementation
Timing
Agency
Responsible for
Monitoring Initials
Date of
Completion
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 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.
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. “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.
ATTACHMENT A / SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM MAY 2026 A-18
Table 1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/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.
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 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 offsets are unavailable; (3) offsets within the United States, only if in-state 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
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.
ATTACHMENT A / SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM MAY 2026 A-19
Table 1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/Project Design Features
Implementation
Timing
Agency
Responsible for
Monitoring Initials
Date of
Completion
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.
ATTACHMENT A / SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM MAY 2026 A-20
Table 1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/Project Design Features
Implementation
Timing
Agency
Responsible for
Monitoring Initials
Date of
Completion
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.
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 MM-GHG-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
ATTACHMENT A / SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM MAY 2026 A-21
Table 1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/Project Design Features
Implementation
Timing
Agency
Responsible for
Monitoring Initials
Date of
Completion
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
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 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.
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
City of Garden
Grove
ATTACHMENT A / SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM MAY 2026 A-22
Table 1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/Project Design Features
Implementation
Timing
Agency
Responsible for
Monitoring Initials
Date of
Completion
provision of bicycle
repair.
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.
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)
Prior to project
opening.
City of Garden
Grove
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.
During project
construction for
installation and
City of Garden
Grove
ATTACHMENT A / SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM MAY 2026 A-23
Table 1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/Project Design Features
Implementation
Timing
Agency
Responsible for
Monitoring Initials
Date of
Completion
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
operation for
maintenance and
provision of bicycle
rentals.
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.
ATTACHMENT A / SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM MAY 2026 A-24
INTENTIONALLY LEFT BLANK