item 21 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 Statem — Garden Grove City Council, June 9, 2026 (part 1 of 2)

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 s ettlement 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 W rit 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 Ap provals, 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 wai ved, 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 Garden Grove City Council
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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 comme nt during the CEQA - required 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 Con siderations” per CEQA Guidelines Section 15093 Garden Grove City Council
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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) adopt s the Supplemental Mitigation Monitoring and Reporting Program attached hereto as Exhibit “B” and incorporated herein by reference; and (c) adopt s 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.

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"

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

TABLE OF CONTENTS
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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

ACRONYMS AND ABBREVIATIONS
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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 Hot el; 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. 1 – INTRODUCTION
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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 strike through 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.

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 commen ters, 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 comment ers (California Public Resources Code Section 21091[d][2][B]); 14 CCR 15088[c], 14 CCR 15132[d], 14 CCR 15204[a]).

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Comment Letter – Caltrans (A1)

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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 bicyc ling 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.

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Comment Letter – SAFER (O1)

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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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Comment Letter – Unite Here Local 11 (O2)

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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 MM- GHG-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, t he 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. 2 – RESPONSES TO COMMENTS RECEIVED
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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 F inal 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 C enter 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 Agr icultural and Rural Environment v. C ounty 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; 2 – RESPONSES TO COMMENTS RECEIVED
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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 con sistent 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 analyz ing 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 trip - generating 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 2 – RESPONSES TO COMMENTS RECEIVED
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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 water- related 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 i s 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 r ooms, 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 2 – RESPONSES TO COMMENTS RECEIVED
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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 Project- generated 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 a nd 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 P DF in the MMRP that limits the number of employees and guests to the assumptions used in the Draft SEIR. 2 – RESPONSES TO COMMENTS RECEIVED
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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 CO ₂e 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 emission s 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, t he 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. 2 – RESPONSES TO COMMENTS RECEIVED
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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 an d 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 End- of-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 2 – RESPONSES TO COMMENTS RECEIVED
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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 VM T 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 CO 2e 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 lo cal 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 transportatio n-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 CO 2e 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 measure s 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 specifi ed 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 CO 2e. 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 2 – RESPONSES TO COMMENTS RECEIVED
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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 th at 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 (Austin- Harris, 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, 2 – RESPONSES TO COMMENTS RECEIVED
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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 densitie s (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 no n-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, us ing the incorrect inputs suggested by the comment would undermine the credibility of the SANDAG model results because it disregards the basic building-square- footage-based methodology to identify an employment density for high -rise hotels. Excerpts from SANDAG ABM2+ Enhancements Final Repo rt, 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 attachment s 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 underestimat ion 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 2 – RESPONSES TO COMMENTS RECEIVED
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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 Angel es 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 commen t’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 co ntext” (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 2 – RESPONSES TO COMMENTS RECEIVED
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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 anal ysis 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 r ecognizes 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 2 – RESPONSES TO COMMENTS RECEIVED
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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 us ing 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 include s 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 no- project alternativ e 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 enh anced 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 2 – RESPONSES TO COMMENTS RECEIVED
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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 be en 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, Mixed- Use Development Alternative, pp. 6 -5 and 6-6). The SEIR demonstrates that neither of those options were feasible o r 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 2 – RESPONSES TO COMMENTS RECEIVED
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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. 2 – RESPONSES TO COMMENTS RECEIVED
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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 a n analysis of the Project ’s consistency with app licable 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 i s 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 2 – RESPONSES TO COMMENTS RECEIVED
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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, t he 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, high - performance 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 detai led 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 2 – RESPONSES TO COMMENTS RECEIVED
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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 devel oped 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. S enate 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. 2 – RESPONSES TO COMMENTS RECEIVED
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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, enf orceable 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 fe asible 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 do es 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. 2 – RESPONSES TO COMMENTS RECEIVED
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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 meas ures 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 a nd 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 a s 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 2 – RESPONSES TO COMMENTS RECEIVED
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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 (NO x) 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 pu rposes 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 s tage 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 know n to be feasible and commercially available at the time of Project im plementation. 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 2 – RESPONSES TO COMMENTS RECEIVED
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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 emis sions 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., NO x) 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 th en 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 2 – RESPONSES TO COMMENTS RECEIVED
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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 t he 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 c omment 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 mitiga tion 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 address ed 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 lodgi ng 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 charac terization 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 2 – RESPONSES TO COMMENTS RECEIVED
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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 Vehicl e 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 space s 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 2 7 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 long - term bicycle spaces.
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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 MM- GHG-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 CO ₂e (unmitigated) to 2,480 MT CO₂e (mitigated) (Draft SEIR, Appendix C, PDF pp. 142 and 215). 2 – RESPONSES TO COMMENTS RECEIVED
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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 h otel 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 CAPCO A Handbook.

Further, the Project site is already located adjacent to a Class II bike lane. 2 – RESPONSES TO COMMENTS RECEIVED
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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 strate gy. 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 p ossible 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 Real- Time 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), wh ich typically targets 2 – RESPONSES TO COMMENTS RECEIVED
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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 providin g 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 considere d 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. 2 – RESPONSES TO COMMENTS RECEIVED
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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 identifie d VMT reduction using the measures identified as part of MM-TRA-1 in the Draft SEIR.
2 – RESPONSES TO COMMENTS RECEIVED
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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-TRA- 1, 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 tra nsportation 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 enviro nment (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 2 – RESPONSES TO COMMENTS RECEIVED
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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 ( MM- GHG-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 MM- GHG-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 Efficien cy 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 MM- GHG-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 2 – RESPONSES TO COMMENTS RECEIVED
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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 energy- efficient 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, MM- GHG-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 V erification 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 kilowatt - hours 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. 2 – RESPONSES TO COMMENTS RECEIVED
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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 2 – RESPONSES TO COMMENTS RECEIVED
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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 eval uated 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.

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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-of- governments.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-complete- 040424.pdf SCAG. 2024b. “Demographics & Growth Forecast.” Technical report, Connect SoCal 2024.

Adopted April 4, 2024. https://scag.ca.gov/connect-SoCal-2024.

FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-1
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. 3 – CHANGES TO THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-2

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 3 – CHANGES TO THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-3
▪ 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, page s 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 impact s related to VMT and c onflicts 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 hea ting 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 3 – CHANGES TO THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-4
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 Boulevard within 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. 3 – CHANGES TO THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-5
▪ 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 prov ided 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) 3 – CHANGES TO THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-6
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 3 – CHANGES TO THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-7
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 f ull 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.
3 – CHANGES TO THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-8
- 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 onboardi ng 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 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 lands cape 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. 3 – CHANGES TO THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-9
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. 3 – CHANGES TO THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-10
▪ 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 3 – CHANGES TO THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-11
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 CO 2e) 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 CO 2e. To mitigate operational emissions below the 1,400 MT CO 2e threshold, the Project would purchase and retire one lump sum of 180,270.60 MT CO 2e of offsets ([7,408.02 MT CO 2e − 6,009.02 [(offsets]) = 1,399 MT CO 2e remaining )]; 6,009.02 MT CO 2e × 30 -year life = 180,270.60 MT CO 2e; or purchase and retire 6,002.46 MT CO 2e 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 CO 2e) 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 3 – CHANGES TO THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-12
(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 additiona l 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 purchas e 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 Project - Based GHG Emissions Reductions and Removals 4 (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/. 3 – CHANGES TO THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-13
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.

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, pe rmanent, 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 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 G rove; (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 mi tigation 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 incl ude: (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 wi thheld. 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.

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. 3 – CHANGES TO THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-15
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 en courages 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 b icycle 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 3 – CHANGES TO THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-16
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 diesel - powered 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 e mission 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 impleme nting vendor standards that require environmental product declarations and third-party certifications to verify material sustainability . .Materials shall be selected not only 3 – CHANGES TO THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-17
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 subcontracto r 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 fact ors 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. 3 – CHANGES TO THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-18
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 Pla n 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 commercial - designated 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. 3 – CHANGES TO THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-19
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 desi gnated 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 con sistent. 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. 4 3, 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 3 – CHANGES TO THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-21
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 red uce 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. 3 – CHANGES TO THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-22
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 m easures 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 ma ndatory 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 3 – CHANGES TO THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-23
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 d uring 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 non - hazardous 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 -site Site ) 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, t he 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 pedestr ian 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 reduc e the number of auto -based trips generated by the Project and to encourage the use of transit, bicycling, and walking. 3 – CHANGES TO THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-24
▪ 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 appl icable 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 th e performance standard, the Project may implement a combination of the following water conservation strategies:
▪ Low-Flow Water Fixtures for guest rooms and public areas. 3 – CHANGES TO THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-27
▪ 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 d uring 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. 3 – CHANGES TO THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-29
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 zero - emission 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 c arbon 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 CO ₂e-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 ,” page s 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.

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 constr uction 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 op erational 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 CO 2e 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 Carb on 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 3 – CHANGES TO THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-33
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 Manual 8 (April 2024) and Climate Forward Program Manual 9 (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 Removals 10 (July 2023); and, Verra’s VCS Standard, Program Guide11 (August 2023), and Methodology Requirements12 (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 th e 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 CO 2e 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/. 3 – CHANGES TO THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 3-34
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, pe rmanent, 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.

13 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 G rove; (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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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 mi tigation 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 avail ability, 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. Th e 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 wi thheld. 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)
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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 Associati on (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 c arpooling, 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 Measure s 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. 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. 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

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 th e Draft Supplemental EIR are also provided in the table.

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 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).

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

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 Measure s/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

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 Measure s/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.
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 Measure s/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

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 Measure s/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

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 Measure s/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:
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 Measure s/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

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 Measure s/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

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 Measure s/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.

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 Measure s/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.
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 Measure s/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

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 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 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 Measure s/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.

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.

4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-15
Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/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 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.
4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-16
Scenario
Offsets
Required
(MT CO 2e)
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 CO2e = 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, 4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-17
Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/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. 4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-18
Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/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.

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.

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/. 4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-19
Table 4-1. 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.

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 4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-20
Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/Project Design Features Implementation Timing Agency
Responsible for
Monitoring Initials
Date of
Completion
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
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

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. 4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-21
Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/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.

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 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.
4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-22
Table 4-1. 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 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

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

4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-23
Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/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 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.

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

4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-24
Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/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

4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-25
Table 4-1. Supplemental Mitigation Monitoring and Reporting Program Mitigation Measure s/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. 4 – SUPPLEMENTAL MITIGATION MONITORING AND REPORTING PROGRAM FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-26

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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 thes e 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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5 – GENERAL RESPONSES TO POST–PUBLIC REVIEW COMMENT LETTERS RECEIVED FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 5-5
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 esta blished 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 tourism- based 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.

5 – GENERAL RESPONSES TO POST–PUBLIC REVIEW COMMENT LETTERS RECEIVED FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 5-6

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5 – GENERAL RESPONSES TO POST–PUBLIC REVIEW COMMENT LETTERS RECEIVED FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 5-7
Post–Public Review Comment Letter – Israel Espinoza (2)

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5 – GENERAL RESPONSES TO POST–PUBLIC REVIEW COMMENT LETTERS RECEIVED FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 5-9
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 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.

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 associa ted 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.

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5 – GENERAL RESPONSES TO POST–PUBLIC REVIEW COMMENT LETTERS RECEIVED FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 5-11
Post–Public Review Comment Letter – Kassidy Nguyen (3)

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5 – GENERAL RESPONSES TO POST–PUBLIC REVIEW COMMENT LETTERS RECEIVED FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 5-13
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 pr ovides 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 t o the PDFs incorporated into the Supplemental MMRP (see Chapter 4, Supplementa l 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 efficien cy 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 Ap pendix 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 imp lementation 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. 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 include d 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 o f 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 fundamentall y 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/.

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

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 Deve lopment 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

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 th is 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 L os 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
Density a Emp ./Unit
No. of Unit s
(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.

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 Unit s
(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-and- analysis.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.

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.

Excerpts from US Bureau of Labor Statistics
Accommodation and Food Services: NAICS 72 : U.S. Bureau of Labor Statistics https://www.bls.gov/iag/tgs/iag72.htm#earnings

Excerpts from LADOT and DCP 2020
C
ity 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 Sit-
Down 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.

C
ity 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/Self-
Storage 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 (K-
12) 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 multi - use 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, Excerpts from Millennium Hollywood Project,
Crain and Associates 2013
Appendix B
Transportation Modeling Procedures
and Results
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. 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 461 1,153 persons

1.2 worker/du 461 553 workers
Office
SCAG General Office 1e m p . / 4 4 0s f 264,303 601 other emp.

Other Commercial
SCAG Health/Fitness Club 1e m p . / 4 2 4s f 80,000 189 service emp.

SCAG Retail 1e m p . / 4 2 4s f 100,000 236 retail emp.

SCAG Quality Restaurant 1e m p . / 4 2 4s f 25,000 59 retail emp.

ITE LU 310 Hotel [A] 8.17 trips/ room
[B] 14.3 trips/ employee
[A]/[B] 0.57 employee/ room 0.57 emp./room 254 145 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 volum
es 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). 3 Table 3
Project Demographic Estimates by Site
2010 to 2035 Minimum Data Increment (Entire Site): County R esidential 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 R esidential 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 R esidential 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 Fr
eeway 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 Plus ProjectBase Minus 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 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.

Excerpts from SCAG Employment Density Study 2001

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

FINAL SUPPLEMENTAL EIR FOR SITE B-2 HOTEL PROJECT 16294 MAY 2026 4-1
4 Supplemental Mitigation Monitoring
and Reporting Program

EXHIBIT "B"
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 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).