Agenda packet — Lake Forest City Council, July 7, 2026 (part 2 of 7)

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therefore, the proposed project’s increase in demand for new or expanded police protection services would be negligible. The proposed project would not induce a substantial increase in population over that which was envisioned in the build-out of the City’s General Plan and the increased demand for police protection services would be negligible. As the proposed project would not result in a significant impact to any study area intersections; no substantial increase in response times for police or emergency vehicles would result from project development. The proposed project would implement Crime Prevention through Environmental Design (CPTED) techniques that would discourage and or reduce crime from occurring on site. The proposed project would not drive the need for a new police facility or expanded facility, the construction of which could cause significant environmental impacts.

Impacts would be less than significant, and no mitigation is required. (DEIR 4.15-12 to 4.15-14)

39. Threshold 4.15.1(iii): The proposed project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for schools.

Impact: The proposed project would not generate the need for new or physically altered school facilities, the construction of which could cause significant environmental impacts, to maintain an acceptable service ratio, response times, or other performance objectives for schools. Impacts would be less than significant. (DEIR at 4.15-14 to 4.15-15) a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures area applicable to this topical area. (DEIR at 4.15-14 to 4.15-15) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.15-14 to 4.15-15)
d. Supporting Explanation: It is not anticipated that the proposed project would result in a significant increase to the City’s population due to hiring out of area employees that would move to the City to work at the project site. The project does not include a residential component; therefore, it would not directly generate any schoolchildren, the addition of which could cause negative impacts to existing or future school facilities or programs. The project’s impact on school facilities is fully mitigated through payment of the requisite school facility development fees current at the time a building permit is issued. These fees would be directed towards maintaining adequate school facilities and programs, which would ensure that any impact to schools that could result from the proposed project would be offset by development fees, and in effect, reduce potential impacts to a less than significant level.

Therefore, impacts related to school facilities and programs, which would generate the need for new schools or an expansion of existing schools, the construction of which could cause significant environmental impacts, would be less than significant.

No mitigation is required. (DEIR 4.15-14 to 4.15-15)
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40. Threshold 4.15.1(iv): The proposed project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for parks.

Impact: The proposed project would not generate the need for new or physically altered park facilities, the construction of which could cause significant environmental impacts, to maintain an acceptable service ratio, response times, or other performance objectives for parks. Impacts would be less than significant. (DEIR at 4.15-15 to 4.15-16) a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures area applicable to this topical area. (DEIR at 4.15-15 to 4.15-16) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.15-15 to 4.15-16)
d. Supporting Explanation: It is not anticipated that the proposed project would result in a significant increase to the City’s population due to hiring out of area employees that would move to the City to work at the project site. The project does not include a residential component; therefore, it would not directly generate additional demand for park services or facilities. Project employees may increase the use of local park facilities during lunch breaks or after-work hours. However, given the relatively low number of employees on the project site, any increased usage would be minimal.

Therefore, the provision of new or physically altered park facilities would not be necessary, and no significant impact would result from development of the proposed project. Impacts would be less than significant, and no mitigation is required. (DEIR

4.15-15 to 4.15-16)

41. Threshold 4.15.1(iv): The proposed project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for other public facilities.

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c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.15-16)
d. Supporting Explanation: It is not anticipated that the proposed project would result in a significant increase to the City’s population due to hiring out of area employees that would move to the City to work at the project site. The proposed project is consistent with the site’s General Plan designation and does not represent unplanned growth given that the project site would be developed consistent with its land use and zoning designations. Therefore, the proposed project would not result in a demand for more services at City-owned facilities, such as libraries, beyond what was anticipated and planned for. Impacts would be less than significant, and no mitigation is required. (DEIR at 4.15-16)

42. Cumulative Impact: Project development, together with cumulative projects, would not result in significant impacts related to public services in the project area. (DEIR at 4.15- 16 to 4.16-17)
a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures area applicable to this topical area. (DEIR at 4.15-16 to 4.16-17) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.15-16 to 4.16-17)
d. Supporting Explanation: The proposed project would have a less than significant impact on public services including fire protection, police protection, schools, parks, and other public facilities. Additionally, all discretionary private development and public works projects within the cumulative study area would be required to adhere to applicable standards, regulations, and fee requirements. Potential impacts on public services would be evaluated and mitigated by individual private cumulative development to reduce or eliminate project-specific public service impacts; therefore, implementation of the proposed project, in combination with other development in the City, would not contribute to a cumulatively considerable impact on public services.

Cumulative impacts relative to public services would be less than significant, and no mitigation is required. (DEIR at 4.15-16 to 4.15-17)
Recreation:

43. Threshold 4.16.1: The proposed project would not increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated.

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a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.16-4 to 4.16-5) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.16-4 to 4.16-5)
d. Supporting Explanation: The proposed project does not propose any residential use; therefore, it would not directly increase the population of the City. It is reasonable to assume that the majority of the new jobs generated by the proposed project would be filled by existing City residents and residents of nearby cities within Orange County; therefore, the proposed project would not generate a significant increase in the City’s population. The proposed project is consistent with the site’s General Plan designation and does not represent unplanned growth given that the project site would be developed consistent with its land use and zoning designations. Because the proposed project would not significantly increase the City’s population, the proposed project would not cause an increase in the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated. Persons employed on-site may utilize existing park or trail facilities; however, any increased usage would be minimal given the relatively low number of employees on the project site and would not result in substantial physical deterioration of the parks thereby requiring additional improvements. Impacts would be less than significant, and no mitigation is required. (DEIR 4.16-4 to 4.16-5)

44. Cumulative Impact: Project development, together with cumulative projects, would not result in significant impacts related to recreation in the project area. (DEIR 5.16-5 to

4.16-6)
a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 5.16-5 to 4.16-6) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 5.16-5 to 4.16-6)
d. Supporting Explanation: While the proposed project may generate an increase in the use of parks and recreational facilities, given that many of the new employees would already be using City parks and/or recreational facilities, the proposed project would not generate a significant increase in the use of nearby parks and recreational facilities to a level that would contribute to substantial physical deterioration of those facilities. Development within the cumulative study area that includes a residential component would be required to provide the appropriate amount of parkland or pay the in-lieu fees pursuant to City requirements, thereby mitigating the specific projects contribution to the cumulative effect of increased residential use on park facilities.

When considered with other projects in the City, development of the proposed Item: 9
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project would not contribute a significant cumulative impact related to recreation. Cumulative impacts to recreation would be less than significant, and no mitigation is required. (DEIR 4.16-5 to 4.16-6)
Transportation and Traffic:

45. Threshold 4.17.1: The proposed project would not conflict with program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities.

Impact: The proposed project would not conflict with a program plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. Impacts would be less than significant. (DEIR at 4.17-7 to 4.17-10) a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.17-7 to 4.17-10) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.17-7 to 4.17-10)
d. Supporting Explanation: The seven intersections studied in the Traffic Impact Analysis (DEIR, Appendix J), are forecast to operate at an acceptable level of service (LOS) during the a.m. and p.m. peak hours both in Existing (2024) with Project and Opening Year (2027) with Cumulative Projects with Project traffic conditions. Project driveways are forecast to operate at satisfactory LOS during both the a.m. and p.m. peak hours. Therefore, the proposed project would not conflict with any program, plan, ordinance, or policy addressing roadways and intersection facilities, or decrease the performance of such facilities.

The project is consistent with the applicable City policies relative to bicycle, pedestrian mobility, and maintenance of a safe transportation network. (DEIR Table

4.17,A, at 4.17-8 to 4.17-9) The proposed project would maintain the existing walkways/sidewalks in the vicinity of the project site. In addition, the proposed project would construct an accessible on-site pedestrian path through the parking lot to a paved walkway along the north side of the building that leads to the primary office area in the northwest corner of the building and the secondary office area in the northeast corner of the building. Additionally, the proposed project would provide 31 bicycle racks. Therefore, the proposed project would support and promote pedestrian mobility and the use of alternate modes of transportation. OCTA Route 177 stops at the southwest and northeast corners of the intersection of Lake Forest Drive/Dimension Drive approximately 2,200 feet away from the project driveway.

Existing transit facilities in the nearby proximity to the project site would be able to accommodate the potential increase in ridership. Therefore, implementation of the proposed project would not conflict with plans, programs, and policies regarding transit facilities or decrease the performance of such facilities. Impacts would be less than significant, and no mitigation is required. (DEIR 4.17-7 to 4.17-10) Item: 9
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46. Threshold 4.17.3: The proposed project would not substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment), and would not include design features or uses that may cause traffic hazards such as sharp curves, tight turning radii from streets, limited roadway visibility, short merging lanes, uneven road grades, or any other conditions determined by the City traffic engineer to be a hazard.

Impact: The proposed project would not substantially increase hazards due to a geometric design feature or incompatible uses, and would not include design features or uses that may cause traffic hazards such as sharp curves, tight turning radii from streets, limited roadway visibility, short merging lanes, uneven road grades, or any other conditions determined by the City traffic engineer to be a hazard. Impacts would be less than significant. (DEIR at 4.17-13 to 4.17-15)
a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.17-13 to 4.17-15) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.17-13 to 4.17-15)
d. Supporting Explanation: The design of the proposed project does not include any geometric design features or incompatible uses that could substantially increase circulation/traffic hazards. Vehicular access to the project site would continue to be provided via two existing driveways on Enterprise Way and an existing shared drive aisle that connects to the adjacent property at the northeast corner of the site. Both existing driveways on Enterprise Way would provide access for circulation for autos, loading and delivery trucks, waste vehicles, and emergency vehicles. Both existing driveways on Enterprise Way can accommodate trucks and would not require widening to accommodate truck turns. Truck circulation would be accommodated from the west and east sides of the building. Loading docks would be located on the southwest side of the proposed building. The proposed project would be required to design, construct, and maintain structures, roadways, and facilities in accordance with applicable standards governing vehicular access. The proposed project driveways would meet the minimum sight distance requirements specified in the Highway Design Manual (HDM). With one exception, truck turning movements at studied intersections are feasible. This movement would be feasible with the installation of improvements proposed as part of the project. Therefore, the proposed project would not substantially increase hazards due to a geometric design feature (e.g., sharp curves, dangerous intersections, tight turning radii from streets, limited roadway visibility, short merging lanes, uneven road grades, or any other conditions determined by the City traffic engineer to be a hazard) or incompatible uses (e.g., farm equipment). Impacts would be less than significant, and no mitigation is required. (DEIR 4.17.13 to 4.17-15)

47. Threshold 4.17.4: The proposed project would not result in inadequate emergency access.

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Impact: The proposed project would not result in inadequate emergency access.

Impacts would be less than significant. (DEIR at 4.17-15 to 4.17-16) a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.17-15 to 4.17-16) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.17-15 to 4.17-16)
d. Supporting Explanation: The proposed project would require temporary lane closures to complete the proposed intersection improvements and may require temporary lane closures on Enterprise Way for the completion of utility connections. However, the proposed project would be required to comply with the California Manual on Uniform Traffic Control Devices (CA MUTCD), which provides uniform standards and specifications for all official traffic control devices in California. Compliance with standards included in the CA MUTCD would ensure that any temporary lane closures that may result from the proposed project would not result in inadequate emergency access at the project site or in the project vicinity. During operation, entrances and exits to and from parking and loading facilities would be marked with appropriate directional signage. All site access points and driveway aprons would be designed and constructed to adequate widths for public safety pursuant to the OCFA. Site design and compliance with standard and emergency OCFA and City requirements, such as the size and location of fire access routes and fire truck turning radii, would allow for proper site evacuation, if necessary, during project operations. Therefore, the proposed project would not result in inadequate emergency access during project operation. Impacts would be less than significant, and no mitigation is required. (DEIR 4.17-15 to 4.17-16) Tribal Cultural Resources:

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significant. All development projects within the cumulative study area would be required to consult with the appropriate tribes and identify proper mitigation to address any potentially significant impacts to tribal cultural resources. As all projects within the cumulative study area would be required to implement appropriate regulatory compliance measures and mitigation measures to avoid or mitigate impacts to tribal cultural resources, when considered with other projects in the City, development of the proposed project would not contribute a significant cumulative impact related to tribal cultural resources. Cumulative impacts to tribal cultural resources would be less than significant and no mitigation is required. (DEIR 4.18-11) Utilities and Service Systems:

49. Threshold 4.19.1: The proposed project would not result in the relocation or construction of new or expanded water, wastewater treatment, or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects.

Impact: The proposed project would not result in significant environmental effects related to the relocation or construction of new or expanded water, wastewater treatment, or storm water drainage, electric power, natural gas, or telecommunications facilities with compliance with applicable regulatory requirements. Impacts would be less than significant. (DEIR at 4.19-12 to 4.19-16)
a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: RCM WQ-3 and RCM WQ-4 relative to stormwater drainage facilities would be applicable to this topical area. (DEIR at

4.19-12 to 4.19-16)
c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.19-12 to 4.19-16)
d. Supporting Explanation: Irvine Ranch Water District (IRWD) is able to meet the projected water demands of existing and planned uses within its service area through 2040 under normal year, single dry-year condition, and over five years of consecutive drought. The potable water demand associated with the proposed project would represent less than one percent of the surplus water supply in the IRWD’s service area in 2025 through 2040 under the worst-case scenario. The proposed project would not necessitate new or expanded water facilities and the IRWD would be able to accommodate the increased demand for potable water.

Therefore, impacts related to water demand are less than significant, and no mitigation is required. (DEIR at 4.19-13)
All connections to the existing wastewater lines would be reviewed and approved by the City’s Public Works Department and IRWD, as applicable. IRWD maintains sufficient treatment capacity to serve the proposed project in addition to its existing commitments. Therefore, the proposed project would not require, nor would it result in, the construction of new wastewater treatment or collection facilities or the expansion of existing facilities other than those facilities to be constructed on site.

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Therefore, impacts related to wastewater treatment are less than significant, and no mitigation is required. (DEIR at 4.19-14)
The proposed project would include three modular wetland systems and three underground detention chambers to reduce site discharge during the 100-year, 24- hour peak runoff rate by 40 percent. The proposed drainage facilities would be designed in compliance with the North Orange County MS4 Permit as detailed in RCM WQ-3 and RCM WQ-4. Therefore, peak discharge would not adversely affect the capacity of downstream networks, and construction or expansion of stormwater drainage facilities would not be required. Impacts related to stormwater drainage would be less than significant, and no mitigation is required. (DEIR at 4.19-14 to

4.19-15)
The increased electricity demand associated with the proposed project would be less than 0.01 percent of SCE’s total electricity demand and operation of the proposed project would increase the annual electricity consumption in Orange County by less than 0.01 percent. Sufficient planned electricity supplies in the SCE service area for estimated net increases in energy demands through 2030. Because the proposed project would only represent a small fraction of electricity demand in SCE’s service area, the project would meet Title 24 requirements, and there would be sufficient electricity supplies available, energy demand for the proposed project would be less than significant, and no mitigation is required. (DEIR at 4.19-15 to 4.19-16) The construction and expansion of telecommunication facilities would occur on site during the site preparation and earthwork phases. The physical impacts of telecommunication facilities within the project site have been considered in each of the topical sections in the EIR; therefore, no significant impacts relative to the relocation or construction of new or expanded telecommunication facilities would result from project development. Impacts would be less than significant, and no mitigation is required. (DEIR at 4.19-16)

50. Threshold 4.19.2: The proposed project would have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years.

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associated with the proposed project would only represent less than one percent of the surplus water supply in the IRWD’s service area in 2025 through 2040 under the worst-case scenario, the proposed project would not necessitate new or expanded water facilities, and the IRWD would be able to accommodate the increased demand for potable water. Therefore, impacts would be less than significant, and no mitigation is required. (DEIR at 4.19-16 to 4.19-17)

51. Threshold 4.19.3: The proposed project would result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments.

Impact: The proposed project would result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments. Impacts would be less than significant. (DEIR at 4.19-17) a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.19-17)
c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.19-17)
d. Supporting Explanation: IRWD maintains sufficient treatment capacity to serve the proposed project in addition to its existing commitments; therefore, impacts relative to the provision of sufficient wastewater treatment capacity are less than significant, and no mitigation is required. (DEIR 4.19-16-17)

52. Threshold 4.19.4: The proposed project would not generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals.

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d. Supporting Explanation: Construction activities occurring on the project site would generate solid waste; however, the proposed project would be required to comply with the CALGreen Code, which requires that at least 65 percent of non-hazardous construction and demolition waste from non-residential construction operations be recycled and/or salvaged for reuse. Solid waste generated by construction activities associated with the proposed project would not cause the capacity at the Frank R.

Bowerman Landfill to be exceeded. The proposed project is estimated to generate approximately 156 tons per year or 855 pounds of solid waste per day during operation. The increase in solid waste generated by the proposed project would constitute approximately 0.01 percent of the average daily capacity (3,000 tons per day) at the receiving landfill and would not exceed its daily capacity. As the proposed project would not generate solid waste in excess of State or local standards, or otherwise impair the attainment impacts of solid waste reduction goals, impacts would be less than significant, and no mitigation is required. (DEIR at 4.19-17 to

4.19-18)

53. Threshold 4.19.5: The proposed project would comply with federal, State, and local management and reduction statutes and regulations related to solid waste.

Impact: The proposed project would comply with federal, State, and local management and reduction statutes and regulations related to solid waste. Impacts would be less than significant. (DEIR at 4.19-18 to 4.19-19)
a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.19-18 to 4.19-19) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.19-18 to 4.19-19)
d. Supporting Explanation: The proposed project would participate in citywide recycling programs in accordance with SB 1016 to reduce demands for landfill space. Per the requirements of the CALGreen Code, a minimum of 65 percent of debris would be diverted to a material recycling facility during construction, thus reducing the input of solid waste to the receiving landfills. During project operation, the proposed project would participate in industrial recycling programs for paper, cardboard, and plastics as encouraged by Action RR-6c of the City’s General Plan. Compliance with federal, State, and local statutes and regulations related to solid waste, would ensure that impacts associated with regulations related to solid waste would be less than significant, and no mitigation is required. (DEIR at 4.19-18 to 4.19-19)

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b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.19-19)
c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.19-19)
d. Supporting Explanation: The proposed project would have a less than significant impact on utilities and service systems. The majority of the cumulative projects identified in the DEIR are consistent with applicable General Plan land use designations and zoning designations and therefore have been considered in the projections used to determine appropriate sizing for utilities and service systems.

Therefore, similar to the proposed project, projects within the cumulative study area that are consistent with site zoning and applicable land use designations would be accommodated by existing utilities and service systems and would not require new or expanded services. Therefore, when considered with other projects in the City, development of the proposed project would not contribute a significant cumulative impact related to utilities or service systems. Cumulative impacts related to utilities and service systems would be less than significant and no mitigation is required. (DEIR at 4.19-19)
Wildfire:

55. Threshold 4.20.1: The proposed project would not impair an adopted emergency response plan or emergency evacuation plan.

Impact: The proposed project would not impair an adopted emergency response plan or emergency evacuation plan. Impacts would be less than significant. (DEIR at 4.20-8 to

4.2-10)
a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.20-8 to 4.2-10) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.20-8 to 4.2-10)
d. Supporting Explanation: In the event an evacuation of all or part of the City during construction of the proposed project, the City would implement procedures contained in the Emergency Operations Plan (EOP) to notify residents and business owners of evacuation orders in affected areas and law enforcement would identify the appropriate routes and assist construction personnel and residents leaving the City in accordance with the City’s recently adopted Local Hazard Mitigation Plan (LHMP).

The proposed project is not anticipated to result in any substantial traffic queuing along Enterprise Way or Dimension Drive, or on the project site during project operation. Therefore, operation of the project would not significantly impair the evacuation of surrounding areas in the event of an emergency. Because the proposed project does not include any emergency facilities, does not serve as an emergency evacuation route, and construction and operational activities would not impact the use of roadways near the project site, the proposed project would not Item: 9
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physically impair or otherwise interfere with emergency response or evacuation in the project vicinity. Therefore, the development of the proposed project would have a less than significant impact associated with impairments to an adopted emergency response plan or emergency evacuation plan and no mitigation is required. (DEIR at 4.20-8 to 4.20-10)

56. Threshold 4.20.2: The proposed project would not exacerbate wildfire risks and therefore expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire due to slope, prevailing winds, and other factors.

Impact: The proposed project would not exacerbate wildfire risks and therefore expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire due to slope, prevailing winds, and other factors. Impacts would be less than significant. (DEIR at 4.20-10 to 4.20-11)
a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures would be applicable to this topical area. (DEIR at 4.20-10 to 4.20-11) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.20-10 to 4.20-11)
d. Supporting Explanation: The proposed project would adhere to applicable building and fire codes, which would reduce the wildfire risk at the project site. The project site is relatively flat with a gentle 3 percent slope downward from east to west. The eastern and southern property boundaries are at a lower elevation than the adjacent properties, which results in a 10- to 15-foot increase in elevation at the property boundary. This minor elevation change across a short distance does not constitute a slope for the purposes of assessing wildfire risks. The project site is not located within a very high fire hazard severity zone (VHFHSZ). Adjacent roadways that surround the project site, including Bake Parkway, Enterprise Way, and Lake Forest Drive, would serve as fire breaks in the unlikely event of the uncontrolled spread of a wildfire; therefore, there is a low likelihood that wildfires would spread to the project site. While the City has experienced wildfires, due to slope, prevailing winds, location, and other factors, the proposed project would not exacerbate wildfire risks.

The likelihood of wildfires affecting the project site or immediate project vicinity is minimal; therefore, impacts would be less than significant, and no mitigation is required. (DEIR at 4.20-10 to 4.20-11)

57. Threshold 4.20.3: The proposed project would not require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment.

Impact: The proposed project would not require the installation or maintenance of associated infrastructure that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment. Impacts would be less than significant. (DEIR at

4.20-11)
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In the absence of any significant potential for on-site or adjacent wildfire hazard, the proposed project would not need to incorporate fire protection infrastructure (such as roads, fuel breaks, emergency water sources, power lines, or other non-existing utilities) that may themselves exacerbate fire risk. The proposed project does not include any changes to public or private roadways that would exacerbate fire risk or that would result in impacts to the environment. Although utilities, including water facilities, sewer facilities, storm drain lines, and power lines would be modified and/or extended throughout the project site, these improvements would be underground and would not exacerbate fire risk. Impacts would be less than significant, and no mitigation is required. (DEIR at 4.20-11)

58. Threshold 4.20.4: The proposed project would not expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff post-fire slope instability, or drainage changes.

Impact: The proposed project would not expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff post-fire slope instability, or drainage changes. Impacts would be less than significant. (DEIR at

4.20-11 to 4.20-12)
a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.20-11 to 4.20-12) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.20-11 to 4.20-12)
d. Supporting Explanation: There is no evidence of landslides in the project vicinity, nor is the project site located within a designated Landslide Hazard Zone. The project site is not located in a VHFHSZ. These two factors, combined, indicate that in the unlikely event that a wildfire should spread to the project site, it would not expose any on-site slopes to erosion and potential failure. The project site is located within Zone X, designated as an area of minimal flood risk, the areas between the limits of the base flood and the 0.2 percent annual chance flood or 500-year flood. Due to the lack of on-site steep slopes that are prone to landslide or erosion, and the presence of the proposed project’s drainage improvements, it is not expected the site would contribute any additional runoff or sedimentation to Serrano Creek or other Item: 9
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downstream drainages. Impacts relative to downslope or downstream flooding as a result of runoff, post-fire slope instability, or drainage changes related to post-wildfire flooding risks would be less than significant, and no mitigation is required. (DEIR at 4.20-11 to 4.20-12)

59. Cumulative Impact: Project development, together with cumulative projects, would not result in significant impacts related to wildfire in the project area. (DEIR at 4.20-12 to

4.20-13)
a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.20-12 to 4.20-13) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.20-12 to 4.20-13)
d. Supporting Explanation: Consistent with the proposed project, all discretionary private development and public works projects within the cumulative study area would be required to comply with CEQA. In this way, potential impacts related to wildfire would be evaluated and mitigated by each individual project. Cumulative development would further be required to adhere to City, County, State, and federal regulations designed to reduce and/or avoid impacts related to wildfire including flooding hazards and landslides after a wildfire event. Since all projects within the cumulative study area would be required to implement appropriate mitigation measures and adhere to applicable regulations, when considered with other projects in the City, development of the proposed project would not contribute a significant cumulative impact related to wildfire. Cumulative impacts related to wildfire would be less than significant and no mitigation is required. (DEIR at 4.20-12 to 4.20-13) SECTION IV: FINDINGS REGARDING POTENTIALLY SIGNIFICANT

ENVIRONMENTAL EFFECTS THAT CAN BE MITIGATED TO LESS THAN

SIGNIFICANT LEVELS WITH ADOPTION OF MITIGATION MEASURES The FEIR identified certain potentially significant effects that could result from implementation of the proposed project. The City Council hereby finds that the following potential environmental impacts of the project are less than significant based on the implementation of project-specific mitigation measures.

Air Quality:

60. Threshold 4.3.2: The proposed project would not result in a cumulatively considerable net increase of criteria pollutants which the project region is in non-attainment under an applicable federal or State air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors) where the incremental effect of the project emissions, considered together with past, present, and reasonably anticipated further project emissions, increase the level of any criteria pollutant above the existing ambient level. Additionally, the proposed project would not violate any air quality standard or contribute substantially to an existing or projected air quality violation (the Item: 9
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SCAQMD construction and operational emission thresholds are used for this assessment).

Impact: Prior to mitigation, the proposed project would generate a cumulatively considerable net increase of criteria pollutants which the project region is in nonattainment under an applicable federal or State air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors) where the incremental effect of the project emissions, considered together with past, present, and reasonably anticipated further project emissions, increase the level of a criteria pollutant above the existing ambient level. In addition, prior to mitigation, the proposed project would violate air quality standards and/or contribute substantially to an existing or projected air quality violation (the SCAQMD construction and operational emission thresholds are used for this assessment). Impacts would be potentially significant prior to mitigation. Changes (i.e., mitigation) have been required of the proposed project to reduce impacts to less than significant levels. (DEIR at 4.3-24 to 4.3-30) a. Finding: Changes (i.e., mitigation) have been required of the proposed project which substantially lessens the significant environmental effect to a level that is less than significant as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.3-24 to 4.3-30) c. Applicable Mitigation Measures: The following mitigation measure is taken directly from the DEIR. The mitigation measure listed below applies to and will be implemented for the proposed project to mitigate impacts related to net increases in criteria pollutants. (DEIR at 4.3-24 to 4.3-30, and 4.3-50) MM AQ-1 Tier 4 Interim Construction Equipment. Prior to issuance of a building permit, the project Applicant shall submit construction plans to the City of Lake Forest verifying that all construction equipment used during construction of the project shall be equipped with Tier 4 Interim engines or the most effective Verified Diesel Emission Control Strategies (VDECS) available for the engine type (Tier 4 engines automatically meet this requirement) as certified by the California Air Resources Board (CARB).1 During construction activities, the equipment shall be properly maintained and tuned in accordance with manufacturer specifications.
d. Supporting Explanation: The emissions associated with operation of the proposed project would not exceed the significance criteria for volatile organic compounds (VOCs), nitrogen oxide (NOX), carbon monoxide (CO), sulfur oxide (SOX), particulate matter less than 10 microns in size (PM10), or particulate matter less than 2.5 microns in size (PM2.5) emissions; thus, the proposed project would not have a significant effect on regional air quality. (DEIR Table I, at 4.3-27) However, maximum daily NOx emissions during the overlapping of grading and building construction phases would exceed the daily significance criteria established by the SCAQMD. Therefore, the proposed project would result in a potentially 1 California Air Resources Board (CARB). 2015. Verified Diesel Emission Control Strategy (VDECS).

Website: https://ww2.arb.ca.gov/sites/default/files/classic/msprog/ordiesel/faq/vdecsfaq.pdf (accessed June 2025).

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significant impact for criteria pollutants during construction. VOCs, CO, SOX, PM2.5, and PM10 emissions during construction would be below established SCAQMD significance thresholds. (DEIR Table 4.3.I, at 4.3-27) Implementation of Mitigation Measure (MM) AQ-1, would require use of Tier 4 Interim engines or the most effective Verified Diesel Emission Control Strategies (VDECS) available for the engine type (Tier 4 engines automatically meet this requirement) as certified by the California Air Resources Board (CARB). With implementation of MM AQ-1, construction-related impacts resulting from development of the proposed project would be reduced to a less than significant level. (DEIR at 4.3-24 to 4.3-30)

61. Threshold 4.3.3: The proposed project would not expose sensitive receptors to substantial pollution concentrations.

Impact: Prior to mitigation, the proposed project could expose sensitive receptors to substantial pollution concentrations. Impacts would be potentially significant prior to mitigation. Changes (i.e., mitigation) have been required of the proposed project to reduce impacts to less than significant levels. (DEIR at 4.3-30 to 4.3-38) a. Finding: Changes (i.e., mitigation) have been required of the proposed project which substantially lessens the significant environmental effect to a level that is less than significant as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.3-30 to 4.3-38) c. Applicable Mitigation Measures: The following mitigation measure is taken directly from the DEIR. The mitigation measure listed below applies to and will be implemented for the proposed project to mitigate impacts related to exposing sensitive receptors to substantial pollution concentrations. (DEIR at 4.3-30 to 4.3-38, and 4.3-50)
MM AQ-1 Tier 4 Interim Construction Equipment. Prior to issuance of a building permit, the project Applicant shall submit construction plans to the City of Lake Forest verifying that all construction equipment used during construction of the project shall be equipped with Tier 4 Interim engines or the most effective Verified Diesel Emission Control Strategies (VDECS) available for the engine type (Tier 4 engines automatically meet this requirement) as certified by the California Air Resources Board (CARB).3 During construction activities, the equipment shall be properly maintained and tuned in accordance with manufacturer specifications.
d. Supporting Explanation: Construction and operation of the proposed project would not exceed the localized significance threshold (LST) thresholds for the closest receptor (DEIR Tables 4.3.O and 4.3.P, at 4.3-36 and 4.3-37); therefore, no locally significant air quality impact would occur. During project construction, the maximum cancer risk for the residential maximally exposed individual (MEI) would be 41.14 in 1 million, which would exceed the SCAQMD cancer risk threshold of 10 in 1 million.

The worker MEI would be 0.70 in 1 million, which would not exceed the SCAQMD 3 CARB. 2015. Verified Diesel Emission Control Strategy (VDECS). Website: https://ww2.arb.ca.gov/sites/ default/files/classic/msprog/ordiesel/faq/vdecsfaq.pdf (accessed June 2025).

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cancer risk threshold of 10 in 1 million. The total chronic Hazard Index (HI) would be 0.054 for the residential MEI and for the worker MEI, which is below the threshold of 1.0. In addition, the total acute HI would be nominal (0.000), which would also not exceed the threshold of 1.0.

Because the residential MEI would exceed the SCAQMD cancer risk threshold, mitigation to reduce the level of toxic air contaminants would be required. Implementation of MM AQ-1, would require use of Tier 4 Interim engines or the most VDECS available for the engine type (Tier 4 engines automatically meet this requirement) as certified by the CARB would reduce construction PM10 emissions by resulting in fewer emissions during the construction process.

Implementation of MM AQ-1 would reduce the construction-related health risk impact to below SCAQMD significant threshold. (DEIR Table 4.3.M, at 4.3-34) During project operation, cancer risks for the residential and worker MEI would not exceed the SCAQMD cancer risk threshold of 10 in 1 million. The total chronic and acute inhalation health index would be less than 0.001 for both residents and workers; therefore, all health risk levels to nearby receptors from operation-related emissions of toxic air contaminants would be below the SCAQMD’s health risk thresholds. (DEIR Table 4.3.N at 4.3-35)

62. Cumulative Impact: Prior to mitigation, project development, together with cumulative projects, could result in significant impacts related to air quality in the project area.

Changes (i.e., mitigation) have been required of the proposed project to reduce impacts to less than significant levels. (DEIR at 4.3-39 to 4.3-50) a. Finding: Changes (i.e., mitigation) have been required of the proposed project which substantially lessens the significant environmental effect to a level that is less than significant as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.3-39 to 4.3-50) c. Applicable Mitigation Measures: The following mitigation measures are taken directly from the DEIR. The mitigation measures listed below, as well as MM AQ-1 discussed above, apply to and will be implemented for the proposed project to mitigate cumulative air quality and health risk impacts to below a level of significance. (DEIR at 4.3-39 to 4.3-51)
MM AQ-2 Volatile Organic Compounds. Prior to issuance of a grading permit, the project Applicant shall submit construction plans to the City of Lake Forest that state that the project shall utilize “Super-Compliant” low volatile organic compounds (VOC) paints for nonresidential interior and exterior surfaces and low VOC paint for parking lot surfaces. Super-Compliant low VOC paints have been reformulated to exceed the regulatory VOC limits put forth by SCAQMD Rule 1113.

Super-Compliant low VOC paints shall be no more than 10 grams per liter (g/L) of VOC.

MM AQ-3 Tier 4 Final Construction Equipment. Prior to issuance of a building permit, the project Applicant shall consult with the City on the status of Western Realco Projects 1 and 2. If in this consultation, the City identifies that the construction schedule of Western Realco Projects 1 and 2, and the IPT Enterprise Business Center LLC Project Item: 9
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(proposed project) will be under construction at the same time, the proposed project shall equip all construction equipment during the overlapping period with Tier 4 Final engines or the most effective Verified Diesel Emission Control Strategies (VDECS) available for the engine type (Tier 4 engines automatically meet this requirement) as certified by the California Air Resources Board. The equipment shall be properly maintained and tuned in accordance with manufacturer specifications. The project Applicant shall submit construction plans to the City of Lake Forest denoting the projected equipment Tier rating that will be used during the construction period.
d. Supporting Explanation: Cumulative long-term operational emissions would not exceed the project-level significance criteria for daily VOCs, NOx, PM10 or PM2.5 emissions (DEIR Table 4.3.S, at 4.3-45); therefore, cumulative operational emissions would not result in a cumulatively considerable net increase of criteria pollutant for which the project region is nonattainment under an applicable federal or State ambient air quality standards. The maximum cumulative cancer risk and chronic health index for the residential or worker MEI and chronic health index would not exceed established thresholds. The total chronic hazard index would be 0.002 for the residential MEI and 0.007 for the worker MEI, which is below the threshold of 1.0. In addition, the total acute hazard index would be less than 0.001, which would also not exceed the threshold of 1.0 (DEIR Table 4.3.V, at 4.3-49); therefore, no cumulative operational health risk impact would occur.

However, cumulative construction-related emissions would exceed the significance criteria for NOx and VOC. (DEIR Table 4.3.Q, at 4.3-41) Therefore, the proposed project is required to implement MM AQ-2, which requires the use of “SuperCompliant” low VOC paints for nonresidential interior and exterior surfaces and low VOC paint for parking lot surfaces to reduce VOC emissions and ensure that construction emissions are below thresholds. Conservatively, the cumulative analysis assessed the concurrent construction of the proposed project and Western Realco Projects 1 and 2. In the event that the construction phases of the proposed project and Western Realco Projects 1 and 2 overlap, the proposed project would be required to implement MM AQ-3 which would require the use of Tier 4 Final engines to further reduce the cumulative NOx emissions to the extent feasible. (DEIR Table

4.3.R, at 4.3-43) With the implementation of MM AQ-2 and MM AQ-3, cumulative construction emissions would not result in a cumulative considerable net increase of any criteria pollutant under a federal or State ambient air quality standard. (DEIR at

4.3-43 to 4.3-44)
The cumulative construction health risk assessment determined that the Western Realco Projects 1 and 2 in tandem with the proposed project would exceed the SCAQMD cumulative cancer risk threshold of 10 in 1 million during construction (DEIR Table 4.3.T, at 4.3-47). Therefore, these cumulative projects would be required to implement mitigation requiring all construction equipment be equipped with Tier 4 Final engines or the most effective VDECS available for the engine type as certified by the CARB (MM AQ-1) to reduce cumulative cancer risk to below established significance levels. (DEIR Table 4.3.U, at 4.3-48) Item: 9
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Geology and Soils:

63. Threshold 4.7.1(ii): The proposed project would not, directly or indirectly, cause potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking result in a potentially significant environmental impact.

Impact: Prior to mitigation, construction of the proposed project could directly and/or indirectly cause substantial adverse effects resulting from strong seismic ground shaking. Impacts would be potentially significant prior to mitigation. Changes (i.e., mitigation) have been required of the proposed project to reduce impacts to less than significant levels. (DEIR at 4.7-12 to 4.7-13)
a. Finding: Changes (i.e., mitigation) have been required of the proposed project which substantially lessens the significant environmental effect to a level that is less than significant as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.7-12 to 4.7-13) c. Applicable Mitigation Measures: The following mitigation measure is taken directly from the DEIR. The mitigation measure listed below applies to and will be implemented for the proposed project to mitigate impacts related to seismic ground shaking. (DEIR at 4.7-12 to 4.7-13, and 4.7-19)
MM GEO-1 Compliance with Applicable California Building Code and ProjectSpecific Geotechnical Specifications. Prior to the final grading permit and the issuance of building permits, the project Applicant shall provide final project plans to applicable City of Lake Forest (City) staff for review and approval showing that the project, including site preparation and construction of proposed buildings, has been designed and will be constructed in conformance with applicable provisions of the most current California Building Code at the time of City review, the City’s Building Code, and the specifications cited in the Geotechnical Investigation, prepared by Southern California Geotechnical, dated November 2021.

During grading, an on-site inspection shall be conducted by the Applicant-hired Project Geotechnical Consultant and the City of Lake Forest Director of Public Works/City Engineer, or designee, to ensure compliance with geotechnical specifications as incorporated into project plans.

Prior to the final grading permit, the Project Geotechnical Consultant shall submit a Final Testing and Observation Geotechnical Report for Rough Grading to the City of Lake Forest Director of Public Works/City Engineer, or designee.

Prior to the issuance of a Certificate of Occupancy for the new building, the Project Geotechnical Consultant shall provide a letter regarding contractor compliance with project plans and required geotechnical. The letter shall be submitted to the City of Lake Forest Building Division for review and approval.

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d. Supporting Explanation: The City requires projects to comply with applicable provisions of the California Building Code (CBC) (Title 24 CCR) and the City’s Municipal Code (Sections 8.02.001 and 8.02.020), which provide for stringent construction requirements on projects in areas of high seismic risk based on numerous interrelated factors. It is acknowledged that seismic hazards cannot be completely eliminated, even with implementation of advanced building practices.

However, the seismic design standards of the CBC are intended to prevent catastrophic structural failure in the most severe earthquakes currently anticipated.

Ground shaking generated by fault movement is considered a potentially significant impact that may affect the proposed project. Mitigation Measure (MM) GEO-1 requires that the project Applicant comply with the recommendations of the Geotechnical Investigation, the most current CBC, and the City Building Code, which stipulates appropriate seismic design provisions that shall be implemented with project design and construction. The Geotechnical Investigation recommends the use of conventional shallow foundations, supported in newly placed compacted fill with a maximum allowable soil bearing pressure of 3,000 pounds per square foot and reinforcement consisting of at least four number five rebars (two top and two bottom) in strip footings. Additionally, the Geotechnical Investigation recommends conventional slab-on-grade building floor supported on newly placed structural fill or densified existing soils, extending to a depth of at least three feet below finished pad grades, with a minimum thickness of 6 inches, and modulus of subgrade reaction kvalue of 150 pounds per square inch (psi). With the implementation of seismic design provisions recommended in the Geotechnical Investigation and in required building codes as specified in MM GEO-1, potential project impacts related to seismic ground shaking would be reduced to less than significant with mitigation incorporated. (DEIR at 4.7-12 to 4.7-13)

64. Threshold 4.7.3: The proposed project would not be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse.

Impact: The proposed project would not be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse.

However, impacts related to corrosive soils would be potentially significant prior to mitigation. Changes (i.e., mitigation) have been required of the proposed project to reduce impacts to less than significant levels. (DEIR at 4.7-14 to 4.7-15) a. Finding: Changes (i.e., mitigation) have been required of the proposed project which substantially lessens the significant environmental effect to a level that is less than significant as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.7-14 to 4.7-15) c. Applicable Mitigation Measures: The following mitigation measure is taken directly from the DEIR. The mitigation measure listed below applies to and will be implemented for the proposed project to mitigate impacts related to corrosive soils. (DEIR at 4.7-14 to 4.7-15, and 4-7-19 to 4.7-20)
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MM GEO-2 Corrosive Soils. Prior to issuance of building permits, the project Applicant/Developer shall retain the services of a licensed corrosion engineer to conduct additional site testing and final design evaluation regarding the possible on-site presence of significant volumes of corrosive soils. At a minimum, the corrosion engineer shall (1) verify the soluble sulfate concentrations of the soils that are present at pad grade within the building areas at the completion of rough grading; (2) provide detailed corrosion protection measures for cast iron and/or ductile iron pipes, as necessary; (3) confirm that soluble sulfates and chloride levels in the on-site soils do not warrant specialized concrete mix design; and (4) confirm that nitrates present in the on-site soil do not warrant protection for copper materials.

During grading, on-site inspection shall be conducted by the Project Geotechnical Consultant and City of Lake Forest Director of Public Works/City Engineer, or designee, to ensure compliance with the corrosion protection measures of the corrosion engineer, as incorporated into the project plans.

Prior to issuance of a building permit, the Director of the City of Lake Forest Public Works Department, or designee, shall verify that the project plans incorporate the corrosion protection measures of the corrosion engineer.
d. Supporting Explanation: Liquefaction is not considered to be a design concern for the proposed project due to the depth to groundwater. Due to the low potential for liquefaction and lack of nearby open face areas, the project site possesses a low potential for lateral spreading. Therefore, there would be no impacts associated with lateral spreading and liquefaction, and no mitigation is required. (DEIR at 4.7-14) Minor ground subsidence is expected to occur at the project site due to settlement and machinery working. Implementation of the proposed project is anticipated to cause subsidence of up to 0.1 feet, which is considered acceptable for grading in areas that are underlain by existing engineered fill soils. According to the Geotechnical Investigation, soils on-site were determined to have relatively high strengths and favorable consolidation and collapse characteristics; therefore, impacts associated with subsidence and collapse would be less than significant. (DEIR 4.7-15)
According to the Geotechnical Investigation completed for the proposed project, onsite soils are not corrosive to concrete or copper pipe but are moderately corrosive to ductile iron pipe. MM GEO-2 requires protection of ferrous metals against corrosion.

Corrosion protection may include, but is not limited to, sacrificial metal, the use of protective coatings like polyethylene protection, and/or cathodic protection and further requires a licensed corrosion engineer conduct additional site testing for presence of significant volumes of corrosive soils following demolition of the existing building on site and verify the soluble sulfate concentrations of the soils present at pad grade within the building areas at the completion of rough grading. With implementation of MM GEO-2, potential impacts related to corrosive soils would be reduced to a less than significant level. (DEIR at 4.7-15) Item: 9
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65. Threshold 4.7.6: The proposed project would not directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.

Impact: The proposed project would not directly or indirectly destroy a known unique paleontological resource or site or unique geologic feature. However, construction of the proposed project could impact previously undiscovered paleontological resources.

Impacts would be potentially significant prior to mitigation. Changes (i.e., mitigation) have been required of the proposed project to reduce impacts to less than significant levels. (DEIR 4.7-16)
a. Finding: Changes have been required of the proposed project which substantially lessens the significant environmental effect to a level that is less than significant as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.7-16)
c. Applicable Mitigation Measures: The following mitigation measure is taken directly from the DEIR. The mitigation measure listed below applies to and will be implemented for the proposed project to mitigate impacts related to paleontological resources. (DEIR at 4.7-16, and 4-7-20 to 4.7-21).

MM GEO-3 Paleontological Resources Impact Mitigation Program. Prior to the final grading permit and the issuance of building permits, the project Applicant/Developer shall provide a letter to the Director of Community Development Department, or designee, stating that they have retained a qualified paleontologist (defined as a practicing paleontologist who is recognized in the paleontological community and proficient in vertebrate paleontology) who is listed on the County of Orange list of certified paleontologists.

Prior to the final grading permit and the issuance of building permits, the qualified paleontologist shall submit to the City, a Paleontological Resources Impact Mitigation Program (PRIMP) for this project. The PRIMP shall include the methods that will be used to protect paleontological resources that may exist within the project site, as well as procedures for monitoring, fossil preparation and identification, curation into a repository, and preparation of a report at the conclusion of grading. The PRIMP shall be consistent with the guidelines of the Society of Vertebrate Paleontology. The City shall not issue a grading permit for the project until the letter and PRIMP, both referenced above, have been received.

During construction, excavation and grading activities in deposits with high paleontological sensitivity shall be monitored by a paleontological monitor as defined by the PRIMP. No monitoring is required for excavations in deposits with no or low paleontological sensitivity (i.e., engineered fill soils).

If paleontological resources are encountered during the course of ground disturbance, the paleontological monitor shall have the authority to temporarily redirect construction away from the area of the find in Item: 9
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order to assess its significance. In the event that paleontological resources are encountered when a paleontological monitor is not present, work in the immediate area of the find shall be redirected, and a paleontologist shall be contacted to assess the find for significance.

Collected resources shall be prepared to the point of identification, identified to the lowest taxonomic level possible, cataloged, and curated into the permanent collections of a scientific institution prepared by the Applicant-hired qualified paleontologist.

Prior to the issuance of building permits, a report of findings shall be prepared to document the results of the monitoring program prepared by the Applicant-hired qualified paleontologist. The report shall be provided to the Director of Community Development, or designee. d. Supporting Explanation: According to the Geotechnical Investigation completed for the proposed project, the project site is underlain by engineered fill soils and Capistrano Formation sandstone bedrock. The soils of the Capistrano Formation have produced scientifically important paleontological resources and are considered to be sensitive for paleontological resources. The proposed project would require a maximum depth of excavation of 6 feet. While engineered fill soils were encountered extending to depths of 12 feet to more than 30 feet, the depth at which Capistrano Formation soils were encountered was not uniform across the site. Therefore, it is possible that ground-disturbing construction activities could impact significant previously undiscovered paleontological resources. To mitigate adverse impacts to unknown buried paleontological resources that may exist on site, MM GEO-3 would be implemented. With implementation of MM GEO-3, the proposed project would have a less than significant impact related to paleontological resources with mitigation incorporated. (DEIR at 4.7-16)
Tribal Cultural Resources:

66. Threshold 4.18.1(a): The proposed project would not cause a substantial adverse change in the significance of a tribal cultural resource, defined in PRC Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American Tribe, and that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in PRC Section 5020.1(k).

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a. Finding: Changes (i.e., mitigation) have been required of the proposed project which substantially lessens the significant environmental effect to a level that is less than significant as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.18-7 to 4.18-9) c. Applicable Mitigation Measures: The following mitigation measures are taken directly from the DEIR. The mitigation measures listed below apply to and will be implemented for the proposed project to mitigate potential impacts to tribal cultural resources to below a level of significance. (DEIR at 4.18-7 to 4.18-9, and 4.18-12 to

4.18-14)
TCR-1 Retain a Native American Monitor Prior to Commencement of GroundDisturbing Activities.

A. The project applicant/lead agency shall retain a Native American Monitor from or approved by the Gabrieleño Band of Mission Indians – Kizh Nation. The monitor shall be retained prior to the commencement of any “ground-disturbing activity” for the subject project at all project locations (i.e., both on-site and any off-site locations that are included in the project description/definition and/or required in connection with the project, such as public improvement work). “Ground-disturbing activity” shall include, but is not limited to, demolition, pavement removal, potholing, auguring, grubbing, tree removal, boring, grading, excavation, drilling, and trenching.

B. A copy of the executed monitoring agreement shall be submitted to the lead agency prior to the commencement of any ground-disturbing activity, or the issuance of any permit necessary to commence a ground-disturbing activity.

C. The monitor will complete daily monitoring logs that will provide descriptions of the relevant ground-disturbing activities, the type of construction activities performed, locations of ground-disturbing activities, soil types, cultural-related materials, and any other facts, conditions, materials, or discoveries of significance to the Tribe. Monitor logs will identify and describe any discovered TCRs, including but not limited to, Native American cultural and historical artifacts, remains, places of significance, etc., (collectively, tribal cultural resources, or “TCR”), as well as any discovered Native American (ancestral) human remains and burial goods. Copies of monitor logs will be provided to the project applicant/lead agency upon written request to the Tribe.

D. On-site tribal monitoring shall conclude upon the later of the following (1) written confirmation to the Kizh from a designated point of contact for the project applicant/lead agency that all ground-disturbing activities and phases that may involve ground-disturbing activities on the project site or in connection with the project are complete; or (2) prior to approval of final building permit, a determination and written notification by the Kizh to the project applicant/lead agency that no future, planned Item: 9
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construction activity and/or development/ construction phase at the project site possesses the potential to impact Kizh TCRs.

TCR-2 Unanticipated Discovery of Tribal Cultural Resource Objects (NonFuneral/Non-Ceremonial).

A. Upon discovery of any TCRs, all construction activities in the immediate vicinity of the discovery shall cease (i.e., not less than the surrounding 50 feet) and shall not resume until the discovered TCR has been fully assessed by the Kizh monitor and/or Kizh archaeologist. The Kizh will recover and retain all discovered TCRs in the form and/or manner the Tribe deems appropriate, in the Tribe’s sole discretion, and for any purpose the Tribe deems appropriate, including for educational, cultural and/or historic purposes.

TCR-3 Unanticipated Discovery of Human Remains and Associated Funerary or Ceremonial Objects.

A. Native American human remains are defined in Public Resources Code (PRC) 5097.98 (d)(1) as an inhumation or cremation, and in any state of decomposition or skeletal completeness. Funerary objects, called associated grave goods in PRC Section 5097.98, are also to be treated according to this statute.

B. If Native American human remains and/or grave goods are discovered or recognized on the project site, then PRC 5097.9 as well as Health and Safety Code Section 7050.5 shall be followed.

C. Human remains and grave/burial goods shall be treated alike per California PRC Section 5097.98(d)(1) and (2).

D. Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human remains and/or burial goods.

E. Any discovery of human remains/burial goods shall be kept confidential to prevent further disturbance.
d. Supporting Explanation: Native American consultation was conducted by the City in compliance with AB 52. The City provided notice of the proposed project via certified mail to Native American tribal contacts provided by the Native American Heritage Commission (NAHC) as well as local Native American tribal representatives that previously requested to be notified of future projects proposed by the City in compliance with AB 52. The City consulted with the Gabrieleno Band of Mission Indians – Kizh Nation (Kizh Nation). No information regarding specific known tribal cultural resources on the project site was provided to the City and consultation was concluded on May 11, 2025.

The site research conducted at the South Central Coast Information Center (SCCIC) identified one previously recorded cultural resource (a prehistoric lithic scatter) within the project site. However, according to previous studies, the knoll where the cultural resource was identified was systematically excavated in 1988 and removed by subsequent site development/construction excavation 1994. Through site Item: 9
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development, the project site has been subject to over excavation and compaction that has disturbed sediments beyond depths at which encountering buried cultural resources is likely. Therefore, the proposed project would not cause a substantial adverse change in the significance of a tribal cultural resource defined as a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American Tribe, and that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in PRC Section 5020.1(k). Nevertheless, implementation of MM TCR-1 through MM TCR-3, would be implemented to address the potential impacts to unanticipated tribal cultural resources, human remains and associated funerary or ceremonial objects. The implementation of these measures would reduce impacts to tribal cultural resources to a less than significant level. (DEIR 4.18-7 to 4.18-9)

67. Threshold 4.18.1(b): The proposed project would not cause a substantial adverse change in the significance of a tribal cultural resource, defined in PRC Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American Tribe, and that is a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of PRC Section 5024.1.

Impact: The proposed project would not cause a substantial adverse change in the significance of a known tribal cultural resource, defined in PRC Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American Tribe, and that is a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of PRC Section 5024.1. However, construction of the proposed project could impact previously undiscovered tribal cultural resources. Impacts would be potentially significant prior to mitigation. Changes (i.e., mitigation) have been required of the proposed project to reduce impacts to less than significant levels. (DEIR at 4.18-9 to 4.18-10)
a. Finding: Changes (i.e., mitigation) have been required of the proposed project which substantially lessens the significant environmental effect to a level that is less than significant as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.18-9 to 4.18-10) c. Applicable Mitigation Measures: MM TCR-1 through MM TCR-3 discussed above apply to and will be implemented for the proposed project to mitigate potential impacts to tribal cultural resources to below a level of significance. (DEIR at 4.18-9 to

4.18-10, and 4.18-12 to 4.18-13)
d. Supporting Explanation: Native American consultation was conducted by the City in compliance with AB 52. The City provided notice of the proposed project via certified mail to Native American tribal contacts provided by the NAHC as well as local Native American tribal representatives that previously requested to be notified of future projects proposed by the City in compliance with AB 52. The City consulted with the Kizh Nation. No information regarding specific known tribal cultural resources on the Item: 9
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project site was provided to the City and consultation was concluded on May 11, 2025.

The site research conducted at the SCCIC identified one previously recorded cultural resource (a prehistoric lithic scatter) within the project site. According to previous studies, the knoll where the cultural resource was identified was systematically excavated in 1988 and removed by subsequent site development/construction excavation 1994. An archaeological pedestrian field survey of the project site was conducted in May 2021; no cultural resources were discovered within the project site during the field May 2021 survey. The project site has been subject to over excavation and compaction that has disturbed sediments beyond depths at which buried cultural resources are likely. Therefore, encountering unknown buried cultural resources, including tribal cultural resources, during project construction is unlikely.

No human remains are documented/known to be on the project site. Because the project site has been previously disturbed including over excavation and compaction during development of the existing building, the likelihood of discovering unknown human remains during construction of the proposed project is extremely low.

Implementation of MM TCR-1 through MM TCR-3 would ensure the proposed project would not cause a substantial adverse change in the significance of a tribal cultural resource defined as a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe that is determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of PRC Section 5024.1. Impacts would be less than significant. (DEIR 4.18-9 to 4.18-10)
SECTION V: FINDINGS REGARDING SIGNIFICANT ENVIRONMENTAL

EFFECTS THAT CANNOT BE MITIGATED TO A LESS THAN SIGNIFICANT LEVEL
The City Council hereby finds that the following environmental impacts identified in the DEIR are significant and, despite the implementation of all feasible mitigation measures, cannot be mitigated to a less than significant level.

Greenhouse Gas Emissions:

68. Threshold 4.8.2: The proposed project would conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases.

Impact: The proposed project would conflict with the policies or goals of the 2022 Scoping Plan related to vehicle miles traveled (VMT); therefore, the proposed project would conflict with a plan or policy adopted for the purpose of reducing GHG emissions.

Impacts would be significant and unavoidable after implementation of mitigation. (DEIR at 4.8-16 to 4.8-20)
a. Finding: Changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR; though these changes do not reduce the identified impact to below established significance thresholds. (State CEQA Guidelines Section 15091(a)(1).

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b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.8-16 to 4.8-20) c. Applicable Mitigation Measures: The following mitigation measures (MM GHG-1 and MM TRA-2) were revised/added in the FEIR and MM TRA-1 is taken directly from the DEIR. These measures apply to and will be implemented by the proposed project to mitigate impacts related to greenhouse gas emissions. (FEIR at 3-2 to 3-4 and Appendix G at 4.19-20, and DEIR at 4.17-11 to 4.17-12)
MM GHG-1: Electric Vehicle Charging. Provisions shall be made at the project site for emerging electric truck technology. Prior to the issuance of a shell building permit, construction plan set shall:
a) Provide for installation of all necessary infrastructure, including conduit, wiring, and sufficient electrical capacity, to support the future installation of on-site electric truck charging stations; and b) Designate sufficient space to accommodate a minimum of four electric trucks charging simultaneously.

The charging stations shall be installed and operational prior to tenant occupancy of the building.

MM TRA-1 Bike Lanes. Prior to issuance of a certificate of occupancy for the proposed industrial building, the project Applicant shall retain a licensed Civil Engineer by the State of California to prepare Civil Street Improvements and Signing & Striping Plans (collectively Construction Plans) for the implementation of bike lanes in both directions on Commercentre Drive between Alton Parkway and Dimension Drive. These bike lanes on Commercentre Drive would connect the proposed project site on Enterprise Way to the existing bike lanes on Alton Parkway, which eventually connects to the Irvine Transportation Center, a multi-model transit hub including Metrolink and Amtrak commuter train services and OCTA bus services.

The construction of said improvements shall be completed per the plans and to the satisfaction of the Public Works Department. The project Applicant shall use these Construction Plans to obtain a Public Works Encroachment Permit to construct said improvements for bike lanes on Commercentre Drive.

MM TRA-2: Pedestrian-Scale Transit Access Lighting. To reduce vehicle miles traveled (VMT) and improve first-/last-mile access to transit, the Item: 9
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applicant/developer shall install pedestrian-scale lighting along the onsite pedestrian pathway between the primary building entrance and the public right-of-way, leading to the existing bus stops. Lighting shall provide adequate nighttime visibility for pedestrians (generally achieving a maintained average of 1.0 foot-candle), avoid glare, and limit spillover to adjacent properties in accordance with Lake Forest Municipal Code section 9.72.085(3). Fixtures shall include automatic dusk-to-dawn controls.

Prior to issuance of building permits, a lighting plan depicting fixture types, locations, heights, and illumination levels shall be submitted by the Applicant to the City for review and approval.

Prior to issuance of a certificate of occupancy, all required lighting shall be installed and operational and shall be maintained by the property owner for the life of the project.
d. Supporting Explanation: A substantial portion of the project’s total GHG emissions are related to vehicle exhaust emissions. While implementation of MM GHG-1 (as revised in the FEIR) would contribute to (but not satisfy) the project’s “fair share” reduction of GHG emissions and MM TRA-1 and MM TRA-2 would promote alternative transportation with the intent of reducing VMT, the project’s VMT impact would remain significant and unavoidable, and therefore, the proposed project would not be consistent with the 2022 Scoping Plan. Therefore, the proposed project would conflict with the plans and policies adopted for the purpose of reducing the emissions of GHGs, including the 2022 Scoping Plan. There is no other feasible mitigation available to substantially lessen or avoid this significant impact; therefore, impacts remain significant and unavoidable. (DEIR at 4.8-16 to 4.8-20)

69. Cumulative Impact: Project development, together with cumulative projects, would result in significant impacts related to greenhouse gas emissions in the project area.

Impacts would be significant and unavoidable after implementation of mitigation. (DEIR at 4.8-20 to 4.8-21)
a. Finding: Changes or alterations have been required, or incorporated into, the proposed project, which avoid or substantially lessen the significant environmental effect as identified in the FEIR; though these changes do not reduce the identified impact to below established significance thresholds. (State CEQA Guidelines Section 15091(a)(1).
b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.8-20 to 4.8-21) c. Applicable Mitigation Measures: MM GHG-1 as discussed above is applicable to this topical area. (FEIR at 3-2 to 3-3)
d. Supporting Explanation: A substantial portion of the project’s total GHG emissions are related to vehicle exhaust emissions. The proposed project would not satisfy its “fair share” of emission reductions required to support SB 743 and the goals of the 2022 Scoping Plan. The proposed project would conflict with the policies or goals of the 2022 Scoping Plan related to VMT; therefore, the proposed project would conflict with a plan or policy adopted for the purpose of reducing GHG emissions.

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A cumulative threshold based on consistency with State targets and actions to reduce GHGs is an appropriate standard of comparison for project-specific significance determinations. The thresholds developed by the SCAQMD are based on and apply to individual projects. Since climate change is a global issue, it is unlikely that individual projects would generate enough GHG emissions to influence climate change on their own. Consequently, it is speculative to determine how an individual project’s GHG emissions would impact climate change in California. The GHG emissions identified in Section 4.8 of the DEIR are the proposed project’s contribution to the cumulative impact. While implementation of MM GHG-1 (as revised in the FEIR) would contribute to (but not satisfy) the project’s “fair share” reduction of GHG emissions and MM TRA-1 and MM TRA-2 would promote alternative transportation with the intent of reducing VMT, the project’s VMT impact would not be reduced to below the City’s VMT threshold, and therefore, would not be consistent with the 2022 Scoping Plan. Therefore, the proposed project would conflict with the plans and policies adopted for the purpose of reducing the emissions of GHGs, including the 2022 Scoping Plan. There is no other feasible mitigation available to substantially lessen or avoid this cumulatively significant impact; therefore, this cumulative impact remains significant and unavoidable. (DEIR at 4.8- 20 to 4.8-21)
Transportation and Traffic:

70. Threshold 4.17.2: The proposed project would conflict or be inconsistent with State CEQA Guidelines Section 15064.3 subdivision (b). Additionally, the proposed project would not meet any of the screening criteria described in the City of Lake Forest Transportation Analysis Guidelines and would exceed the vehicle miles traveled (VMT) thresholds described in the City of Lake Forest Transportation Analysis Guidelines.

Impact: The proposed project would conflict or be inconsistent with State CEQA Guidelines Section 15064.3 subdivision (b) related to VMT. Additionally, the proposed project would not meet any of the screening criteria described in the City of Lake Forest Transportation Analysis Guidelines and would exceed the vehicle miles traveled (VMT) thresholds described in the City of Lake Forest Transportation Analysis Guidelines.

Impacts would be significant and unavoidable after implementation of mitigation. (DEIR at 4.17-11 to 4.17-12)
a. Finding: Changes or alterations have been required, or incorporated into, the proposed project, which avoid or substantially lessen the significant environmental effect as identified in the FEIR; though these changes do not reduce the identified impact to below established significance thresholds. (State CEQA Guidelines Section 15091(a)(1).)
b. Applicable Regulatory Compliance Measures: The following regulatory compliance measure is applicable to this topical area and was added to the FEIR for clarity. (FEIR 3-4 and Appendix G at 4.17-18 to 4.17-19)
RCM TRA-1: Development Standards Pursuant to Section 9.160.040 of the City’s Municipal Code. The provisions of Zoning Code Chapter

9.160.040 (Facility Design Regulations) shall be implemented as follows:

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• Prior to the issuance of the building permits for the construction of the primary building, the site plan and/or floor plans in the construction drawings shall clearly show the location of the required carpool parking stalls, vanpool parking stalls, ride share vehicle loading area, bicycle parking, shower facilities, locker facilities, and commuter information area, in accordance with the regulations in Zoning Code Section

9.160.040.
• Prior to issuance of building permits for the construction of the primary building, the Applicant shall retain a licensed Civil Engineer by the State of California to prepare Civil Street Improvement Plans for the installation of a bus shelter with solar-powered lights, a bus bench, and a trash receptacle for the existing bus stop located on the northwest corner of the intersection of Dimension Drive at Commercentre
Drive/Enterprise Way, in accordance with the regulations in Zoning Code Section 9.16.040 and Orange County
Transportation Authority Guidelines.

The bus stop improvements shall be designed in accordance to the standards provided in the Orange County Transportation Authority (OCTA) Transit-Supportive Design Guidelines (June 30, 2021 or latest edition). As appropriate, the existing sidewalk shall be widened within the existing right-of-way (ROW) to a minimum eight feet wide to accommodate
wheelchair bus boardings. If that is not feasible due to ROW constraints, then the sidewalk shall be widened to greatest extent practical.

The project Applicant shall submit these Civil Street
Improvement Plans to the City’s Engineering Division and obtain a Public Works Encroachment Permit to construct the improvements to the existing bus stop.
• Prior to issuance of Certificate of Occupancy of the building, all provisions of Chapter 9.160 shall be implemented, as
approved on the construction drawings and civil street
improvement plans, including but not limited to, the required carpool parking stalls, vanpool parking stalls, ride share vehicle loading area, bicycle parking, shower facilities, locker facilities, commuter information area, and improvements to the existing bus stop located on the northwest corner of the intersection of Dimension Drive at Commercentre
Drive/Enterprise Way.
c. Applicable Mitigation Measures: The following mitigation measures apply to and will be implemented for the proposed project to mitigate impacts related to VMT. MM TRA-1 is taken directly from the DEIR and MM TRA-2 has been added to the FEIR. (DEIR at 4.17-11 to 4.17-12, and FEIR 3-4 and Appendix G at 4.19-20) Item: 9
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MM TRA-1 Bike Lanes. Prior to issuance of a certificate of occupancy for the proposed industrial building, the project Applicant shall retain a licensed Civil Engineer by the State of California to prepare Civil Street Improvements and Signing & Striping Plans (collectively Construction Plans) for the implementation of bike lanes in both directions on Commercentre Drive between Alton Parkway and Dimension Drive. These bike lanes on Commercentre Drive would connect the proposed project site on Enterprise Way to the existing bike lanes on Alton Parkway, which eventually connects to the Irvine Transportation Center, a multi-model transit hub including Metrolink and Amtrak commuter train services and OCTA bus services.

MM TRA-2: Pedestrian-Scale Transit Access Lighting. To reduce vehicle miles traveled (VMT) and improve first-/last-mile access to transit, the applicant/developer shall install pedestrian-scale lighting along the onsite pedestrian pathway between the primary building entrance and the public right-of-way, leading to the existing bus stops. Lighting shall provide adequate nighttime visibility for pedestrians (generally achieving a maintained average of 1.0 foot-candle), avoid glare, and limit spillover to adjacent properties in accordance with Lake Forest Municipal Code section 9.72.085(3). Fixtures shall include automatic dusk-to-dawn controls.

Prior to issuance of building permits, a lighting plan depicting fixture types, locations, heights, and illumination levels shall be submitted by the Applicant to the City for review and approval.

Prior to issuance of a certificate of occupancy, all required lighting shall be installed and operational and shall be maintained by the property owner for the life of the project.
d. Supporting Explanation: The proposed project is considered a non-residential office/ employment project. The project VMT rate exceeds the City’s VMT threshold (Target VMT Rate) by 20 percent (FEIR Table 4.17.B, at 4.17.-13) and, therefore, is required to reduce its VMT by 20 percent. Therefore, the proposed project would be required to implement MM TRA-1 and MM TRA-2 which encourage a mode shift from vehicles to bicycles, thereby reducing and displacing VMT. Additionally, the project Applicant is required to comply with the site development standards specified in Section 9.160 of the City’s Municipal Code (RCM TRA-1) related to employee parking spaces, parking for carpool vehicles, parking for vanpool vehicles, bicycle parking, shower Item: 9
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facilities, locker facilities, commuter information areas, rideshare vehicle loading areas, and the provision of transit/bus shelters.

Assuming implementation of mitigation could achieve the maximum 0.5 percent VMT reduction, the reduction achieved would not reduce the project’s VMT to below the City’s VMT threshold. Therefore, even with implementation of RCM TRA-1, MM TRA1, and MM TRA-2, the project’s VMT impact would remain significant and unavoidable. (FEIR Appendix G at 4.17-11 to 4.17-13 and 4.17-20)

71. Cumulative Impact: Project development, together with cumulative projects, would result in significant impacts related to transportation and traffic, specifically VMT, in the project area. Impacts would be significant and unavoidable after implementation of mitigation. (FEIR Appendix G at 4.17-17 to 4.17-18)
a. Finding: Changes or alterations have been required, or incorporated into, the proposed project, which avoid or substantially lessen the significant environmental effect as identified in the FEIR, though these changes do not reduce the identified impact to below established significance thresholds. (State CEQA Guidelines Section 15091(a)(1).)
b. Applicable Regulatory Compliance Measures: RCM TRA-1 as discussed above is applicable to this topical area. (FEIR 3-4 and Appendix G at 4.17-17 to 4.17-20) c. Applicable Mitigation Measures: MM TRA-1 and MM TRA-2 as discussed above area applicable to this topical area. (FEIR 3-4 and Appendix G at 4.17-17 to 4.19-20) d. Supporting Explanation: The proposed project would result in a less than significant impact related to conflicts with a program, plan, or ordinance, or policy addressing the circulation system, roadway design hazards, and emergency access. However, based on the City of Lake Forest Transportation Analysis Guidelines (TA Guidelines), the project VMT rate exceeds the City’s VMT threshold. The proposed project would be required to implement RCM and Traffic Demand Management (TDM) measures as specified in RCM TRA-1, MM TRA-1, and MM TRA-2, to promote alternative transportation with the intent of reducing VMT. Assuming the maximum 0.5 percent VMT reduction, the reduction achieved would not reduce the project’s VMT impact to below the City’s VMT threshold. Therefore, even with implementation of RCM TRA-1, MM TRA-1, and MM TRA-2, the proposed project would result in a cumulatively significant and unavoidable transportation impact related to VMT. (FEIR Appendix G at 4.17-17 to 4.17-18) SECTION VI: FINDINGS REGARDING SIGNIFICANT IRREVERSIBLE

ENVIRONMENTAL CHANGES
Section 15126.2(d) of the State CEQA Guidelines requires that an EIR consider and discuss significant irreversible changes that would be caused by implementation of a proposed project.

The State CEQA Guidelines specify that the use of nonrenewable resources during the initial and continued phases of a project should be discussed because a large commitment of such resources makes removal or non-use thereafter unlikely. Primary and secondary impacts (e.g., a highway improvement that provides access to a previously inaccessible area) should also be discussed because such changes generally commit future generations to similar uses.

Irreversible damage can also result from environmental accidents associated with a project and should be discussed.

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Construction of the proposed project would require consumption of resources that are not replenishable or that may renew so slowly as to be considered nonrenewable. These resources would include certain types of lumber and other forest products (e.g., hardwood lumber), aggregate materials used in concrete and asphalt (e.g., sand, gravel, and stone), metals (e.g., steel, copper, and lead), petrochemical construction materials (e.g., plastics), and water. Fossil fuels (e.g., gasoline and oil) would also be consumed in the use of construction vehicles and equipment. Lumber, aggregate materials, metals, and petrochemical construction materials would be used to construct the proposed building. Once construction is complete, the proposed project would not require additional consumption of these materials and, should the proposed building be demolished in the future, some of these materials may be recycled or salvaged for future uses as required by the CALGreen Code and SB 1374. (DEIR at 4.19-17 to 4.19-18) Given the temporary nature and short duration of construction activities, construction-related water consumption would not significantly impact water supplies. (DEIR at 4.19-12 to 4.19-13) The use of construction vehicles and equipment would require the temporary consumption of nonrenewable fossil fuels such as natural gas and oil. The proposed project would comply with existing requirements for fuel efficiency and use of renewable energy sources pursuant to the PRC and the CALGreen Code, which would minimize the consumption of non-renewable resources during construction to the maximum extent feasible. (DEIR at 4.6-7 to 4.6-10) Operation of the proposed project would continue to expend similar non-renewable resources that are currently consumed within Lake Forest and on site. These include energy resources such as electricity, petroleum-based fuels, fossil fuels, and water. Energy resources would be used for heating and cooling the building and building lighting. Fossil fuels are primary energy sources for project operation. This existing, finite energy source would thus be incrementally reduced. The proposed project would comply with existing requirements for energy efficiency and use of renewable energy sources as required by Title 24, Part 6 of the CCR, the CALGreen Code, the California Energy Efficiency Strategic Plan, SB 100, the California Renewable Portfolio Standards Program, the PRC, and the City of Lake Forest General Plan, which would minimize the consumption of non-renewable resources during operation to the maximum extent feasible. (DEIR at 4.6-1 to 4.6-10)
The future tenant of the new industrial building is unknown at this time, and it is possible project operation may result in the use or handling of hazardous materials depending on what types of manufacturing activities would occur on the project site. Nevertheless, such materials would be used, handled, stored, and disposed of in accordance with applicable government regulations and standards that would serve to protect against a significant and irreversible environmental change resulting from the accidental release of hazardous materials, including requirements for HMBPs and RMPs for facilities handling significant quantities of hazardous materials, OSHA and Cal/OSHA regulations, CCR Title 8, the CGP, and USDOT, RCRA, and State regulations. (DEIR 4.9-9 to 4.9-13)
In summary, construction and operation of the proposed project would commit the use of slowly renewable and non-renewable resources and would limit the availability of these resources on the project site for future generations or for other uses during the life of the proposed project.

However, the continued use of such resources during operation would be on a relatively small scale, consistent with all State and local policies and regulations referenced above aimed at minimizing the inefficient use of non-renewable resources. As a result, the use of nonrenewable resources in this manner would not result in significant irreversible changes to the environment under the proposed project.

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SECTION VII: GROWTH-INDUCING IMPACTS
Sections 15126(d) and 15126.2(e) of the State CEQA Guidelines require that an EIR analyze growth-inducing impacts and discuss the ways in which a proposed project could foster economic or population growth or construction of additional housing, either directly or indirectly, in the surrounding environment. Section 15126.2(d) of the State CEQA Guidelines also requires a discussion of the characteristics of projects that may encourage and facilitate other activities that could significantly affect the environment, either individually or cumulatively. A project is typically considered growth inducing: (1) if it would foster economic or population growth or the construction of additional housing; (2) if it would remove obstacles to population growth or tax community services to the extent that the construction of new facilities would be necessary; or (3) if it would encourage or facilitate other activities that cause significant environmental effects.5 Examples of projects likely to have significant growth-inducing impacts include extensions or expansions of infrastructure systems beyond what is needed to serve project-specific demand, and development of new residential subdivisions or industrial parks in areas that are currently only sparsely developed or are undeveloped.

The proposed project consists of the redevelopment of an existing office/industrial building with a new industrial building and associated parking and landscaping. The proposed project does not include a housing component. The area surrounding the project site is already highly urbanized and developed with a mix of residential, business park, regional park/open space, and industrial land uses. Due to the developed nature of the area surrounding the project site, population growth within the vicinity of the project site is highly constrained and implementation of the proposed project would not remove impediments to population growth in the area surrounding the project site. (DEIR at 4.14-6 to 4.14-8) The construction of the proposed project would provide short-term construction jobs over an approximately 12-month period. Construction jobs would be temporary and would be specific to the variety of construction activities. The work requirements of most construction projects are highly specialized, so construction workers remain at a job site only for the limited time in which their specific skills are needed to complete a particular phase of the construction process. Given the relatively short duration of construction, the relatively small size of the proposed project, and the availability of local and regional construction workers, project-related construction workers would not be expected to relocate their places of residence as a consequence of working on the project site. Once operational, the proposed project would not result in direct population growth because the proposed project is not a residential use or does not include a residential component; and therefore, would not add new residents at the project site. The proposed industrial building would generate approximately 187 new jobs in the City of Lake Forest. Due to the large population and the existing workforce within Orange County and the proportion of unemployed individuals within the City (3.7 percent of the labor force) and Orange County (4.0 percent of the labor force), it is reasonable to assume that the majority of the new jobs generated by the proposed project would be filled by existing City residents and residents of nearby Cities within Orange County. Therefore, because it is reasonable to assume that the majority of the new jobs generated by the proposed project would be filled by the local and regional labor pools and that the types of employment offered by the proposed project would not cause people to move or relocate to the area solely for the purpose of being close to the project site, the proposed project would not generate substantial population growth in the area.

Furthermore, since employees would already live in the City or nearby geographic areas, it is assumed that they would already have adequate housing. (DEIR at 4.14-6 to 4.14-8) 5 State CEQA Guidelines. 2023. Section 15126.2(d).

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The proposed project is consistent with the project site’s General Plan designation and does not represent unplanned growth given that the project site would be developed consistent with its land use and zoning designations. Therefore, although the proposed project would provide short- and long-term employment opportunities, it would not result in substantial direct or indirect population growth or create a significant demand for housing in the project site vicinity. (DEIR at 4.11-8 to 4.11-27)
The proposed project would consist of redevelopment of an existing developed site and would not require the extension of utilities or roads into undeveloped areas or directly or indirectly lead to the development of undeveloped sites. The existing office/industrial building has existing onsite connections to water, sewer, stormwater, and electricity. Redevelopment of the project site with the new industrial building would require improvements to existing on-site connections for water, sewer, drainage, and electricity. These on-site improvements are wholly contained within the project footprint and would only serve the proposed project. (DEIR at 4.19-2 to 4.19-5, and

4.19-12 to 4.19-16)
All access and internal circulation improvements implemented as part of the proposed project would provide for better circulation flows within the project site and would not foster off-site population growth. Additionally, the proposed off-site intersection improvements included as part of the proposed project are intended to enhance public safety and address concerns related to large truck turning movements and would not foster off-site population growth. (DEIR at 4.17-13 to 4.17-16) Due to the nature of the project (i.e., non-residential) and the location of the project site within a developed and urbanized area, development of the proposed project would not result in growth-inducing impacts.

SECTION VIII: ALTERNATIVES TO THE PROPOSED PROJECT
Background:

Section 15126.6 of the State CEQA Guidelines requires EIRs to consider and discuss alternatives to the proposed actions. Subsection (a) states:

An EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives. An EIR need not consider every conceivable alternative to a project. Rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decision-making and public participation.

An EIR is not required to consider alternatives which are infeasible. The lead agency is responsible for selecting a range of project alternatives for examination and must publicly disclose its reasoning for selecting those alternatives. There is no ironclad rule governing the nature or scope of the alternatives to be discussed other than the rule of reason.

Subsection 15126.6(b) states the purpose of the alternatives analysis:

Because an EIR must identify ways to mitigate or avoid the significant effects that a project may have on the environment (Public Resources Code Section 21002.1), the discussion of alternatives shall focus on alternatives to the project or its location which are capable of avoiding or substantially lessening any significant effects of the project, even if these alternatives would impede Item: 9
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to some degree the attainment of the project objectives, or would be more costly.

In subsection 15126.6(c), the State CEQA Guidelines describe the selection process for a range of reasonable alternatives:

The range of potential alternatives to the proposed project shall include those that could feasibly accomplish most of the basic objectives of the project and could avoid or substantially lessen one or more of the significant effects. The EIR should briefly describe the rationale for selecting the alternatives to be discussed. The EIR should also identify any alternatives that were considered by the lead agency but were rejected as infeasible during the scoping process and briefly explain the reasons underlying the lead agency’s determination. Additional information explaining the choice of alternatives may be included in the administrative record. Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are: (i) failure to meet most of the basic project objectives, (ii) infeasibility, or (iii) inability to avoid significant environmental impacts.

The range of alternatives required is governed by a “rule of reason” that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice. The EIR shall include sufficient information about each alternative to allow meaningful evaluation, analysis, and comparison with the proposed project. Alternatives are limited to ones that would avoid or substantially lessen any of the significant effects of the project. Of those alternatives, the EIR need examine in detail only the ones that the lead agency determines could feasibly attain most of the basic objectives of the project.

However, when significant impacts can be mitigated by the adoption of mitigation measures, the lead agency has no obligation to consider the feasibility of alternatives with respect to that impact in its findings, even if the alternative would mitigate the impact to a greater degree than the proposed Project. (PRC § 21002; Kings County Farm Bureau v. City of Hanford (1990) 221 Cal.App.3d 692, 730-731; Laurel Heights Improvement Association v. Regents of the University of California (1988) 47 Cal.3d 376, 400-403; Laurel Hills Homeowners Association v. City Council (1978) 83 Cal.App.3d 515, 521.) The City has adopted mitigation measures to avoid or substantially lessen the potentially significant environmental impacts identified in the DEIR.

However, specific direct and cumulative impacts related to greenhouse gas emissions and VMT would remain significant and unavoidable.

Project Objectives:

The following objectives have been established for the proposed project: (DEIR at 3-20 to 3-21)

1. Provide a permitted land use that is consistent with the General Plan land use and zoning designation and that helps fulfill the demands of businesses and residents in the City of Lake Forest;

2. Re-envision an existing underutilized office/industrial property to build a new financially and environmentally sustainable building;

3. Re-envision an existing underutilized office/industrial property to provide a building type that is flexible and accommodating to a variety of permitted land uses to extend the useful life of the building;
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4. Provide industrial development that is attractive and minimizes conflicts with the surrounding existing uses;

5. Provide employment opportunities and facilitate job-creation for the residents of Lake Forest and surrounding communities to reduce the need for members of the local workforce to commute outside the area for employment;

6. Redevelop an underutilized site for improvement and enhanced contribution to the City of Lake Forest’s fiscal benefits; and

7. Cluster land uses in proximity to other similar industrial/commercial uses and close to access points of the State highway system, such as State Route 241, to reduce traffic congestion on surface streets and reduce local air pollution emissions from vehicle sources.

Alternatives Considered but Rejected:

Alternative Sites. CEQA requires that the discussion of alternatives focus on alternatives to the project or its location that are capable of avoiding or substantially lessening any significant impacts of the project. The key question and first step in the analysis is whether any of the significant impacts of the project would be avoided or substantially lessened by relocating the project. Only locations that would avoid or substantially lessen any of the significant impacts of the project need be considered for inclusion in the EIR (State CEQA Guidelines Section 15126.6[f][2][A]). Among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, General Plan consistency, other plans or regulatory limitations, jurisdictional boundaries, and whether the applicant can reasonably acquire, control, or otherwise have access to the alternative site (State CEQA Guidelines Section 15126.6[f][1]). If it is determined that no feasible alternative locations exist, the EIR must disclose the reasons for this conclusion (State CEQA Guidelines Section 15126.6[f][2][B]).

No alternative locations where the proposed project could be undertaken are analyzed in the Draft EIR. Key objectives of the proposed project include re-envisioning an existing underutilized property to develop a new financially stable building that fulfills the demands of businesses and residents in the City and provides employment opportunities for the residents of Lake Forest and surrounding communities. The Applicant/Developer does not own or control any other property in the vicinity of the project site that would be suitable for development of the proposed project or that would meet the proposed project objectives including redevelopment of an existing underutilized property. Additionally, the City has not identified any currently underutilized/vacant properties within the project vicinity with a Light Industrial land use and zoning designation that would allow for the implementation of a project with similar uses and square footage. Furthermore, development of the proposed project on an alternative site would likely result in many of the same environmental impacts as development of the proposed project on the project site. Therefore, this alternative was rejected from further consideration. (DEIR at 5-4 to 5-5)
Reduced Daily Trip Alternative. An alternative that could be screened out of a project-level assessment based on the City’s TA Guidelines would eliminate the project’s significant and unavoidable VMT impact and was therefore considered. To be screened out of a project-level assessment, the alternative would need to satisfy the “Small Project Screening” criteria. To satisfy the “Small Project Screening” criteria, the alternative would need to result in less than 110 daily trips. If the alternative resulted in less than 110 daily trips, it could be screened out of a VMT analysis and would be presumed to have a less than significant VMT impact. Potential Item: 9
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developments on the project site that could meet this criteria include: (1) development of a maximum 64,060-square-foot building with a warehouse use; (2) development of a maximum 23,165-square-foot building with a manufacturing use; or (3) development of a maximum 10,100-square-foot building with an office use. Development of one of these smaller buildings would also incrementally reduce impacts associated with air quality, greenhouse gas emissions, noise, and transportation and traffic. However, development of buildings of this size would yield a very low land coverage that would not justify the relation between land value, building construction costs, and potential revenue, resulting in an unfeasible project. Additionally, tenants required to support the smaller building sizes and assumed uses are not present in the market to facilitate the required financial viability. Finally, development of this alternative would not meet the majority of the project objectives. Therefore, for the reasons above this alternative was rejected from further consideration. (DEIR at 5-5)
Alternatives Selected for Analysis:

The DEIR identified three alternatives:

Alternative 1 – No Project Alternative
Alternative 2 - Previous Use and Associated Site Development Permit Alternative Alternative 3 – Reduced Project Alternative
Alternative 1 – No Project Alternative
Description: CEQA requires analysis of a “No Project” Alternative. The purpose of describing and analyzing a No Project Alternative is to allow decision-makers to compare the impacts of approving the proposed project with the impacts of not approving the proposed project. According to State CEQA Guidelines Section 15126.6(e)(3)(C), the lead agency should proceed to analyze the impacts of the No Project Alternative by projecting what would reasonably be expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services.

Under Alternative 1, the No Project Alternative, the project site would remain in its current condition. No development of a new building, site improvements, or ground disturbance would occur. The project site would continue to be occupied by the existing 144,906-square-foot, two-story tilt-up office/industrial building and associated parking and landscaping. The existing building would remain vacant, consistent with existing conditions. (DEIR at 5-6 to 5-7) Finding: The City Council finds, pursuant to PRC Section 21081(a)(3), that specific legal, economic, social, technical, or other considerations make the No Project Alternative infeasible; therefore, the City Council hereby rejects the No Project Alternative.

Environmental Analysis: No new development would occur on the project site. The project site would remain developed with the existing office/industrial building and associated parking and landscaping. Currently the existing building is vacant. If the building remains vacant, the existing environmental conditions would remain unchanged. (DEIR at 5-7 to 5-12)
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Supporting Explanation:

Avoid or Substantially Lessen Project Impacts: Because Alternative 1 would not require demolition activities, construction of a new building, or increase the intensity of on-site uses, the impacts of Alternative 1 would be less than the impacts of the proposed project for aesthetics, air quality, biological resources, cultural resources, energy, geology and soils, greenhouse gas emissions, hazards and hazardous materials, hydrology and water quality, noise, population and housing, public services, recreation, transportation, tribal cultural resources, utilities and service systems, and wildfire. More specifically, Alternative 1 would not result in significant and unavoidable transportation impacts related to VMT or a significant and unavoidable cumulatively considerable impact related to GHG emissions. (DEIR at 5- 12)
Attainment of Project Objectives: Alternative 1 would be potentially consistent with the following Project Objective 7: (Cluster land uses in proximity to other similar industrial/commercial uses and close to access points of the State highway system, such as State Route 241, to reduce traffic congestion on surface streets and reduce local air pollution emissions from vehicle sources).

Under Alternative 1 the existing underutilized office/industrial building would remain in place and would remain vacant. Therefore, this alternative would not be consistent with any of the other Project Objectives. (DEIR at 5-12 to 5-13) Comparative Merits: The No Project Alternative would avoid significant and unavoidable impacts related to VMT and GHG emissions. It would also avoid any construction-related impacts associated with project development. However, this alternative would only partially attain 1 of the 7 objectives of the proposed project. It is also not reasonable to assume that the project site and existing industrial/office building would remain vacant in perpetuity. As previously discussed, the No Project Alternative is legally infeasible, as it would conflict with the Applicant’s vested right to lease the existing industrial/office building and occupy the project site. Further, keeping the existing industrial/office building vacant would conflict with the intent of the industrial complex to provide industrial business and jobs which thereby provide an economic benefit to the City and its residents. Therefore, the City Council hereby rejects the No Project Alternative.

Alternative 2 - Previous Use and Associated Site Development Permit Alternative Description: Under Alternative 2, no new development would occur on the project site and no site improvements (aside from potential interior tenant improvements) would be implemented. The project site would remain developed with the existing office/ industrial building and would operate as an office consistent with the existing Site Development Permit. Alternative 2 would not require demolition activities or construction of a new building.

Alternative 2 assumes that the project site would be occupied by office uses consistent with the existing Site Development Permit. The project site would continue to be occupied by a 144,906-square-foot, two-story tilt-up office/industrial building and associated parking and landscaping. No modifications would be made to the exterior of the building, parking, or landscaping and no construction activities (aside from interior tenant improvements) or ground disturbance would occur.

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Under this alternative, an estimated 472 individuals would be employed at the project site. Alternative 2 is expected to generate 1,571 daily trips, including 220 a.m. and 209 p.m. peak-hour trips, resulting in a net increase of 844 daily trips compared to the proposed project. (DEIR at 5-13)
Finding: The City Council finds, pursuant to PRC Section 21081(a)(3), that specific legal, economic, social, technical, or other considerations make the Previous Use and Associated Site Development Permit Alternative infeasible; therefore, the City Council hereby rejects the Previous Use and Associated Site Development Permit Alternative.

Environmental Analysis: In the absence of construction or ground disturbance, no construction-related impacts would occur. As no exterior modifications to the building or project site would occur under this alternative, the environmental conditions associated with subsequent operation of the building would be similar to those associated with the previous use and what is typical in an office park environment (e.g., aesthetics, noise). As the demolition and construction activities necessary for implementation of the proposed project would not occur, Alternative 2 would not alter the site’s existing drainage, landscaping, or ground surface; therefore, there would be no potential for impacts relative to biological resources, cultural resources, geology/soils, mineral resources, tribal cultural resources, wildfire or changes to onsite or local hydrology/water quality. Because the existing structure would remain, the emission of construction-related criteria pollutants and toxic air contaminants (TACs) would not occur under Alternative 2. Compared to the proposed project, the net increase in employees on-site would increase the number of daily trips, resulting in a proportional increase in the volume of air pollutant and greenhouse gas emissions emitted during project operation. Operation of the existing use would be consistent with existing City land use and zoning designations, and no impact would occur. Use of the existing building for office uses would potentially increase the number of potential jobs (by 285 jobs); though, similar to the proposed project, it is reasonable the majority of these jobs would be filled by existing City or County residents and would not represent unplanned growth; therefore, increased demand for public service, recreation, or utility services would be negligible. The increase in the number of daily trips (844 daily trips) would contribute to significant and unavoidable VMT related impacts, and a cumulatively significant greenhouse gas impact. (DEIR 5-13 to 5-20)
Supporting Explanation:

Avoid or Substantially Lessen Project Impacts: Alternative 2 would not result in any construction-related impacts. Similar to the proposed project, development of Alternative 2 would result in no impacts to agriculture and forestry resources, land use and planning, and mineral resources and would result in less than significant impacts to population and housing, public services, recreation, and utilities and service systems. In the absence of demolition activity, compared to the proposed project, impact relative to aesthetics, biological resources, cultural resources, geology and soils, hazards and hazardous materials, hydrology and water quality, noise, tribal cultural resources, and wildfire be reduced under Alternative 2.

Alternative 2 would result in a significant and unavoidable transportation impact related to VMT and a significant and unavoidable cumulatively considerable impact related to GHG emissions. (DEIR 5-20 to 5-21)
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Attainment of Project Objectives: Alternative 2 would be potentially consistent with the following three project objectives:

1. Provide a permitted land use that is consistent with the General Plan land use and zoning designation and that helps fulfill the demands of businesses and residents in the City of Lake Forest;

Under Alternative 2 the existing building would operate as an office consistent with the existing Site Development Permit. The project site would continue to be occupied by a 144,906-square-foot, two story tilt-up office/industrial building and associated parking and landscaping. Therefore, Alternative 2 would not be consistent with the remaining four project objectives. (DEIR at 5-21)
Comparative Merits: Compared to the proposed project, Alternative 2 would eliminate construction-related impacts but would result in a net increase in employees on-site thereby increasing the number of daily trips and resulting in a proportional increase in the volume of air pollutant and greenhouse gas emissions emitted during project operation. The increase in the number of daily trips (844 daily trips compared to the proposed project) would contribute to significant and unavoidable VMT related impacts, and a cumulatively significant greenhouse gas impact. (DEIR at 5-10 to 5-21) Furthermore, this alternative only achieves some, but not the majority of the project’s objectives. More importantly, this alternative assumes that a tenant could be secured for the existing building in its current configuration.

The fact that the existing building has not been occupied for more than 2 years demonstrates that the existing building is not aligned with the current needs of tenants in the City for this specific land use. State CEQA Guidelines sections 15091(c)(3) and 15126.6 provide that where a proposed alternative is neither legally possible nor meets the project objectives, the alternative may be rejected as infeasible. Alternative 2 is infeasible under the State CEQA Guidelines for the reasons described above. Therefore, the City Council hereby rejects the Previous Use and Associated Site Development Permit Alternative (Alternative 2).

Alternative 3 – Reduced Project Alternative
Description: Under Alternative 3, the square footage of the proposed project would be reduced by 25 percent, and all building uses (e.g., office, manufacturing, and warehouse) would be proportionally reduced. The existing office/industrial building would be demolished and a new 35-foot-tall, 124,352.25-square-foot tilt-up concrete industrial building would be constructed. The building would include 7,500 square feet of office space, 48,750 square feet of manufacturing space, and 68,102.25 square feet of warehouse space. The area of decreased building footprint would be designated for additional vehicle and truck parking. Consistent with the proposed Item: 9
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project, Alternative 3 would include a gated truck loading area, truck and auto parking spaces, and new landscaping throughout the site.

Under this alternative, an estimated 139 individuals would be employed at the project site. Alternative 3 is expected to generate 429 daily trips, including 55 a.m. and 58 p.m. peak-hour trips; therefore, compared to the proposed project, Alternative 3 would result in a net decrease of 298 daily trips. (DEIR at 5-21 to 5-22) Finding: TheCity Council finds, pursuant to PRC Section 21081(a)(3), that specific legal, economic, social, technical, or other considerations make the Reduced Project Alternative infeasible; therefore, the City Council hereby rejects the Reduced Project Alternative.

Environmental Analysis: Demolition and construction activities would be required site -wide to accommodate Alternative 3. While the building size is reduced, modification of the entire site would still occur, providing additional vehicle and truck parking.

Therefore, the impacts associated with site disturbance (e.g., biological resources, cultural resources, geology/soils, tribal cultural resources, wildfire or changes to onsite or local hydrology/water quality) would still occur similar to the proposed project.

As demolition and construction would occur under this alternative, the emission of construction-related criteria pollutants and TACs would still occur, though the volume of emissions may be incrementally reduced. Compared to the proposed project, the net decrease in employees (a 48 employee decrease) would reduce the number of daily trips (by 298 trips), resulting in an incremental and proportional decrease in volume of air pollutant and greenhouse gas emissions emitted during project operation. The reduced size of the use would still be consistent with existing City land use and zoning designations, and no impact would occur. Because a reduction in on-site employment would occur, the uses envisioned under Alternative 3 are not likely to result in unplanned growth. Compared to the proposed project, development of a smaller building with a smaller potential workforce would incrementally reduce the demand for public service, recreation, and utility services. Though a reduction in daily trips would occur, this alternative would still exceed the City’s VMT threshold and would contribute to significant and unavoidable VMT related impacts, and a cumulatively significant greenhouse gas impact. (DEIR 5-22 to 5-30) Supporting Explanation:

Avoid or Substantially Lessen Project Impacts: The existing office/industrial building would be demolished and a new industrial building with truck and auto parking spaces, and new landscaping would be constructed. Alternative 3 and the proposed project are similar in that both would result in no impacts to agriculture and forestry resources, land use and planning, and mineral resources; and both would result in less than significant impacts to biological resources, cultural resources, geology and soils, hazards and hazardous materials, hydrology and water quality, population and housing, public services, recreation, tribal cultural resources, and wildfire. However, because Alternative 3 would result in the development of a slightly smaller building, would result in 48 fewer employees, and would result in a net decrease of 298 daily trips compared to the proposed project, the impacts of Alternative 3 would be less than the impacts of the proposed project for aesthetics, air quality, energy, utilities and service systems, and noise. Consistent with the proposed project, Alternative 3 would result in a significant and unavoidable transportation impact related to VMT Item: 9
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and a significant and unavoidable cumulatively considerable impact related to GHG emissions. (DEIR at 5-30 to 5-31)
Attainment of Project Objectives: Alternative 3 would be potentially consistent with all seven of the project objectives; however, due to the reduced size of the building and fewer job offerings, the objectives would not be met to the same degree as the proposed project. (DEIR at 5-31)
Comparative Merits: Compared to the proposed project, Alternative 3 would reduce some the project’s impacts, but would not eliminate those impacts, and consistent with the proposed project would result in a significant and unavoidable impact related to VMT and GHG emissions. While Alternative 3 would meet the project’s objectives, the objectives would not be met to the same degree as the proposed project.

Alternative 3 would substantially reduce the overall building area and site coverage.

However, the Project Applicant has submitted evidence regarding the economic infeasibility of Alternative 3. For example, the Project Applicant provided that development costs are not linearly scalable with building area due to the presence of many fixed and quasi-fixed costs, including site acquisition, entitlement, permitting, infrastructure, and certain construction components. As a result, a reduction in project size would not yield a commensurate reduction in total project costs on a persquare-foot basis. In contrast, lease revenues are directly correlated with leasable area and would decrease proportionally with a reduction in building square footage.

Accordingly, the Project Applicant provided that Alternative 3 would materially degrade the project’s revenue-to-cost relationship and preclude the achievement of the Applicant’s business objectives, thereby rendering the project economically infeasible. Because the proposed project already reflects a constrained development program necessary to maintain financial viability under current market conditions, the Project applicant provided that further reduction in scale would prevent the project from meeting its core business objectives and would not be economically feasible.

State CEQA Guidelines sections 15091(c)(3) and 15126.6 provide that where a proposed alternative is neither legally possible nor meets the project objectives, the alternative may be rejected as infeasible. Alternative 3 is infeasible under the State CEQA Guidelines for the reasons described above. Therefore, the City Council hereby rejects the Reduced Project Alternative (Alternative 3).

Environmentally Superior Alternative
CEQA requires the identification of an Environmentally Superior Alternative among the alternatives evaluated in an EIR. While Alternative 1 would avoid the impacts of the proposed project, it would not achieve the beneficial impacts of the proposed project including the re-envisioning of an existing underutilized office/industrial property to provide a building type that is flexible and accommodating to a variety of permitted land uses to extend the useful life of the building, and creating employment opportunities. While Alternative 1 would be environmentally superior in the technical sense in that contribution to the aforementioned impacts would not occur, it would fail to achieve all but one of the project’s objectives. State CEQA Guidelines Section 15126.6(e)(2) provides that, if the No Project/No Build Alternative is the Environmentally Superior Alternative, then the EIR shall also identify an Environmentally Superior Alternative among the other alternatives.

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Of the other alternatives, Alternative 2 would only meet three of the project objectives and would result in similar or reduced environmental impacts compared to the proposed project; though it would still result in a significant and unavoidable transportation impact related to VMT and a significant and unavoidable cumulatively considerable impact related to GHG emissions.

Alternative 3 was identified as the Environmentally Superior Alternative as it would result in similar or reduced impacts as the proposed project. While the number of daily trips is reduced, compared to the proposed project, Alternative 3 would still result in a significant and unavoidable transportation impact related to VMT and a significant and unavoidable cumulatively considerable impact related to GHG emissions. Alternative 3 would achieve all of the project objectives, though not to the same degree as the proposed project. (DEIR at 5-31 to 5-32) Finding: For the reasons set forth below in Supporting Explanation, and as discussed further in the FEIR, the City Council hereby rejects the Environmentally Superior Alternative because it would still result in significant unavoidable VMT and GHG impacts. The Environmentally Superior Alternative would render development of the site economically infeasible, depriving the City of the economic and employment benefits derived from the development of the project and associated infrastructure improvements. Therefore, the City Council, pursuant to PRC Section 21081(a)(3), hereby rejects the Environmentally Superior Alternative.

Supporting Explanation: Compared to the proposed project, Alternative 3 would reduce some the project’s impacts, but would not eliminate those impacts, and consistent with the proposed project would result in a significant and unavoidable impact related to VMT and GHG emissions. While Alternative 3 would meet the project’s objectives, the objectives would not be met to the same degree as the proposed project.

Alternative 3 would not meet the Applicant’s business objectives. The business plan created at acquisition of the property was predicated on designing a project that optimizes site coverage while adhering to land use regulations and providing necessary infrastructure. The proposed project, as designed, represents the minimum development intensity necessary to achieve the Applicant’s fundamental business objectives. Since the project’s initial conception, material changes in market conditions have substantially affected project feasibility. Notably, construction costs for comparable industrial developments have increased by approximately 22 percent between 2021 and 2025. At the same time, lease rates have remained relatively flat.

In addition, the project has incurred increased additional capital obligations through City-required off-site infrastructure improvements associated with the entitlement process, further elevating total development costs and constraining viability.

Alternative 3 would substantially reduce the overall building area and site coverage.

However, development costs are not linearly scalable with building area due to the presence of many fixed and quasi-fixed costs, including site acquisition, entitlement, permitting, infrastructure, and certain construction components. As a result, a reduction in project size would not yield a commensurate reduction in total project costs on a per-square-foot basis. In contrast, lease revenues are directly correlated with leasable area and would decrease proportionally with a reduction in building square footage.

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Accordingly, Alternative 3 would materially degrade the project’s revenue-to-cost relationship and preclude the achievement of the Applicant’s business objectives, thereby rendering the project economically infeasible. Because the proposed project already reflects a constrained development program necessary to maintain financial viability under current market conditions, further reduction in scale would prevent the project from meeting its core business objectives and would not be feasible.

CEQA does not require the City to choose the environmentally superior alternative.

Instead CEQA requires the City to consider environmentally superior alternatives, explain the considerations that led it to conclude that those alternatives were infeasible from a policy standpoint, weigh those considerations against the environmental impacts of the proposed project, and make findings that the benefits of those considerations outweighed the harm. Based upon the foregoing, the City Council hereby rejects the Environmentally Superior Alternative.

SECTION IX: ADOPTION OF STATEMENT OF OVERRIDING CONSIDERATIONS Pursuant to State CEQA Guidelines Section 15093(a), the City Council must balance, as applicable, the economic, legal, social, technological, or other benefits of the Project against its unavoidable environmental risks in determining whether to approve the project. If the specific benefits of the project outweigh the unavoidable adverse environmental effects, those environmental effects may be considered acceptable.

Having reduced the adverse significant environmental effects of the Project to the extent feasible by adopting the mitigation measures; having considered the entire administrative record on the project; the City Council has weighed the benefits of the Project against its unavoidable adverse impacts after mitigation in regards to greenhouse gas emissions and transportation and traffic. While recognizing that the unavoidable adverse impacts are significant under CEQA thresholds, the City Council nonetheless finds that the unavoidable adverse impacts that will result from the Project are acceptable and outweighed by specific social, economic and other benefits of the Project.

In making this determination, the factors and public benefits specified below were considered. Any one of these reasons is sufficient to justify approval of the Project. Thus, even if a court were to conclude that not every reason is supported by substantial evidence, the City Council would be able to stand by its determination that each individual reason is sufficient. The substantial evidence supporting the various benefits can be found in the preceding findings, which are incorporated by reference into this section, and in the documents found in the Records of Proceeding.

The City Council therefore finds that for each of the significant impacts which are subject to a finding under CEQA Section 21081(a)(3), that each of the following social, economic, and environmental benefits of the Project, independent of the other benefits, outweigh the potential significant unavoidable adverse impacts and render acceptable each and every one of these unavoidable adverse environmental impacts:

Item: 9
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1. The Project provides a permitted land use that is consistent with the General Plan land use and zoning designation and that helps fulfill the demands of businesses and residents in the City of Lake Forest.

2. The Project re-envisions an existing underutilized office/industrial property to build a new financially and environmentally sustainable building.

3. The Project re-envisions an existing underutilized office/industrial property to provide a building type that is flexible and accommodating to a variety of permitted land uses to extend the useful life of the building.

4. The Project provides industrial development that is attractive and minimizes conflicts with the surrounding existing uses.

5. The Project provides employment opportunities and facilitates job-creation for the residents of Lake Forest and surrounding communities to reduce the need for members of the local workforce to commute outside the area for employment.

6. The Project redevelops an underutilized site for improvement and enhanced contribution to the City of Lake Forest’s fiscal benefits.

7. The Project would cluster land uses in proximity to other similar industrial/commercial uses and close to access points of the State highway system, such as State Route 241, to reduce traffic congestion on surface streets and reduce local air pollution emissions from vehicle sources.

Item: 9
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EXHIBIT B

MITIGATION MONITORING AND REPORTING PROGRAM
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4.1 Aesthetics
There are no significant impacts related to aesthetics. No mitigation is required.

4.2 Agriculture and Forestry Resources
There are no significant impacts related to agriculture and forestry resources. No mitigation is required.

4.3 Air Quality
MM AQ-1: Tier 4 Interim Construction Equipment. Prior to issuance of a building permit, the project
Applicant shall submit construction plans to the
City of Lake Forest verifying that all construction
equipment used during construction of the project
shall be equipped with Tier 4 Interim engines or
the most effective Verified Diesel Emission
Control Strategies (VDECS) available for the
engine type (Tier 4 engines automatically meet
this requirement) as certified by the California Air
Resources Board (CARB). 7 During construction
activities, the equipment shall be properly
maintained and tuned in accordance with
manufacturer specifications.

Prior to issuance
of a building
permit.

Project Applicant
/ City of Lake
Forest
MM AQ-2: Volatile Organic Compounds. Prior to issuance
of a grading permit, the Project Applicant shall
submit construction plans to the City of Lake
Forest that state that the project shall utilize
“Super-Compliant” low volatile organic
compounds (VOC) paints for nonresidential
interior and exterior surfaces and low VOC paint
for parking lot surfaces. Super-Compliant low
VOC paints have been reformulated to exceed
the regulatory VOC limits put forth by SCAQMD
Rule 1113. Super-Compliant low VOC paints shall
be no more than 10 grams per liter (g/L) of VOC.

Prior to issuance
of a grading
permit.

Project Applicant
/ City of Lake
Forest
MM AQ-3: Tier 4 Final Construction Equipment. Prior to
issuance of a building permit, the project
Applicant shall consult with the City on the status
of Western Realco Projects 1 and 2. If in this
consultation, the City identifies that the
construction schedule of Western Realco Projects
1 and 2, and the IPT Enterprise Business Center
LLC Project (proposed project) will be under
construction at the same time, the proposed
project shall equip all construction equipment
during the overlapping period with Tier 4 Final
engines or the most effective Verified Diesel
Emission Control Strategies (VDECS) available
for the engine type (Tier 4 engines automatically
meet this requirement) as certified by the
California Air Resources Board. The equipment
shall be properly maintained and tuned in
accordance with manufacturer specifications. The
project Applicant shall submit construction plans
to the City of Lake Forest denoting the projected
Prior to issuance
of a building
permit.

Project Applicant
/ City of Lake
Forest
7 CARB. 2015. Verified Diesel Emission Control Strategy (VDECS). Website: https://ww2.arb.ca.gov/sites/ default/files/classic/msprog/ordiesel/faq/vdecsfaq.pdf (accessed June 2025) Item: 9
194

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4.4 Biological Resources
RCM BIO-1: Nesting Bird Clearance Survey. If
construction/ground disturbing activities,
including demolition, occurs between February 1
and August 31, a Qualified Biologist shall conduct
a pre-construction clearance survey for nesting
birds within 3 days of the start of any construction,
vegetation clearing, or grading activities
(including disking and demolition) to ensure that
no nesting birds are disturbed during
construction. The Qualified Biologist shall be
retained by the Construction Contractor. The
Qualified Biologist conducting the clearance
survey shall document a negative survey with a
brief letter report indicating that no impacts to
active avian nests would occur. If an active avian
nest is discovered during the pre-construction
clearance survey, construction activities shall stay
outside of a no-disturbance buffer. In general, the
no-disturbance buffer shall be a minimum of 50
feet for passerines and 250 feet for raptors.

However, a species’ sensitivity to disturbance can
vary among species, the level of noise or
construction disturbance, and the line of sight
between the nest and the disturbance. Limits of
construction to avoid an active nest shall be
established in the field with flagging, fencing, or
other appropriate barriers; and construction
personnel shall be instructed on the sensitivity of
nest areas. A biological monitor, with experience
in monitoring active nests, shall be present to
delineate the boundaries of the buffer area and to
monitor daily all active nests to observe the
efficacy of the no-disturbance buffers and to
document any new nesting occurrences to ensure
that nesting behavior is not adversely affected by
the construction activity. Adversely affected
nesting behavior, as determined by the biological
monitor, includes, but is not limited to, disrupting
reproductive behavior, nest abandonment, and/or
prolonged absences of parents while incubating
eggs. Once the young have fledged and left the
nest, or the nest otherwise becomes inactive
under natural conditions, construction, vegetation
clearing, or grading activities (including disking
and demolition) within the buffer area can occur.

Field memorandums shall be prepared by the
biological monitor within 24 hours of each day of
monitoring and shall be submitted to the City of
Lake Forest to document compliance with the
applicable resource protection measures.

Prior to any
construction,
demolition,
vegetation
clearing, or
grading activities
and during
construction.

Construction
Contractor / City
of Lake Forest
Item: 9
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4.5 Cultural Resources
RCM CUL-1: Unknown Archaeological Resources. In
the event that archaeological resources are
discovered during excavation, grading, or
construction activities, work shall cease within
100 feet of the find until a qualified archaeologist
from the Orange County List of Qualified
Archaeologists has evaluated the find in
accordance with federal, State, and local
guidelines to determine whether the find
constitutes a “unique archaeological resource,” as
defined in Section 21083.2(g) of the California
Public Resources Code (PRC). Personnel of the
proposed project shall not collect or move any
archaeological materials and associated
materials. Construction activity may continue
unimpeded beyond 100 feet from the find on other
portions of the project site. The found deposits
shall be treated in accordance with federal, State,
and local guidelines, including those set forth in
PRC Section 21083.2. Prior to issuance of a
grading permit, the Director of Community
Development, or designee, shall ensure that this
regulatory compliance measure is documented
on the grading plans.

During grounddisturbing
construction
activities, upon
discovery of
archaeological
resources.

Construction
Contractor and
Qualified
Archaeologist /
City of Lake
Forest Director of
Community
Development or
designee
Item: 9
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The MLD shall complete the inspection and make
recommendations or preferences for treatment
within 48 hours of being granted access to the
site. The MLD recommendations may include
scientific removal and nondestructive analysis of
human remains and items associated with Native
American burials, preservation of Native
American human remains and associated grave
goods in place, relinquishment of Native
American human remains and associated items
to the descendants for treatment, or any other
culturally appropriate treatment. Prior to issuance
of a grading permit, the Director of Community
Development, or designee, shall ensure that this
regulatory compliance measure is documented
on the grading plans.

During grounddisturbing
construction
activities, upon
discovery of
human remains.

Construction
Contractor and
County Coroner /
City of Lake
Forest Director of
Community
Development or
designee

4.6 Energy
There are no significant impacts related to energy. No mitigation is required.

4.7 Geology and Soils
MM GEO-1: Compliance with Applicable California
Building Code and Project-Specific
Geotechnical Specifications. Prior to the final
grading permit and the issuance of building
permits, the project Applicant shall provide final
project plans to applicable City of Lake Forest
(City) staff for review and approval showing that
the project, including site preparation and
construction of proposed buildings, has been
designed and will be constructed in conformance
with applicable provisions of the most current
California Building Code at the time of City review,
the City’s Building Code, and the specifications
cited in the Geotechnical Investigation, prepared
by Southern California Geotechnical, dated
November 2021.

During grading, an on-site inspection shall be
conducted by the Applicant-hired Project
Geotechnical Consultant and the City of Lake
Forest Director of Public Works/ City Engineer, or
Prior to the final
grading permit
and issuance of
building permits.

Project Applicant
and Project
Geotechnical
Consultant / City
of Lake Forest
Director of Public
Works, City
Engineer, or
designee
Item: 9
197

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Prior to the final grading permit, the Project
Geotechnical Consultant shall submit a Final
Testing and Observation Geotechnical Report for
Rough Grading to the City of Lake Forest Director
of Public Works/City Engineer, or designee.

Prior to the issuance of a Certificate of Occupancy
for the new building, the Project Geotechnical
Consultant shall provide a letter regarding
contractor compliance with project plans and
required geotechnical. The letter shall be
submitted to the City of Lake Forest Building
Division for review and approval.

MM GEO-2: Corrosive Soils. Prior to issuance of building permits, the project Applicant/Developer shall
retain the services of a licensed corrosion
engineer to conduct additional site testing and
final design evaluation regarding the possible onsite presence of significant volumes of corrosive soils. At a minimum, the corrosion engineer shall
(1) verify the soluble sulfate concentrations of the
soils that are present at pad grade within the
building areas at the completion of rough grading;
(2) provide detailed corrosion protection
measures for cast iron and/or ductile iron pipes,
as necessary; (3) confirm that soluble sulfates
and chloride levels in the on-site soils do not
warrant specialized concrete mix design; and (4)
confirm that nitrates present in the on-site soil do
not warrant protection for copper materials.

During grading, on-site inspection shall be
conducted by the Project Geotechnical
Consultant and City of Lake Forest Director of
Public Works/City Engineer, or designee, to
ensure compliance with the corrosion protection
measures of the corrosion engineer, as
incorporated into the project plans.

Prior to issuance
of building
permits.

Project Applicant
and Project
Geotechnical
Consultant / City
of Lake Forest
Director of Public
Works, City
Engineer, or
designee
MM GEO-3: Paleontological Resources Impact Mitigation
Program. Prior to the final grading permit and the
issuance of building permits, the project
Applicant/Developer shall provide a letter to the
Director of Community Development Department,
or designee, stating that they have retained a
qualified paleontologist (defined as a practicing
paleontologist who is recognized in the
paleontological community and proficient in
Prior to the final
grading permit
and issuance of
building permits.

Project Applicant
/ City of Lake
Forest Director of
Community
Development
Department or
designee
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198

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Prior to the final grading permit and the issuance
of building permits, the qualified paleontologist
shall submit to the City, a Paleontological
Resources Impact Mitigation Program (PRIMP)
for this project. The PRIMP shall include the
methods that will be used to protect
paleontological resources that may exist within
the project site, as well as procedures for
monitoring, fossil preparation and identification,
curation into a repository, and preparation of a
report at the conclusion of grading. The PRIMP
shall be consistent with the guidelines of the
Society of Vertebrate Paleontology. The City shall
not issue a grading permit for the project until the
letter and PRIMP, both referenced above, have
been received.

During construction, excavation and grading
activities in deposits with high paleontological
sensitivity shall be monitored by a paleontological
monitor as defined by the PRIMP. No monitoring
is required for excavations in deposits with no or
low paleontological sensitivity (i.e., engineered fill
soils).

If paleontological resources are encountered
during the course of ground disturbance, the
paleontological monitor shall have the authority to
temporarily redirect construction away from the
area of the find in order to assess its significance.

In the event that paleontological resources are
encountered when a paleontological monitor is
not present, work in the immediate area of the find
shall be redirected, and a paleontologist shall be
contacted to assess the find for significance.

Collected resources shall be prepared to the point
of identification, identified to the lowest taxonomic
level possible, cataloged, and curated into the
permanent collections of a scientific institution
prepared by the Applicant-hired qualified
paleontologist.

Refer to RCM WQ-1 through RCM WQ-4 under Section 4.10 below.

4.8 Greenhouse Gas Emissions
MM GHG-1: Electric Vehicle Charging. Provisions shall be made at the project site for emerging electric
Prior to issuance
of a shell building
permit and in
conjunction with
Project Applicant
/ City of Lake
Forest
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199

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Prior to issuance of tenant improvement permits
for the building, the tenant improvement plans
shall include installation of a minimum of four
electric truck charging stations at the
predesignated locations. The charging stations
shall be installed and operational prior to tenant
occupancy of the building.
the approval of
tenant
improvement
plans and
permits.

4.9 Hazards and Hazardous Materials
There are no significant impacts related to hazards and hazardous materials. No mitigation is required.

4.10 Hydrology and Water Quality
RCM WQ-1: Construction General Permit. Prior to the
issuance of a grading permit, the Construction
Contractor shall obtain coverage under the State
Water Resources Control Board (SWRCB)
National Pollutant Discharge Elimination System
(NPDES) General Permit for Stormwater
Discharges Associated with Construction and
Land Disturbance Activities (Order No. 2022-
0057-DWQ, NPDES No. CAS000002)
(Construction General Permit). This shall include
submission of Permit Registration Documents
(PRDs), including a Notice of Intent for coverage
under the permit to the SWRCB via the
Stormwater Multiple Application and Report
Tracking System (SMARTs). The Construction
Contractor shall provide the Waste Discharge
Identification Number (WDID) to the Lake Forest
Public Works Director, or designee, to
demonstrate proof of coverage under the
Construction General Permit. Project construction
shall not be initiated until a WDID is received from
the SWRCB and is provided to the City, or
designee.

Construction
Contractor / Lake
Forest Public
Works Director or
designee
Item: 9
200

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Construction.

The SWPPP shall include a construction site
monitoring program that identifies requirements
for dry weather visual observations of pollutants
at all discharge locations, and as appropriate
(depending on the Risk Level), sampling of the
site effluent and receiving waters. A Qualified
SWPPP Practitioner shall be responsible for
implementing the BMPs at the site and performing
all required monitoring and inspection/
maintenance/repair activities.

Upon completion of construction and stabilization
of the site, a Notice of Termination shall be
submitted via SMARTs.

RCM WQ-2: City of Lake Forest Municipal Code. Prior to the issuance of a grading permit, the Project
Applicant shall submit and obtain approval of an
Erosion Control Plan in compliance with Article
XIII of Chapter 8.30 of the City of Lake Forest
Municipal Code from the Lake Forest Public
Works Director, or designee. The Erosion Control
Plan shall be submitted to the City of Lake Forest
Building Official for approval by September 15
each year for projects under a grading permit. All
grading shall be undertaken in accordance with
the BMPs for pollution prevention adopted by the
City, the City’s NPDES Permit regulating
discharges into and from its Municipal Separate
Storm Sewer System (MS4), the Drainage Area
Management Plan (DAMP), and any other
conditions, requirements and water quality
management plans adopted by the City.

Additionally, the project Applicant shall adhere to
the erosion and sediment control and water
quality system maintenance requirements listed
in Section 8.30.154 of the Lake Forest Municipal
Code.

Prior to the
issuance of a
grading permit.

Project Applicant
/ Lake Forest
Public Works
Director
RCM WQ-3: Final Water Quality Management Plan. Prior to issuance of a grading permit, the project Applicant
shall submit and obtain approval of a Final Water
Quality Management Plan (WQMP) to the Lake
Forest Public Works Director, or designee. The
project shall implement project design features
identified in the Final WQMP. The Final WQMP
shall demonstrate that any proposed on-site
development plan includes BMPs for source
control, pollution prevention, site design, low
Prior to issuance
of a grading
permit.

Project Applicant
/ Lake Forest
Public Works
Director, or
designee
Item: 9
201

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Periodic maintenance of any required BMPs and
landscaped areas during project occupancy and
operation shall be in accordance with the
schedule outlined in the Final WQMP.

Item: 9
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Table 7.A: Mitigation and Monitoring Reporting Program
Draft EIR Mitigation Measures (MMs) and Regularly
Compliance Measures (RCMs) Timing
Responsible
Party /
Approving
Agency
Date
Completed
and Initials
RCM WQ-4: Final Hydrology and Hydraulic Analyses. Prior to issuance of grading permits, the project
Applicant shall submit and obtain approval of the
Final Hydrology and Hydraulic Analyses to the
Lake Forest Director of Public Works, or
designee, and the Orange County Flood Control
District (OCFCD). The Final Hydrology and
Hydraulic Analyses shall be prepared consistent
with the requirements of the Orange County
Hydrology Manual (Orange County Environment
Agency 1986) and Orange County Hydrology
Manual Addendum No. 1 (Orange County
Environment Agency 1996), or subsequent
guidance manuals. The Final Hydrology and
Hydraulic Analyses shall confirm that the on-site
storm drains, on-site detention basins, and any
other drainage structures are appropriately sized
to accommodate stormwater runoff from the
design storm so that the peak flow of stormwater
discharge from the project site is less than
existing conditions. The Final Hydrology and
Hydraulic Analyses shall also demonstrate that
the detention facilities meet the hydromodification
requirements of the Waste Discharge
Requirements for the County of Orange, Orange
County Flood Control District and the
Incorporated Cities of Orange County within the
Santa Ana Region Areawide Urban Storm Water
Runoff Orange County (North Orange County
MS4 Permit), Order R8-2009-0030, NPDES No.

CAS618030 (as amended by Order No. R8-2010-
0062). In compliance with the hydromodification
requirements, the post-project runoff discharge
volume for the 2-year storm shall not exceed that
of the predevelopment condition by more than 5
percent, and the time of concentration of postdevelopment runoff for the 2 year storm event shall not be greater than 5 percent less than that
of the predevelopment condition. The Director of
the City of Lake Forest Public Works Department,
or designee, shall ensure that the drainage
facilities specified in the Final Hydrology and
Hydraulic Analyses are incorporated into the final
project design.

Prior to issuance
of grading
permits.

Project Applicant
/ Lake Forest
Director of Public
Works, or
designee, and
the OCFCD

4.11 Land Use and Planning
There are no significant impacts related to land use and planning. No mitigation is required.

4.12 Mineral Resources
There are no significant impacts related to mineral resources. No mitigation is required.

4.13 Noise
RCM NOI-1: City of Lake Forest Municipal Code, Section

11.16.060(D). During construction, construction
activities shall be limited to between the hours of
7:00 a.m. and 8:00 p.m. Mondays through
Saturdays. No construction shall be permitted
outside of these hours or on legal City of Lake
During
construction.

Construction
Contractor / City
of Lake Forest
Item: 9
203

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RCM NOI-2: Pre-Construction Vibration Assessment. After a specific project equipment list has been
determined and prior to the issuance of a building
permit, the following actions shall be
implemented:
1) A qualified structural engineer, as approved by
the Director of Community Development, or
designee shall identify all structures that are
located within the distances established in Table
2 of Section 11.16.090 of the City’s Municipal
Code and that have the potential to be affected by
ground-borne vibration originating from the
construction; and
2) A qualified acoustical engineer shall compile a
list of proposed construction equipment and
compare to the City's accepted vibration criteria.

If it is determined that the proposed equipment
would generate vibration levels below the City's
standard of 0.3 inches per second (in/sec) peak
particle velocity (PPV), no further vibration
assessment is necessary. However, if vibration
levels would potentially exceed the City's
standard of 0.3 in/sec PPV, the Project Applicant
shall develop a Vibration Monitoring and
Construction Contingency Plan for approval by
the Director of Community Development, or
designee, to ensure that vibration levels would not
exceed the City's accepted vibration damage
criteria of 0.3 in/sec PPV. If a Vibration Monitoring
and Construction Contingency Plan is deemed
necessary, monitoring of vibration during initial
construction activities shall be required.

Monitoring results may indicate the need for more
or less intensive measurements. The Vibration
Monitoring and Construction Contingency Plan, at
the discretion of the Director of Community
Development or designee, shall include the
following items as necessary:
• Identification of structures where
monitoring would be conducted;
• A vibration monitoring schedule;
• Defined structure-specific vibration
limits;
• Photographic, elevation, and crack
surveys to document before and after
construction conditions; and
• Identification of construction
contingencies for when vibration levels
approach the limits.

After a specific
project equipment
list has been
determined and
prior to issuance
of a building
permit.

Project Applicant
/ Lake Forest
Director
Community
Development or
designee
Item: 9
204

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4.14 Population and Housing
There are no significant impacts related to population and housing. No mitigation is required.

4.15 Public Services
There are no significant impacts related to public services. No mitigation is required.

4.16 Recreation
There are no significant impacts related to recreation. No mitigation is required.

4.17 Transportation
RCM TRA-1: Development Standards Pursuant to
Section 9.160.040 of the City’s Municipal
Code. The provisions of Zoning Code Chapter

9.160.040 (Facility Design Regulations) shall be
implemented as follows:
• Prior to the issuance of the building permits
for the construction of the primary building,
the site plan and/or floor plans in the
construction drawings shall clearly show the
location of the required carpool parking stalls,
vanpool parking stalls, ride share vehicle
loading area, bicycle parking, shower
facilities, locker facilities, and commuter
information area, in accordance with the
regulations in Zoning Code Section

9.160.040.
• Prior to issuance of building permits for the
construction of the primary building, the
applicant shall retain a licensed Civil Engineer
by the State of California to prepare Civil
Street Improvement Plans for the installation
of bus shelters with solar-powered lights, bus
benches, and trash receptacles for the
existing bus stop located on the northwest
corner of the intersection of Dimension Drive
at Commercentre Drive/Enterprise Way, in
accordance with the regulations in Zoning
Code Section 9.16.040 and Orange County
Transportation Authority Guidelines.

As appropriate, the existing sidewalk shall be
widened within the existing right-of-way
Prior to the
issuance of the
building permits
and prior to
issuance of
Certificate of
Occupancy of the
building.

Project Applicant
/ City of Lake
Forest
Item: 9
205

Page 116 of 119 ends

The project Applicant shall submit these Civil
Street Improvement Plans to the City’s
Engineering Division and obtain a Public
Works Encroachment Permit to construct the
improvements to the existing bus stop.
• Prior to issuance of Certificate of Occupancy
of the building, all provisions of Chapter 9.160
shall be implemented, as approved on the
construction drawings and civil street
improvement plans, including but not limited
to, the required carpool parking stalls, vanpool
parking stalls, ride share vehicle loading area,
bicycle parking, shower facilities, locker
facilities, commuter information area, and
improvements to the existing bus stop located
on the northwest corner of the intersection of
Dimension Drive at Commercentre
Drive/Enterprise Way.

MM TRA-1: Bike Lanes. Prior to issuance of a certificate of occupancy for the proposed industrial building,
the project Applicant shall retain a licensed Civil
Engineer by the State of California to prepare Civil
Street Improvements and Signing & Striping
Plans (collectively Construction Plans) for the
implementation of bike lanes in both directions on
Commercentre Drive between Alton Parkway and
Dimension Drive. These bike lanes on
Commercentre Drive would connect the proposed
project site on Enterprise Way to the existing bike
lanes on Alton Parkway, which eventually
connects to the Irvine Transportation Center, a
multi-model transit hub including Metrolink and
Amtrak commuter train services and OCTA bus
services.

Based on a preliminary design assessment, the
Construction Plans shall include an asphalt slurry
seal of Commercentre Drive to modify the existing
lane striping for the addition of standard striped
bike lanes and green bike markings. The project
Applicant shall use these Construction Plans to
obtain a Public Works Encroachment Permit to
construct said improvements for bike lanes on
Commercentre Drive. The construction of said
improvements shall be completed per the plans
and to the satisfaction of the Public Works
Department. The project Applicant shall use these
Construction Plans to obtain a Public Works
Encroachment Permit to construct said
Prior to issuance
of a certificate of
occupancy.

Project Applicant
/ City of Lake
Forest
Item: 9
206

Page 117 of 119 ends

MM TRA-2: Pedestrian-Scale Transit Access Lighting. To
reduce vehicle miles traveled (VMT) and improve
first-/last-mile access to transit, the
applicant/developer shall install pedestrian-scale
lighting along the on-site pedestrian pathway
between the primary building entrance and the
public right-of-way, leading to the existing bus
stops. Lighting shall provide adequate nighttime
visibility for pedestrians (generally achieving a
maintained average of 1.0 foot-candle), avoid
glare, and limit spillover to adjacent properties in
accordance with Lake Forest Municipal Code
section 9.72.085(3). Fixtures shall include
automatic dusk-to-dawn controls.

Prior to issuance of building permits, a lighting plan
depicting fixture types, locations, heights, and
illumination levels shall be submitted by the
Applicant to the City for review and approval.

Prior to issuance of a certificate of occupancy, all
required lighting shall be installed and operational
and shall be maintained by the property owner for
the life of the project.

Prior to the
issuance of the
building permits.

Project Applicant
/ City of Lake
Forest

4.18 Tribal Cultural Resources
MM TCR-1: Retain a Native American Monitor Prior to
Commencement of Ground-Disturbing
Activities.

A. The project applicant/lead agency shall retain
a Native American Monitor from or approved
by the Gabrieleño Band of Mission Indians –
Kizh Nation. The monitor shall be retained
prior to the commencement of any “grounddisturbing activity” for the subject project at all project locations (i.e., both on-site and any
off-site locations that are included in the
project description/definition and/or required
in connection with the project, such as public
improvement work). “Ground-disturbing
activity” shall include, but is not limited to,
demolition, pavement removal, potholing,
auguring, grubbing, tree removal, boring,
grading, excavation, drilling, and trenching.

B. A copy of the executed monitoring
agreement shall be submitted to the lead
agency prior to the earlier of the
commencement of any ground-disturbing
activity, or the issuance of any permit
necessary to commence a ground-disturbing
activity.

C. The monitor will complete daily monitoring
logs that will provide descriptions of the
relevant ground-disturbing activities, the type
Prior to
commencement
of grounddisturbing
activities.

Project
Applicant/Lead
Agency / City of
Lake Forest
Community
Development
Department
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D. On-site tribal monitoring shall conclude upon
the later of the following (1) written
confirmation to the Kizh from a designated
point of contact for the project applicant/lead
agency that all ground-disturbing activities
and phases that may involve grounddisturbing activities on the project site or in connection with the project are complete; or
(2) prior to approval of final building permit, a
determination and written notification by the
Kizh to the project applicant/lead agency that
no future, planned construction activity
and/or development/construction phase at
the project site possesses the potential to
impact Kizh TCRs.

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A. Upon discovery of any TCRs, all construction
activities in the immediate vicinity of the
discovery shall cease (i.e., not less than the
surrounding 50 feet) and shall not resume
until the discovered TCR has been fully
assessed by the Kizh monitor and/or Kizh
archaeologist. The Kizh will recover and
retain all discovered TCRs in the form and/or
manner the Tribe deems appropriate, in the
Tribe’s sole discretion, and for any purpose
the Tribe deems appropriate, including for
educational, cultural and/or historic
purposes.

During
construction,
upon discovery of
any tribal cultural
resources.

Construction
Contractor and
Kizh monitor
and/or Kizh
archaeologist /
City of Lake
Forest
Community
Development
Department
MM TCR-3: Unanticipated Discovery of Human Remains
and Associated Funerary or Ceremonial
Objects.

A. Native American human remains are defined
in PRC 5097.98 (d)(1) as an inhumation or
cremation, and in any state of decomposition
or skeletal completeness. Funerary objects,
called associated grave goods in Public
Resources Code Section 5097.98, are also
to be treated according to this statute.

B. If Native American human remains and/or
grave goods are discovered or recognized on
the project site, then Public Resource Code
5097.9 as well as Health and Safety Code
Section 7050.5 shall be followed.

C. Human remains and grave/burial goods shall
be treated alike per California Public
Resources Code section 5097.98(d)(1) and
(2).

D. Preservation in place (i.e., avoidance) is the
preferred manner of treatment for discovered
human remains and/or burial goods.

E. Any discovery of human remains/burial
goods shall be kept confidential to prevent
further disturbance.

During
construction,
upon discovery of
human remains
or associated
funerary or
ceremonial
objects.

Construction
Contractor and
County Coroner/
City of Lake
Forest Director of
Community
Development
Department

4.19 Utilities and Service Systems
There are no significant impacts related to utilities and service systems. No mitigation is required.

4.20 Wildfire
There are no significant impacts related to wildfire. No mitigation is required.

Source: Compiled by LSA (2025).

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ATTACHMENT 2
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RESOLUTION NO. CC 2026-__

A RESOLUTION OF THE CITY COUNCIL OF THE

CITY OF LAKE FOREST, APPROVING SITE
DEVELOPMENT PERMIT 06-21-5437 FOR THE

DEMOLITION OF AN EXISTING BUILDING AND THE

CONSTRUCTION OF A NEW INDUSTRIAL BUILDING
LOCATED AT 26200 ENTERPRISE WAY
WHEREAS, on June 17, 2021, Chris Sanford of IPT Enterprise Business Center, LLC, filed an application for Use Permit 06-21-5437 for the demolition of an existing industrial building and the construction of a new industrial building located at 26200 Enterprise Way (“Project”); and
WHEREAS, on May 16, 2023, Chris Sanford of IPT Enterprise Business Center, LLC, re-filed the application as a Site Development Permit (Site Development Permit 06-21-5437) for the demolition of an existing industrial building and the construction of a new industrial building, with a maximum height of 35 feet, located at 26200 Enterprise Way; and
WHEREAS, the property is zoned Light Industrial in the Pacific Commercentre Planned Community, which requires a Site Development Permit for the development of an industrial building with a maximum height of 35 feet; and WHEREAS, the City gave notice of the public hearing at which the project would be considered by the Planning Commission by publishing a notice in a newspaper of general circulation on May 21, 2026, and by posting a notice at City Hall, mailing a notice to owners of property located within 300 feet of the project site, and emailing the interest list for this project on May 21, 2026; and WHEREAS, on June 4, 2026, the Planning Commission held a noticed public hearing at which interested persons had an opportunity to testify in support of, or opposition to, Site Development Permit 06-21-5437 and the corresponding Environmental Impact Report and at which the Planning Commission considered and approved Site Development Permit 06-21-5437 and the Project on June 5, 2026; and
WHEREAS, the IPT Enterprise Business Center LLC (Project) Final Environmental Impact Report (EIR) (SCH #2024030755) has been prepared for the Project and on June 5, 2026, the Planning Commission adopted environmental findings pursuant to the California Environmental Quality Act (CEQA), adopted a Item: 9
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Statement of Overriding Considerations, certified the Final EIR, and adopted the Mitigation Monitoring and Reporting Program (MMRP); and WHEREAS, on June 18, 2026, Doug Carstens, on behalf of “We the Meadows,” submitted a written notice of appeal in compliance with Lake Forest Municipal Code Section 2.04.110; and
WHEREAS, pursuant to Lake Forest Municipal Code Section 2.04.130, the City gave notice of the public hearing at which the appeal of the Planning Commission’s determination of the Project would be considered by the City Council by publishing a notice in a newspaper of general circulation on June 25, 2026, and by posting a notice at City Hall, mailing a notice to owners of property located within 300 feet of the project site, and emailing the interest list for this project on June 25, 2026; and
WHEREAS, on July 7, 2026, the City Council conducted a duly noticed public hearing in accordance with Lake Forest Municipal Code Section 2.04.130, to consider: adopting environmental findings pursuant to CEQA, adopting a Statement of Overriding Considerations, certifying the Final EIR, adopting the MMRP, and approving Site Development Permit 06-21-5437 for the Project, and solicited comments on the same; and
WHEREAS, on July, 7 2026, the City Council held a duly noticed public hearing in accordance with Lake Forest Municipal Code Section 2.04.130, at which interested persons had an opportunity to testify in support of, or opposition to, the appeal of the Planning Commission’s CEQA determinations and approval of Site Development Permit 06-21-5437, and at which time the Project was fully considered under a de novo standard of review; and
WHEREAS, based upon all relevant testimony from staff, the public and the City’s consultant team, on July 7, 2026, a majority of the City Council voted to adopt environmental findings pursuant to CEQA, adopt a Statement of Overriding Considerations, certify the Final EIR, and adopt the MMRP; and WHEREAS, based upon all relevant testimony from staff, the public and the City’s consultant team, on July 7, 2026, a majority of the City Council voted to approve Site Development Permit 06-21-5437 and approve the Project; and WHEREAS, all other legal prerequisites to the adoption of this Resolution have occurred.

NOW THEREFORE, THE CITY COUNCIL OF THE CITY OF LAKE FOREST DOES RESOLVE, DETERMINE, FIND AND ORDER AS FOLLOWS:

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SECTION 1. INCORPORATION OF RECITALS. The Lake Forest City Council hereby finds and determines that the Recitals above are true and correct and incorporated herein.

SECTION 2. FINDINGS. The Lake Forest City Council hereby finds, based on consideration of the whole record before it, as follows:

1. CEQA: The approval of the permit application is in compliance with the requirements of the California Environmental Quality Act.

The requirements of CEQA have been satisfied in that the IPT Enterprise Business Center LLC (Project) Final Environmental Impact Report (EIR) (SCH #2024030755) has been prepared for the Project and the City Council has adopted environmental findings, adopted a Statement of Overriding Considerations, certified the Final EIR, and adopted the MMRP concurrent with this Resolution.

2. General Plan Consistency: The use or project proposed is consistent with the General Plan.

The project site is designated Light Industrial (“LI”) on the General Plan Land Use Element Map. The LI designation “provides for a variety of light industrial uses that are non-polluting and which can co-exist with surrounding land uses and which do not create smoke, gas, dust, noise, vibration, soot, or glare which might be obnoxious or offensive to persons residing or conducting business in the City.” The proposed industrial use is consistent with the purpose and intent of the LI designation, as it is not expected to generate obnoxious or offensive conditions, as documented in detail in the various technical studies prepared for the project and included in the project’s EIR. Furthermore, the maximum allowable floor area ratio (FAR) for the LI designation is 0.6:1.0 and the proposed facility meets this requirement with a FAR of 0.43:1.0. Lastly, as detailed in the “General Plan Policy Compliance Table” (attached as “Exhibit A” and incorporated herein by reference), the project is consistent with the applicable goals and policies in the General Plan. Therefore, the proposed project, as conditioned, is consistent with the General Plan and all applicable goals and policies.

3. Zoning Code: The use, activity, or improvement(s) proposed by the application is consistent with the provisions of the Zoning Code.

The project site is located in the Light Industrial (LI) zoning district in the Pacific Commercentre Planned Community, which requires a Site Development Permit for the development of the new industrial building. The Item: 9
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LI zoning district is intended to provide for a broad range of industrial uses as specified in the Lake Forest Zoning Code Section 9.72.090 (NonResidential Land Use Matrix), column “I.” Pursuant to this Code section, the proposed office, manufacturing and warehouse uses are “Permitted Uses” in this zoning district.

With the approval of this Site Development Permit, the proposed project is in compliance with all development standards of the zoning district, including but not limited to the required minimum setbacks, maximum building height, and minimum boundary landscaping depths. Additionally, the proposed circulation and parking layout was designed in compliance with all applicable requirements in Chapter 9.168 of the Zoning Code, including but not limited to, the parking stall size requirements and the drive aisle minimum width requirements. Furthermore, the 262 off-street parking stalls proposed at the site exceed the City’s parking requirement for the proposed uses (261 parking stalls). Furthermore, as conditioned, the project will comply with the water efficient landscape requirements, in Zoning Code section 9.146.110.

Based on employment generation factors in Zoning Code Section

9.160.030(D), the proposed building is subject to Zoning Code Chapter

9.160 (Facility Design Requirements), which includes regulations related to carpool and vanpool parking stalls, bicycle parking, shower and locker facilities, a commuter information area, rideshare vehicle loading areas, and transit/bus stop shelters. The proposed site plan shows the location for the required carpool parking stalls, vanpool parking stalls, bicycle parking spaces, and rideshare loading parking stalls, in compliance with Zoning Code Chapter 9.160 requirements. Additionally, the proposed floor plan provides for the required shower facilities, locker facilities, and commuter information area also required by Zoning Code Chapter 9.160. This resolution includes conditions of approval that ensure compliance with standards in Zoning Code Chapter 9.160, as noted on the plans. In accordance with Zoning Code Section 9.160.040, this resolution also includes a condition of approval requiring the applicant to design and construct a bus shelter at the existing bus stop on the northwest corner of the intersection of Dimension Drive and Commercentre Drive/Enterprise Way. As such, the project as conditioned, is in compliance with Chapter

9.160.

Accordingly, the project, as conditioned, is consistent with the provisions of the City’s Zoning Code.

4. Compatibility: The location, size, design and operating characteristics of the proposed use will not create significant noise, traffic, or other conditions or Item: 9
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situations that may be objectionable, detrimental or incompatible with other permitted uses in the vicinity.

The project site is bordered to the north, south, and west by existing oneand two-story industrial buildings that include a mix of permitted uses, including office, manufacturing, and warehouse uses. The recently constructed Meadows residential development which consists of singlefamily residences, a senior apartment complex, and local parks, is located to the northeast/east of the project site.

This project’s EIR includes a noise and vibration study, which considered the site topography and the shielding provided by the proposed building, and the proposed 16 ft. high, 60 ft. long wall at the eastern end of the loading docks. The noise study concluded that, with compliance of the regulatory compliance measures identified in the EIR, the project’s construction and operation would not have any significant noise or vibration impacts on the surrounding uses, including the Meadows residential development.

The project’s EIR also included a traffic impact analysis (TIA), which evaluated level of service (LOS) on the intersections surrounding the project site under various scenarios, including before and after implementation of the project and other anticipated projects in the vicinity. Based on the results of this TIA, implementation of the proposed project, including the proposed off-site improvements at the five intersections, would not result in any significant impacts to the surrounding roadway system. The evaluation of the study area intersection LOS showed that the addition of project traffic would not cause an intersection operation to deteriorate below the City’s performance threshold. Additionally, as designed, all inbound and outbound truck turning movements at the study area intersections are considered feasible.

The project site is not connected to the adjacent Meadows residential development by any streets or walkways. The proposed building would be setback approximately 150-160 feet from the side/rear yard property lines of the adjacent single-family residential properties along Burwood Street.

There are no proposed modifications to the block wall and landscape buffers that separate the Meadows residential development and the industrial area.

However, the proposed project includes the installation of additional landscaping, including additional trees, along the northeastern corner of the project site, adjacent to the Meadows residential development. This new landscaping will further reduce the visibility of the project site as viewed from the Meadows residential development. Furthermore, the project is designed so that the truck dock and loading area of the proposed building are oriented Item: 9
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to the southeast (i.e., not facing the residential properties), are located over 200 feet away from the nearest residential property line, and would not be readily visible from the residences.

The proposed building materials are typical of those found in the surrounding areas, are non-reflective, and would not create unusual or isolated glare effects that would affect daytime visibility or views in the project vicinity.

Overall, the proposed building is compatible with the architecture of the existing industrial buildings in the Pacific Commercentre Planned Community. The proposed building would be constructed of architecturally enhanced tilt-up concrete panels and would be painted varying shades of gray with a blue accent. The building architecture utilizes scoring, color transitions, and windows to provide articulation to the facades of the building. The truck doors, which would be painted to match the building, would be located on the south elevation of the building, and would not be visible from the surrounding streets or residential properties.

Compatibility with surrounding uses is further achieved by additional conditions of approval that impose, among other things, a “Quiet Zone” on the internal driveway adjacent to the Meadows that provides additional operational restrictions between the hours of 10:00 p.m. and 7:00 a.m., limiting the number of truck trips to the numbers analyzed in the EIR, restricting trucks’ use of the drive aisle on the north corner of the property that leads to Bake Parkway, and adding additional sign
requirements. These conditions further ensure the peace and tranquility of the surrounding uses, particularly the adjacent residential neighborhood.

As such, based on the City’s analysis of the project, including the information in the project’s EIR, the location, size, design and operating characteristics of the proposed use will not create significant noise, traffic, or other conditions or situations that may be objectionable, detrimental or incompatible with other permitted uses in the vicinity.

5. General Welfare: The application will not result in conditions or circumstances contrary to the public health and safety and the general welfare.

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The project, as conditioned, will be in compliance with all applicable State, County, and City design, building, and other safety related laws, codes, and regulations, including, but not limited to, the California Building Code and California Fire Code. The project was reviewed by Orange County Fire Authority (OCFA) for compliance with OCFA’s codes and guidelines. This resolution includes numerous conditions of approval recommended by OCFA to ensure Code compliance and fire safety.

Additionally, the Project’s EIR included a Health Risk Assessment (HRA) (Appendix “C” of the EIR). The HRA concluded that the health risk levels to nearby sensitive receptors from project-related emissions (with the inclusion of Mitigation Measure AQ-1) of toxic air contaminants would be well below the South Coast Air Quality Management District’s (SCAQMD) HRA thresholds. As compared to the project-level thresholds of significance promulgated by SCAQMD, the cumulative emissions associated with the proposed project with implementation of MM AQ-1, combined with the mitigated emissions of the other potential future construction projects in the vicinity, would not result in a significant impact on sensitive receptors during construction. In addition, cumulative operational emissions would be below the SCAQMD's HRA thresholds. As such the HRA concludes that there will be no significant air quality impacts that would significantly affect public health.

Conditions of approval were imposed on the project to protect the public safety, health, and general welfare. Those additional conditions include a “Quiet Zone” on the internal driveway adjacent to the Meadows that provides additional operational restrictions between the hours of 10:00 p.m. and 7:00 a.m., limiting the number of truck trips to the numbers analyzed in the EIR, restricting trucks’ use of the drive aisle on the north corner of the property that leads to Bake Parkway, and adding additional sign
requirements. These additional conditions of approval will lessen noise impacts and will reduce truck traffic near residential uses.

Lastly, the project includes best management practices as required by the project’s Water Quality Management Plan, to ensure the project does not negatively impact water quality. Therefore, the application will not result in conditions or circumstances contrary to the public health and safety and the general welfare.

6. Development Fees for Provision of Public Facilities.

Pursuant to the LFMC, the development will be subject to payment of all applicable development fees at the time of building permit issuance.

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7. City Design Guidelines: The project has been reviewed in accordance with Citywide Design Guidelines and is consistent with the purpose and intent of the Guidelines.

The Citywide Design Guidelines provide general guidelines for new development in the City. These guidelines address the site’s layout, architecture/building design, and landscaping. The project site is located in the Pacific Commercentre/Baker Ranch Business Park Area. As stated in the Guidelines: “The Design Guidelines should be viewed as qualitative rather than mandatory development standards and may be interpreted with some flexibility.” Accordingly, a project does not need to comply with every design guideline if the project is consistent with the purpose and intent of the Design Guidelines. The project complies with the applicable design guidelines, as summarized below:
• Transitions in Land Use section of the Design Guidelines - The building would be located over 150 feet from the closest property line to a singlefamily residence, and an approximately 60-foot-wide (minimum) on-site landscaped slope would buffer the industrial project from the shared property line of the adjacent single-family residential community. • Architecture and Building Design section of the Design Guidelines - The building architecture would utilize scoring, color transitions, and windows to provide articulation to long facades of the building to create visual interest.
• Architecture and Building Design section of the Design Guidelines - The building architecture features low, medium, and high elevation elements. • Architecture and Building Design section of the Design Guidelines - The main building entrance, which faces Enterprise Way, would be emphasized with vertical and horizontal bands, windows, and decorative light sconces. Building articulation would be provided at the entrance by changes in the façade planes and height variation in roof line. These architectural features make the main entrance easily identifiable and the architectural focal point of the building .
• Architecture and Building Design section of the Design Guidelines - The building has been designed with a built-in rooftop well to screen the rooftop mechanical equipment.
• Vehicular Access/Circulation/Parking section of the Design Guidelines - The vehicular entrances to the site would be flanked by landscaping that includes trees, hedges and landscaped berms.

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• Parking Lot Landscaping section of the Design Guidelines - The project would maintain and/or enhance the existing perimeter landscaping around the entire site, which screens the parking areas.

Accordingly, the project has been reviewed in accordance with the Citywide Design Guidelines and is consistent with the purpose and intent of the Guidelines.

SECTION 3. CITY COUNCIL ACTIONS. The City Council hereby takes the following actions:

1. In accordance with Lake Forest Municipal Code Section 2.04.130, the City Council hereby denies the appeal and approves Site Development Permit 06-21-5437 for the demolition of an existing industrial building and the construction of a new industrial building located at 26200 Enterprise Way subject to the following conditions:

CONDITIONS OF APPROVAL:

SDP 06-21-5437
The following Conditions of Approval shall apply to the applicant for the permit or owner of the project, whichever is appropriate for the condition.

INDEMNIFICATION

1. The applicant shall indemnify, protect, defend, and hold the City, and/or any of its officials, officers, employees, agents, departments, agencies, and instrumentalities thereof, harmless from any and all claims, demands, lawsuits, writs of mandamus, and other actions and proceedings (whether legal, equitable, declaratory, administrative or adjudicatory in nature), and alternative dispute resolution procedures (including, but not limited to arbitrations, mediations, and other such procedures), judgments, orders, and decisions (collectively “Actions”), brought against the City, and/or any of its officials, officers, employees, agents, departments, agencies, and instrumentalities thereof, that challenge, attack, or seek to modify, set aside, void, or annul, any action of, or any permit or approval issued by the City and/or any of its officials, officers, employees, agents, departments, agencies, and instrumentalities thereof (including actions approved by the voters of the City) for or concerning the project, whether such Actions are brought under the Ralph M. Brown Act, California Environmental Quality Act, the Planning and Zoning Law, the Subdivision Map Act, Community Redevelopment Law, Code of Civil Procedure Sections 1085 or 1094.5, or any other federal, state, or local constitution, statute, law, ordinance, charter, Item: 9
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rule, regulation, or any decision of a court of competent jurisdiction. It is expressly agreed that the City shall have the right to approve, which approval will not be unreasonably withheld, the legal counsel providing the City’s defense, and that applicant shall reimburse City for any costs and expenses directly and necessarily incurred by the City in the course of the defense. City shall promptly notify the applicant of any Action brought and City shall cooperate with applicant in the defense of the Action.

2. Expiration: Site Development Permit No. 06-21-5437 shall expire 24 months from the date of this approval if either building permits for the project have not been issued or if the use has not been established, and an extension of time has not been approved by the Director of Community Development. (PLNG)

3. The Planning Division processes discretionary applications on a deposit basis. Deposit funds are provided by applicants/developers to cover the actual costs associated with staff time and resources utilized in processing an application. If, at any time, the cost to process the application exceeds the deposit on file, additional funds shall be deposited by the applicant/developer. A final accounting for this project will be prepared following the City Council’s decision on the project and if needed, a request for additional funds will be provided to the applicant. Should additional funds be required, the applicant shall submit a check or money order, payable to the City of Lake Forest, for the additional funds. (PLNG) The applicant shall obtain a grading permit issued by the Public Works Department. Prior to issuance of a grading permit, the following shall be completed:

4. The applicant shall submit to the Public Works Department for review and approval a site-specific final drainage study, including supporting hydraulic and hydrological data to the Public Works Department for approval. The Study shall include all off-site and on-site storm water runoff impacts. In addition, the Study shall identify the project’s contribution to storm water runoff and shall provide locations and sizes of catch basins and system connections points and all downstream drainage mitigation measures. The Drainage Plan shall make provisions to ensure that the on-site drainage shall be in compliance with the NPDES guidelines. (PW)

5. The applicant shall submit to the Public Works Department for review and approval a final grading plan showing building footprints, new and revised pads and elevations of finished grades, drainage routes, retaining walls, erosion control, slope easements and other pertinent information. The plans must Item: 9
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include all applicable plan sheets listed below. The final plan shall be 24” x 36”, ink on mylar, with elevations to nearest 0.01-foot, scale 1” = 20’ and provided electronically. A plan check deposit shall be posted prior to checking and total checking fees, based on City’s consultant’s charges and City’s administrative costs shall be paid prior to its approval. The Grading Plan shall make provisions to ensure that the on-site drainage shall be in compliance with the NPDES guidelines. a. Title Sheet
b. General and other applicable notes.
c. Grading plan.
d. Demolition plan.
e. Erosion control plan.
f. Drainage plans and details.
g. Existing drainage facilities.
h. Typical sections at adjoining properties showing all details of drainage. i. Landscape and Irrigation (PW)

6. The applicant shall submit to the Public Works Department for review and approval a geotechnical report that addresses all applicable project parameters (i.e., site drainage, structural drainage, structural setbacks, infiltration capabilities). (PW)

7. The applicant shall submit to the Public Works Department for review and approval Street Improvement Plans showing all proposed street grading and drainage improvements within the public right-of-way. The Plan shall show all proposed improvements fronting the project and shall clearly depict the limits of construction. (PW)

8. The applicant shall demonstrate to the Public Works Department that coverage has been obtained under California’s General Permit for Storm Water Discharge Associated with Industrial Activity by providing a copy of the Notice of Intent (NOI) submitted to the State Water Resources Control Board and a copy of the subsequent notification of the issuance of a Waste Discharge Identification (WDID) Number or provide documentation that the WDID threshold requirement does not require a NOI thus not requiring a WDID. (PW)

9. If the project meets or exceeds the WDID threshold, the applicant shall demonstrate that coverage has been obtained under California’s General Permit for Stormwater Discharges Associated with Control Activity by providing a copy of the Notice of Intent (NOI) submitted to the State Water Resources Control Board and a copy of the subsequent notification of the issuance of a Waste Discharge Identification (WDID) Number to the Lake Forest Development Services Department. The applicant shall prepare and implement a Storm Water Pollution Prevention Plan (SWPPP). A copy of the Item: 9
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SWPPP shall be kept at the project site and shall be available for review on request. (PW)

10. The applicant shall submit to the Public Works Department for review and approval a Water Quality Management Plan that:
a. Adheres to the City’s water quality requirements for land development which are documented on the City’s website.
(https://www.lakeforestca.gov/departments/public_works/environmental_ compliance/water_quality_requirements_for_land_development.php) b. Addresses Site Design BMPs such as minimizing impervious areas, maximizing permeability, minimizing directly connected impervious areas, creating reduced or “zero discharge” areas, and conserving natural areas. c. Incorporates the applicable Routine Source Control BMPs as defined in the Local Implementation Plan (LIP).
d. Incorporates Treatment Control BMPs as defined in the LIP. e. Generally describes the long-term operation and maintenance requirements for the Treatment Control BMPs.
f. Identifies the entity that will be responsible for long-term operation and maintenance of the Treatment Control BMPs.
g. Describes the mechanism for funding the long-term operation and maintenance of the Treatment Control BMPs. (PW)

11. The applicant shall submit to the Public Works Department for review and approval a precise landscape and irrigation construction plan prepared by a licensed landscape architect for the project consistent with the landscape plans approved by the City Council. The plans shall also include new landscaping in any existing landscape areas where the landscaping has not been maintained. The landscape and irrigation plans shall be in compliance with the requirements of the City’s Water Efficient Landscape regulations (LFMC section 9.146.110) and the City’s Guidelines for Implementation of the Water Efficient Landscape Ordinance. (PW)

12. The construction contractor shall prepare and submit a haul route plan for construction traffic for review and approval by the Public Works Department. (PW)

13. Prior to submittal of any fire master plans or architectural plans to the OCFA, the applicant or responsible party shall attend a pre-submittal meeting with an OCFA plan reviewer. Call OCFA Planning & Development Services at Item: 9
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714-573-6108 at least two weeks in advance to arrange for scheduling and payment for the pre-submittal meeting. (OCFA)

14. The applicant or responsible party shall submit the plan(s) listed below to the Orange County Fire Authority (OCFA) for review and approval. a) Fire master plan (service code PR145). Fire master plan shall include the proposed gates. (OCFA)

15. Irrevocable reciprocal access easements for emergency access purposes to the benefit of the City of Lake Forest shall be recorded concurrently with the final map or, where no final map is required, prior to approval of the fire master plan. (OCFA)

16. The applicant or responsible party shall arrange with the appropriate city, county, or state public works department or agency for installation of traffic pre-emption devices on each traffic signal installed, relocated, or similarly modified as part of this project. (OCFA)

17. The project Applicant/Developer shall provide a letter to the Director of Community Development Department, or designee, stating that they have retained a qualified paleontologist (defined as a practicing paleontologist who is recognized in the paleontological community and proficient in vertebrate paleontology) who is listed on the County of Orange list of certified paleontologists.

The qualified paleontologist shall submit to the City, a Paleontological Resources Impact Mitigation Program (PRIMP) for this project. The PRIMP shall include the methods that will be used to protect paleontological resources that may exist within the project site, as well as procedures for monitoring, fossil preparation and identification, curation into a repository, and preparation of a report at the conclusion of grading. The PRIMP shall be consistent with the guidelines of the Society of Vertebrate Paleontology. The City shall not issue a grading permit for the project until the letter and PRIMP, both referenced above, have been received. (MM GEO-3)

18. The Construction Contractor shall obtain coverage under the State Water Resources Control Board (SWRCB) National Pollutant Discharge Elimination System (NPDES) General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities (Order No. 2022-0057-DWQ, NPDES No. CAS000002) (Construction General Permit). This shall include submission of Permit Registration Documents (PRDs), including a Notice of Intent for coverage under the permit to the SWRCB via the Stormwater Multiple Application and Report Tracking System (SMARTs). The Item: 9
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Construction Contractor shall provide the Waste Discharge Identification Number (WDID) to the Lake Forest Public Works Director, or designee, to demonstrate proof of coverage under the Construction General Permit.

Project construction shall not be initiated until a WDID is received from the SWRCB and is provided to the City, or designee.

Best Management Practices (BMPs) for erosion and sediment control, site management/housekeeping/waste management, management of non-storm water discharges, run-on and runoff controls, and BMP
inspection/maintenance/repair activities. BMP implementation shall be consistent with the BMP requirements in the most recent version of the California Stormwater Quality Association’s Stormwater Best Management Handbook: Construction.

The SWPPP shall include a construction site monitoring program that identifies requirements for dry weather visual observations of pollutants at all discharge locations, and as appropriate (depending on the Risk Level), sampling of the site effluent and receiving waters. A Qualified SWPPP Practitioner shall be responsible for implementing the BMPs at the site and performing all required monitoring and inspection/maintenance/repair activities.

Upon completion of construction and stabilization of the site, a Notice of Termination shall be submitted via SMARTs. (RCM WQ-1)

19. The Project Applicant shall submit and obtain approval of an Erosion Control Plan in compliance with Article XIII of Chapter 8.30 of the City of Lake Forest Municipal Code from the Lake Forest Public Works Director, or designee.

The Erosion Control Plan shall be submitted to the City of Lake Forest Building Official for approval by September 15 each year for projects under a grading permit. All grading shall be undertaken in accordance with the BMPs for pollution prevention adopted by the City, the City’s NPDES Permit regulating discharges into and from its Municipal Separate Storm Sewer System (MS4), the Drainage Area Management Plan (DAMP), and any other conditions, requirements and water quality management plans adopted by the City. Additionally, the project Applicant shall adhere to the erosion and sediment control and water quality system maintenance requirements listed in Section 8.30.154 of the Lake Forest Municipal Code. (RCM WQ-2)

20. The project Applicant shall submit and obtain approval of a Final Water Quality Management Plan (WQMP) to the Lake Forest Public Works Director, or designee. The project shall implement project design features identified in Item: 9
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the Final WQMP. The Final WQMP shall demonstrate that any proposed onsite development plan includes BMPs for source control, pollution prevention, site design, low impact development (LID) implementation, and structural treatment control. BMPs shall be designed and implemented to address 303(d) listed pollutants and retain the project site’s minimum design capture volume and hydromodification volume to ensure that post-development storm water runoff volume or time of concentration does not exceed predevelopment storm water runoff by more than 10 percent of the 2-year peak flow in accordance with the Santa Ana Regional Water Quality Control Board Order Number R8-2009-0030, NPDES Permit No. CAS618030, as amended by Order No. R8-2010-0062, also known as the North Orange County MS4 permit. The proposed LID BMPs specified in the Final WQMP shall be incorporated into the grading and development plans submitted to the City of Lake Forest for review and approval. Periodic maintenance of any required BMPs and landscaped areas during project occupancy and operation shall be in accordance with the schedule outlined in the Final WQMP. (RCM WQ3)

21. The project Applicant shall submit and obtain approval of the Final Hydrology and Hydraulic Analyses to the Lake Forest Director of Public Works, or designee, and the Orange County Flood Control District (OCFCD). The Final Hydrology and Hydraulic Analyses shall be prepared consistent with the requirements of the Orange County Hydrology Manual (Orange County Environment Agency 1986) and Orange County Hydrology Manual Addendum No. 1 (Orange County Environment Agency 1996), or subsequent guidance manuals. The Final Hydrology and Hydraulic Analyses shall confirm that the on-site storm drains, on-site detention basins, and any other drainage structures are appropriately sized to accommodate stormwater runoff from the design storm so that the peak flow of stormwater discharge from the project site is less than existing conditions. The Final Hydrology and Hydraulic Analyses shall also demonstrate that the detention facilities meet the hydromodification requirements of the Waste Discharge Requirements for the County of Orange, Orange County Flood Control District and the Incorporated Cities of Orange County within the Santa Ana Region Areawide Urban Storm Water Runoff Orange County (North Orange County MS4 Permit), Order R8-2009-0030, NPDES No. CAS618030 (as amended by Order No. R8-2010-0062). In compliance with the hydromodification requirements, the post-project runoff discharge volume for the 2-year storm shall not exceed that of the predevelopment condition by more than 5 percent, and the time of concentration of post-development runoff for the 2 year storm event shall not be greater than 5 percent less than that of the predevelopment condition. The Director of the City of Lake Forest Public Works Department, or designee, shall ensure that the drainage facilities Item: 9
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specified in the Final Hydrology and Hydraulic Analyses are incorporated into the final project design. (RCM WQ-4)

22. The project applicant/lead agency shall retain a Native American Monitor from or approved by the Gabrieleño Band of Mission Indians – Kizh Nation.

The monitor shall be retained prior to the commencement of any “grounddisturbing activity” for the subject project at all project locations (i.e., both onsite and any off-site locations that are included in the project description/definition and/or required in connection with the project, such as public improvement work). “Ground-disturbing activity” shall include, but is not limited to, demolition, pavement removal, potholing, auguring, grubbing, tree removal, boring, grading, excavation, drilling, and trenching.

A copy of the executed monitoring agreement shall be submitted to the lead agency prior to the earlier of the commencement of any ground-disturbing activity, or the issuance of any permit necessary to commence a grounddisturbing activity.

The monitor will complete daily monitoring logs that will provide descriptions of the relevant ground-disturbing activities, the type of construction activities performed, locations of ground-disturbing activities, soil types, culturalrelated materials, and any other facts, conditions, materials, or discoveries of significance to the Tribe. Monitor logs will identify and describe any discovered TCRs, including but not limited to, Native American cultural and historical artifacts, remains, places of significance, etc., (collectively, tribal cultural resources, or “TCR”), as well as any discovered Native American (ancestral) human remains and burial goods. Copies of monitor logs will be provided to the project applicant/lead agency upon written request to the Tribe. (MM TCR-1)
Prior to the final inspection for the grading permit, the following shall be completed:

23. The project Applicant shall provide final project plans to applicable City of Lake Forest (City) staff for review and approval showing that the project, including site preparation and construction of proposed buildings, has been designed and will be constructed in conformance with applicable provisions of the most current California Building Code at the time of City review, the City’s Building Code, and the specifications cited in the Geotechnical Investigation, prepared by Southern California Geotechnical, dated November 2021. (MM GEO-1)
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24. The Project Geotechnical Consultant shall submit a Final Testing and Observation Geotechnical Report for Rough Grading to the City of Lake Forest Director of Public Works/City Engineer, or designee. (MM GEO-1) The applicant shall obtain a building permit issued by the Building Division. Prior to issuance of any building permits for the construction of the building, the following shall be completed:

25. The final Site Development Permit conditions of approval shall be printed on each plan set submitted for building permits. (PLNG)

26. The applicant or responsible party shall submit the plan(s) listed below, if applicable, to the Orange County Fire Authority (OCFA) for review and approval.
a. architectural (service codes PR200-PR285), when required by the OCFA “Plan Submittal Criteria Form”
b. architectural (service codes PR264-PR272)
c. architectural (service codes PR212-PR220, abbreviated review) d. alternative methods and materials (AM&M) request (service code PR910), if any portion of the structure will be occupied prior to completion of the entire structure. Phased occupancy AM&M requests shall accompany the architectural submittal;
e. tanks storing hazardous materials (service codes PR300-PR305); f. hazardous materials compliance and chemical classification (service codes PR315-PR328);
g. hazardous equipment, processes, or operations (service codes PR345- PR360);
h. high-piled storage (service code PR330);
i. refrigeration and vapor detection/alarm system (service codes PR340 and PR500-PR520), if required by the Refrigeration Disclosure worksheet in OCFA guideline G-02 or the California Fire or Mechanical Codes; j. battery (service code PR375), for any system containing an aggregate quantity of electrolyte in excess of 50 gallons;
k. smoke control rational analysis, report, and other required documentation (service codes PR380-PR382).
l. emergency responder radio system design (service code PR928); this submittal may be deferred when acceptable to the Building Department, Item: 9
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but the required conduit must be installed prior to concealing interior construction;
m. underground piping for private hydrants and fire sprinkler systems (service code PR470-PR475);
n. underground piping (service code PR470-PR475), if private hydrants are installed/modified or a fire sprinkler system is required by code or installed voluntarily;
o. fire sprinkler system (service codes PR400-PR465);
p. alternate methods and materials (AM&M) request (PR910). (OCFA)

27. The applicant or responsible party shall enter into a secured fire protection agreement with OCFA Strategic Services (714-573-6199) to mitigate additional fire service impacts resulting from the project. (OCFA)

28. The applicant shall submit and obtain approval of a Public Works encroachment permit for street improvements and traffic signal modification plans, collectively known as construction plans, for the following five intersections as summarized below and shown on the plans approved by the City Council.
a. Bake Parkway/Commercentre Drive (Exhibit 1-1 of the approved plans). Modifications shall be made to the traffic signal to accommodate protected eastbound and westbound left-turn phasing (from split phasing). Lane geometrics shall be modified for the westbound approach to accommodate dual left-turn lanes and a shared through/right-turn lane. Additionally, modifications shall be made to the traffic signal equipment.
b. Dimension Drive/Bake Parkway (Exhibit 5-1 of the approved plans).

Modifications shall be made to the median to accommodate a 430-foot westbound left-turn lane. Additionally, modifications shall be made to the traffic signal equipment.
c. Dimension Drive/Commercentre Drive – Enterprise Way (Exhibit 3-2 of the approved plans). Modifications shall be made to the traffic signal to accommodate protected eastbound and westbound left-turn phasing (from permissive phase). The curb radius of the southeast corner at this intersection shall be modified to accommodate wheelbase-67 (WB67) truck turns (northbound right turn). Additionally, modifications shall be made to the traffic signal equipment.
d. Lake Forest Drive/Dimension Drive (Exhibit 6-1 of the approved plans).

Modifications shall be made to accommodate a 250-foot northbound Item: 9
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left-turn lane and a 205-foot eastbound left-turn lane. Additionally, modifications shall be made to the traffic signal equipment. e. Lake Forest Drive/Rancho Parkway (Exhibit 4-2 of the approved plans).

Modifications shall be made to accommodate a new 225-foot northbound right-turn lane, a 470-foot northbound left-turn lane, and a 440-foot southbound left-turn lane. Additionally, modifications shall be made to the traffic signal equipment.

Said construction plans shall be signed and stamped by a California Licensed Civil Engineer and submitted for review and approval by the Public Works Director or designee.

In the event that multiple development projects are conditioned to complete the same off-site improvements, the responsibility to design the improvements shall rest with the developer that proceeds with development first, as determined by issuance of a building permit.

Nothing in this condition shall preclude the respective developers from entering into private cost-sharing agreement; but the City shall not be a party to or responsible for enforcement of such agreements. (TENG)

29. All applicable development impact fees shall be paid to the appropriate agencies. (BLDG)

30. A “Landscape Documentation Package” and “Landscape Submittal sheet”, which shall include the required Water Efficient Landscape worksheets as described in the City’s Water Efficient Landscape Guidelines, and a signed/stamped Certificate of Landscape Design certifying that the proposed landscaping will be in compliance with the City's Water Efficient Landscape Ordinance, shall be included with the landscape and irrigation plan set and submitted for review and approval. (LFMC Sec. 9.146.110) (PLNG)

31. Phased occupancy of this structure shall be permitted only with prior approval from OCFA and the Building Official. Requests for phased occupancy shall be submitted for evaluation by OCFA as an alternate materials and methods proposal (PR910) accompanying the architectural submittal. Such requests shall be made prior to start of construction only. (OCFA)

32. The project applicant shall provide written evidence that the construction drawings include all required building improvements to accommodate the certification through the LEED Volume Program. (PLNG)

33. The project Applicant shall submit construction plans to the City of Lake Forest verifying that all construction equipment used during construction of Item: 9
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the project shall be equipped with Tier 4 Interim engines or the most effective Verified Diesel Emission Control Strategies (VDECS) available for the engine type (Tier 4 engines automatically meet this requirement as certified by the California Air Resources Board (CARB). During construction activities, the equipment shall be properly maintained and tuned in accordance with manufacturer specifications. (MM-AQ-1)

34. The Project Applicant shall submit construction plans to the City of Lake Forest that state that the project shall utilize “Super-Compliant” low volatile organic compounds (VOC) paints for nonresidential interior and exterior surfaces and low VOC paint for parking lot surfaces. Super-Compliant low VOC paints have been reformulated to exceed the regulatory VOC limits put forth by SCAQMD Rule 1113. Super-Compliant low VOC paints shall be no more than 10 grams per liter (g/L) of VOC. (MM-AQ-2)

35. The project Applicant shall consult with the City on the status of Western Realco Projects 1 and 2. If in this consultation, the City identifies that the construction schedule of Western Realco Projects 1 and 2, and the IPT Enterprise Business Center LLC Project (proposed project) will be under construction at the same time, the proposed project shall equip all construction equipment during the overlapping period with Tier 4 Final engines or the most effective Verified Diesel Emission Control Strategies (VDECS) available for the engine type (Tier 4 engines automatically meet this requirement) as certified by the California Air Resources Board. The equipment shall be properly maintained and tuned in accordance with manufacturer specifications. The project Applicant shall submit construction plans to the City of Lake Forest denoting the projected equipment Tier rating that will be used during the construction period. (MM-AQ-3)

36. Regulatory compliance measures RCM CUL-1 and RCM CUL-2, documented in the EIR shall be documented on the grading plans. (RCM CUL-1/RCM CUL-2)

37. The project Applicant/Developer shall retain the services of a licensed corrosion engineer to conduct additional site testing and final design evaluation regarding the possible on-site presence of significant volumes of corrosive soils. At a minimum, the corrosion engineer shall (1) verify the soluble sulfate concentrations of the soils that are present at pad grade within the building areas at the completion of rough grading; (2) provide detailed corrosion protection measures for cast iron and/or ductile iron pipes, as necessary; (3) confirm that soluble sulfates and chloride levels in the onsite soils do not warrant specialized concrete mix design; and (4) confirm Item: 9
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that nitrates present in the on-site soil do not warrant protection for copper materials.

The Director of the City of Lake Forest Public Works Department, or designee, shall verify that the project plans incorporate the corrosion protection measures of the corrosion engineer. (MM GEO-2)

38. A report of findings shall be prepared to document the results of the monitoring program prepared by the Applicant-hired qualified paleontologist.

The report shall be provided to the Director of Community Development, or designee. (MM GEO-3)

39. The construction plan set shall:
a) Provide for installation of all necessary infrastructure, including conduit, wiring, and sufficient electrical capacity, to support the future installation of on-site electric truck charging stations;
b) Designate sufficient space to accommodate a minimum of four electric trucks charging simultaneously. (MM GHG-1)

40. After a specific project equipment list has been determined and prior to the issuance of a building permit, the following actions shall be implemented 1) A qualified structural engineer, as approved by the Director of Community Development, or designee shall identify all structures that are located within the distances established in Table 2 of Section 11.16.090 of the City’s Municipal Code and that have the potential to be affected by ground-borne vibration originating from the construction; and
2) A qualified acoustical engineer shall compile a list of proposed construction equipment and compare to the City's accepted vibration criteria. If it is determined that the proposed equipment would generate vibration levels below the City's standard of 0.3 inches per second (in/sec) peak particle velocity (PPV), no further vibration assessment is necessary.

However, if vibration levels would potentially exceed the City's standard of

0.3 in/sec PPV, the Project Applicant shall develop a Vibration Monitoring and Construction Contingency Plan for approval by the Director of Community Development, or designee, to ensure that vibration levels would not exceed the City's accepted vibration damage criteria of 0.3 in/sec PPV.

If a Vibration Monitoring and Construction Contingency Plan is deemed necessary, monitoring of vibration during initial construction activities shall be required. Monitoring results may indicate the need for more or less intensive measurements. The Vibration Monitoring and Construction Contingency Plan, at the discretion of the Director of Community Development or designee, shall include the following items as necessary:

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Identification of structures where monitoring would be conducted; • A vibration monitoring schedule;
• Defined structure-specific vibration limits;
• Photographic, elevation, and crack surveys to document before and after construction conditions; and
• Identification of construction contingencies for when vibration levels approach the limits.

When vibration levels approach the limits specified in Section 11.16.090 of the City’s Municipal Code, construction shall be suspended and contingencies identified in the approved Vibration Monitoring and Construction Contingency Plan shall be implemented as necessary to lower vibration levels, which could include shielding or protecting the affected building from potential vibration impacts as a possible alternative to changing construction methods. (RCM NOI-2)

41. The site plan and/or floor plans in the construction drawings shall clearly show the location of the required carpool parking stalls, vanpool parking stalls, ride share vehicle loading area, bicycle parking, shower facilities, locker facilities, and commuter information area, in accordance with the regulations in Zoning Code Section 9.160.040. (RCM TRA-1)

42. The applicant shall retain a licensed Civil Engineer by the State of California to prepare Civil Street Improvement Plans for the installation of a bus shelter with solar-powered lights, a bus bench, and a trash receptacle for the existing bus stop located on the northwest corner of the intersection of Dimension Drive at Commercentre Drive/Enterprise Way, in accordance with the regulations in Zoning Code Section 9.16.040 and Orange County Transportation Authority Guidelines.

The bus stop improvements shall be designed in accordance to the standards provided in the Orange County Transportation Authority (OCTA) Transit-Supportive Design Guidelines (June 30, 2021 or latest edition). As appropriate, the existing sidewalk shall be widened within the existing rightof-way (ROW) to a minimum eight feet wide to accommodate wheelchair bus boardings. If that is not feasible due to ROW constraints, then the sidewalk shall be widened to greatest extent practical.

43. To reduce vehicle miles traveled (VMT) and improve first-/last-mile access to transit, the applicant/developer shall install pedestrian-scale lighting along the on-site pedestrian pathway between the primary building entrance and the public right-of-way, leading to the existing bus stops. Lighting shall provide adequate nighttime visibility for pedestrians (generally achieving a maintained average of 1.0 foot-candle), avoid glare, and limit spillover to adjacent properties in accordance with Lake Forest Municipal Code section

9.72.085(3). Fixtures shall include automatic dusk-to-dawn controls. A lighting plan depicting fixture types, locations, heights, and illumination levels shall be submitted by the Applicant to the City for review and approval. (MM TRA-2)

44. On-site tribal monitoring shall conclude upon the later of the following: (1) written confirmation to the Kizh from a designated point of contact for the project applicant/lead agency that all ground-disturbing activities and phases that may involve ground-disturbing activities on the project site or in connection with the project are complete; or (2) prior to approval of final building permit, a determination and written notification by the Kizh to the project applicant/lead agency that no future, planned construction activity and/or development/construction phase at the project site possesses the potential to impact Kizh TCRs. (MM TCR-1)
Within 3 days of the start of any construction, vegetation clearing, or grading activities (including disking and demolition), the following shall be completed:

45. If construction/ground disturbing activities, including demolition, occurs between February 1 and August 31, a Qualified Biologist shall conduct a pre-construction clearance survey for nesting birds within 3 days of the start of any construction, vegetation clearing, or grading activities (including disking and demolition) to ensure that no nesting birds are disturbed during construction. The Qualified Biologist shall be retained by the Construction Contractor. The Qualified Biologist conducting the clearance survey shall document a negative survey with a brief letter report indicating that no impacts to active avian nests would occur. If an active avian nest is discovered during the pre-construction clearance survey, construction activities shall stay outside of a no-disturbance buffer. In general, the nodisturbance buffer shall be a minimum of 50 feet for passerines and 250 feet for raptors. However, a species’ sensitivity to disturbance can vary among species, the level of noise or construction disturbance, and the line of sight between the nest and the disturbance. Limits of construction to avoid an active nest shall be established in the field with flagging, fencing, or other appropriate barriers; and construction personnel shall be instructed on the sensitivity of nest areas. A biological monitor, with experience in monitoring Item: 9
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active nests, shall be present to delineate the boundaries of the buffer area and to monitor daily all active nests to observe the efficacy of the nodisturbance buffers and to document any new nesting occurrences to ensure that nesting behavior is not adversely affected by the construction activity.

Adversely affected nesting behavior, as determined by the biological monitor, includes, but is not limited to, disrupting reproductive behavior, nest abandonment, and/or prolonged absences of parents while incubating eggs.

Once the young have fledged and left the nest, or the nest otherwise becomes inactive under natural conditions, construction, vegetation clearing, or grading activities (including disking and demolition) within the buffer area can occur. Field memorandums shall be prepared by the biological monitor within 24 hours of each day of monitoring and shall be submitted to the City of Lake Forest to document compliance with the applicable resource protection measures. (RCM BIO-1)
During grading and construction of the project, the following shall be completed:

46. Before commencement of construction, the applicant or responsible party shall attend a pre-construction meeting with an OCFA inspector. Call OCFA Inspection Scheduling at 714-573-6150 at least five days in advance to schedule and pay for the pre-construction meeting. (OCFA)

47. After installation of required fire access roadways and hydrants, the applicant shall receive clearance from the OCFA prior to bringing combustible building materials on-site. Call OCFA Inspection Scheduling at 714-573-6150 with the Service Request number of the approved fire master plan at least five days in advance to schedule the lumber drop inspection. (OCFA)

48. Construction activities shall be limited to between the hours of 7:00 a.m. and 8:00 p.m. Mondays through Saturdays. No construction shall be permitted outside of these hours or on legal City of Lake Forest holidays, without a specific exemption issued by the City of Lake Forest. (RCM NOI-1)

49. Project construction activities shall be required to comply with the standard SCAQMD rules and requirements for fugitive dust control, which includes, but is not limited to:
a. All active construction areas shall be watered a minimum of two (2) times daily;
b. Speed on unpaved roads shall be less than 15 mph;
c. Any visible dirt deposition on any public roadway shall be swept or washed at the site access points within 30 minutes;
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d. Any on-site stockpiles of debris, dirt or other dusty material shall be covered or watered twice daily;
e. All operations on any unpaved surface shall be suspended if winds exceed 15 mph;
f. Access points shall be washed or swept daily;
g. Construction sites shall be sandbagged for erosion control; h. Nontoxic chemical soil stabilizers shall be applied according to manufacturers’ specifications to all inactive construction areas (previously graded areas inactive for 10 days or more); i. All trucks hauling dirt, sand, soil, or other loose materials shall be covered, and maintain at least 2 feet of freeboard space in accordance with the requirements of California Vehicle Code (CVC) section 23114; j. Unpaved and gravel construction access roads shall be paved or have gravel at least 100 feet onto the site from the main road and use gravel aprons at truck exits;
k. The ground cover of disturbed areas shall be replaced as quickly possible;
l. A fugitive dust control plan shall be prepared and submitted to SCAQMD prior to the start of construction. (PW)

50. Prior to concealing interior construction, the applicant or responsible party shall submit and obtain approval of the plan(s) listed below to the OCFA for review and approval:
a. sprinkler monitoring system (service code PR500)
b. fire alarm system (service code PR500-PR520)
c. fire sprinkler system (service codes PR430-PR455).
d. hood and duct extinguishing system (service code PR335) (OCFA)

51. In the event that archaeological resources are discovered during excavation, grading, or construction activities, work shall cease within 100 feet of the find until a qualified archaeologist from the Orange County List of Qualified Archaeologists has evaluated the find in accordance with federal, State, and local guidelines to determine whether the find constitutes a “unique archaeological resource,” as defined in Section 21083.2(g) of the California Public Resources Code (PRC). Personnel of the proposed project shall not collect or move any archaeological materials and associated materials.

Construction activity may continue unimpeded beyond 100 feet from the find on other portions of the project site. The found deposits shall be treated in Item: 9
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accordance with federal, State, and local guidelines, including those set forth in PRC Section 21083.2. Prior to issuance of a grading permit, the Director of Community Development, or designee, shall ensure that this regulatory compliance measure is documented on the grading plans. (RCM CUL-1)

52. If human remains are encountered, State Health and Safety Code Section 7050.5 states that no further disturbance shall occur until the County Coroner has made a determination of origin and disposition pursuant to State PRC Section 5097.98. The County Coroner must be notified of the find immediately. If the remains are determined to be Native American, the County Coroner would notify the Native American Heritage Commission (NAHC), which would determine and notify a Most Likely Descendant (MLD).

Prior to issuance of a grading permit, the Director of Community Development, or designee, shall ensure that this regulatory compliance measure is documented on the grading plans. (RCM CUL-2)

53. During grading, an on-site inspection shall be conducted by the Applicanthired Project Geotechnical Consultant and the City of Lake Forest Director of Public Works/ City Engineer, or designee, to ensure compliance with geotechnical specifications as incorporated into project plans. (MM GEO-1)

54. During grading, on-site inspection shall be conducted by the Project Geotechnical Consultant and City of Lake Forest Director of Public Works/City Engineer, or designee, to ensure compliance with the corrosion protection measures of the corrosion engineer, as incorporated into the project plans. (MM GEO-2)

55. During construction, excavation and grading activities in deposits with high paleontological sensitivity shall be monitored by a paleontological monitor as defined by the PRIMP. No monitoring is required for excavations in deposits with no or low paleontological sensitivity (i.e., engineered fill soils).

If paleontological resources are encountered during the course of ground disturbance, the paleontological monitor shall have the authority to Item: 9
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temporarily redirect construction away from the area of the find in order to assess its significance. In the event that paleontological resources are encountered when a paleontological monitor is not present, work in the immediate area of the find shall be redirected, and a paleontologist shall be contacted to assess the find for significance.

56. Upon discovery of any TCRs, all construction activities in the immediate vicinity of the discovery shall cease (i.e., not less than the surrounding 50 feet) and shall not resume until the discovered TCR has been fully assessed by the Kizh monitor and/or Kizh archaeologist. The Kizh will recover and retain all discovered TCRs in the form and/or manner the Tribe deems appropriate, in the Tribe’s sole discretion, and for any purpose the Tribe deems appropriate, including for educational, cultural and/or historic purposes. (MM TCR-2)

57. Native American human remains are defined in PRC 5097.98 (d)(1) as an inhumation or cremation, and in any state of decomposition or skeletal completeness. Funerary objects, called associated grave goods in Public Resources Code Section 5097.98, are also to be treated according to this statute.

If Native American human remains and/or grave goods are discovered or recognized on the project site, then Public Resource Code 5097.9 as well as Health and Safety Code Section 7050.5 shall be followed.

Human remains and grave/burial goods shall be treated alike per California Public Resources Code section 5097.98(d)(1) and (2).

Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human remains and/or burial goods.

Any discovery of human remains/burial goods shall be kept confidential to prevent further disturbance. (MM TCR-3)
Prior to the issuance of a certification of occupancy for the building, the following shall be completed:

58. The street improvements and traffic signal modifications for the five intersections shall be completed in accordance with the City-approved plans and to the satisfaction of the Public Works Director or designee. Where Item: 9
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multiple projects are conditioned to complete the same improvements, responsibility shall rest with the developer of the project first reaching final inspection or issuance of a certificate of occupancy. Developers may enter into private cost-sharing agreements, but the City shall not be a party to or responsible for such agreements. (TENG)

59. The applicant shall submit a letter from the project’s registered civil engineer certifying that the finished grading has been completed in accordance with the City-approved grading plan and that all structural Best Management Practices from approved Final Water Quality Management Plan have been constructed and installed. (ENG)

60. The applicant shall submit a letter of certification to the Director of Community Development from the project architect certifying that all improvements have been constructed in accordance with the approved plans. Determination of consistency shall be subject to the review and approval of the Director of Community Development. (PLNG)

61. The applicant shall have installed all landscaping and irrigation in accordance with the approved construction plans. The applicant shall submit a landscape installation verification letter from a licensed landscape architect certifying that the landscaping for the project was installed in accordance with the approved plans. (PLNG)

62. Any landscaping that has not been maintained or was damaged during construction, shall be replaced with the same or a similar plant species (PLNG)

63. In accordance the City’s Water Efficient Landscape Guidelines, the landscape architect shall submit a completed and signed “Landscape Installation Certificate of Completion” for all the landscaping at the site. As detailed in the certificate, the following items shall also be completed:
a. Irrigation scheduling parameters used to set the controller; b. Landscape and irrigation maintenance schedule;
c. Irrigation audit report; and
d. Soil analysis report, if not submitted with Landscape Documentation Package, and documentation verifying implementation of the soil report recommendations. (PLNG)

64. An emergency responder digital radio system shall be provided in this structure. Refer to CFC 510 and the OCC/OCFA DAS/BDA guidelines Item: 9
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(available at ocfa.org) for requirements. Evidence of compliance with emergency responder digital radio system design and performance criteria shall be provided prior to occupancy. (OCFA)

65. The applicant or responsible party shall submit the plan(s) listed below, if applicable, to the Orange County Fire Authority (OCFA) for review and approval:
a. emergency responder radio system testing (service code PR928) (OCFA)

66. All OCFA inspections shall be completed to the satisfaction of the OCFA inspector and be in substantial compliance with codes and standards applicable to the project and commensurate with the type of occupancy (temporary or final) requested. Inspections shall be scheduled at least five days in advance by calling OCFA Inspection Scheduling at 714-573-6150. (OCFA)

67. All parking stalls shall be striped in accordance with the approved plans. (PLNG)

68. The applicant shall ensure that mechanical equipment placed on the roof such as, but not limited to, air conditioning, heating, ventilating ducts and exhaust fans shall be screened from view through the use of approved roof screens, recessed roof wells and/or the building parapets. (PLNG)

69. The project applicant shall provide evidence that the building has been constructed in accordance with the regulations for certification through the LEED Volume program (PLNG)

70. The Project Geotechnical Consultant shall provide a letter regarding contractor compliance with project plans and required geotechnical. The letter shall be submitted to the City of Lake Forest Building Division for review and approval. (MM GEO-1)

71. All provisions of Chapter 9.160 shall be implemented, as approved on the construction drawings and civil street improvement plans, including but not limited to, the required carpool parking stalls, vanpool parking stalls, ride share vehicle loading area, bicycle parking, shower facilities, locker facilities, commuter information area, and improvements to the existing bus stop located on the northwest corner of the intersection of Dimension Drive at Commercentre Drive/Enterprise Way. (RCM TRA-1)

72. The project Applicant shall retain a licensed Civil Engineer by the State of California to prepare Civil Street Improvements and Signing & Striping Plans Item: 9
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(collectively Construction Plans) for the implementation of bike lanes in both directions on Commercentre Drive between Alton Parkway and Dimension Drive. These bike lanes on Commercentre Drive would connect the proposed project site on Enterprise Way to the existing bike lanes on Alton Parkway, which eventually connects to the Irvine Transportation Center, a multi-model transit hub including Metrolink and Amtrak commuter train services and OCTA bus services.

Based on a preliminary design assessment, the Construction Plans shall include an asphalt slurry seal of Commercentre Drive to modify the existing lane striping for the addition of standard striped bike lanes and green bike markings. The project Applicant shall use these Construction Plans to obtain a Public Works Encroachment Permit to construct said improvements for bike lanes on Commercentre Drive. The construction of said improvements shall be completed per the plans and to the satisfaction of the Public Works Department. The project Applicant shall use these Construction Plans to obtain a Public Works Encroachment Permit to construct said improvements for bike lanes on Commercentre Drive. (MM TRA-1)

73. All required lighting shall be installed and operational and shall be maintained by the property owner for the life of the project. (MM TRA-2)

74. The property owner and/or business operator shall obtain Community Development approval of sign plans (sign design and locations) for signs to be posted on-site, related to conditions #86, #87, and # 88. This signage shall be installed per the approved sign plans. (PLNG)

75. The property owner shall install a security camera system to monitor trucking related activities onsite at both truck court gates and at the shared drive aisle at the north corner of the property. (PLNG)
Prior to issuance of building permits for any tenant improvement plans for the building, the following shall be completed:

76. The property owner and/or business operator shall obtain Planning and Code Enforcement Division approval of sign plans (sign design and locations), for signs to be posted at each driveway entrance to the property, that includes the following information:
a. Property owner, business owner, or property management company name
b. A telephone number and local contact for the public to report any problems or concerns about the property.

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The property owner and/or business operator shall install the approved signage. (PLNG)

77. The tenant improvement plans shall include installation of a minimum of four electric truck charging stations at the predesignated locations. The charging stations shall be installed and operational prior to tenant occupancy of the building. (MM GHG-1)
The use shall be operated and maintained in substantial conformance with the following:

78. All trucks/trailers shall only be parked in the truck loading dock area. (PLNG)

79. The building shall not be used for any cold storage uses or any user that requires refrigerated storage. (PLNG)

80. The required parking stalls in the truck loading area shall be accessible to employees during business hours. (PLNG)

81. The applicant shall maintain signage at the site, as approved by the City, with current contact information for the public to report any problems or concerns about the property. (PLNG)

82. All landscaping shall be maintained in a healthy and living condition. If necessary, plants shall be replaced in a manner that is consistent with the landscaping plan. Landscaping shall be irrigated and all irrigation systems shall be maintained in good working order. (PLNG)

83. The project site shall maintain compliance with the City’s Noise Ordinance (Chapter 11.16 of the Lake Forest Municipal Code) at all times. (PLNG)

84. Signs, including window signage, are not a part of this approval. All signage will be subject to separate approval in compliance with the City’s Sign Ordinance and/or an approved Planned Sign Program. (PLNG)

85. The project shall be developed and maintained in substantial compliance with the site plans, landscape plans, and the building elevations approved by the City Council on July 7, 2026 and on file with the City of Lake Forest Community Development Department. Minor modification or changes to these plans shall be subject to the additional review, and CEQA compliance, as determined by the Director of Community Development. (PLNG) Item: 9
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86. The internal driveway adjacent to The Meadows shall be designated as a Quiet Zone between the hours of 10:00 PM and 7:00 AM, daily. Operations of commercial vehicles using this driveway between the hours of 10:00 PM and 7:00 AM shall comply with the following: (1) Audible backup alarms (beepers) are prohibited. Vehicles shall utilize approved silent or "smart" backup warning systems, such as broadband white noise alarms or camerabased detection systems, in compliance with applicable Cal/OSHA safety requirements. (2) Engine idling is prohibited while using the designated Quiet Zone driveway. (3) The property owner shall maintain clearly visible signage at each end of the designated Quiet Zone driveway notifying drivers of the nighttime noise restrictions prior to entering the zone. The property owner and/or business park management shall notify all tenants, contractors, and vendors of these requirements in writing prior to occupancy and annually thereafter. Documentation shall be maintained on-site and available to the City upon request. (PLNG)

87. All commercial truck traffic shall be prohibited from utilizing the shared drive aisle at the north corner of the property, that leads to Bake Parkway. Signage reflecting this restriction shall be maintained, as approved by the Community Development Department. (PLNG)

88. The property owner and/or business operator shall maintain signage, as approved by the Community Development Department, restricting idling at the site to 5 minutes or less. (PLNG)

89. Commercial truck traffic on the project site shall not exceed 15 truck trips (entering or exiting) per hour between the hours of 7:00 a.m. to 10:00 p.m. and 4 truck trips (entering or exiting) per hour between the hours of 10:00 p.m. and 7:00 a.m..(PLNG)

90. The property owner shall maintain the installed security camera system to monitor trucking related activities onsite at both truck court gates and at the shared drive aisle at the north corner of the property. Summarized reports shall be provided to the City, which shall include the date and time, for all commercial truck traffic activity entering and exiting the site from the security cameras to the City of Lake Forest on a quarterly basis.

The Property Owner shall, at its sole expense, retain a qualified, independent third party, subject to City approval, and such approval shall not be unreasonably withheld, and unaffiliated with the Property Owner or tenants, to verify monitoring data and prepare the quarterly reports submitted to the City. The independent third party shall maintain a secure, tamper-resistant, continuously backed-up database with a record of all truck trips and the Item: 9
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database shall be provided to the City upon request. The City shall have the right, at any time and upon reasonable notice, to inspect the truck monitoring systems, audit monitoring records, obtain direct electronic access to monitoring data, and require production of supporting documentation necessary to verify compliance with this condition. The records related to truck trips, truck monitoring systems, data, and supporting documentation shall be retained by the independent third party for a minimum of one year. (PLNG)
SECTION 4. EFFECTIVE DATE. This Resolution takes effect immediately upon its adoption.

SECTION 5. SEVERABILITY. If any provision of this Resolution or its application to any person or circumstances is for any reason held to be invalid, such invalidity has no effect on the other provisions or applications of the Resolution that can be given effect without the invalid provision or application and, to this extent, the provisions of this Resolution are severable. The City Council hereby declares that it would have adopted this Resolution, and each section, subsection, subdivision, sentence, clause, phrase, or portion thereof, irrespective of the fact that any one or more sections, subsections, sentences, phrases, or portions thereof be declared invalid or unconstitutional.

SECTION 6. CUSTODIAN OF RECORDS. The documents and materials that constitute the record of proceedings on which this Resolution is based are located at the City of Lake Forest City Hall, 100 Civic Center Drive, Lake Forest, CA 92630.

The custodian for these records is the City Clerk.

SECTION 7. NOTICE OF DECISION. The City Clerk shall cause a Notice of Decision of the appeal to be served on the appellant and the applicant, in substantially the same form as set forth in Lake Forest Municipal Code Section

2.04.130(D), within five days of the adoption of this Resolution.

APPROVED this 7th day of July 2026, by the following vote, to wit:

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____________________
ROBERT PEQUEÑO
MAYOR
ATTEST:
_______________________

THY MERRITT

CITY CLERK
APPROVED AS TO FORM:
__________________________
MATTHEW E. RICHARDSON

CITY ATTORNEY

STATE OF CALIFORNIA )

COUNTY OF ORANGE ) SS

CITY OF LAKE FOREST )
I, Thy Merritt, City Clerk of the City of Lake Forest, California, do hereby certify that the foregoing Resolution No. 2026-__ was duly passed and adopted at a regular meeting of the Lake Forest City Council on the 7th day of July 2026, by the following vote, to wit:

AYES: COUNCIL MEMBERS
NOES: COUNCIL MEMBERS
ABSTAIN: COUNCIL MEMBERS
ABSENT: COUNCIL MEMBERS
_______________________________

THY MERRITT

CITY CLERK
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“Exhibit A”
General Plan Compliance Table
General Plan Goals, Policies, and Actions General Plan Consistency Analysis Goal LU-1 Land Use Mix: A community with a balanced land use pattern that meets the City’s long-term housing, employment, and civic needs.

Policy LU-1.8 Consistent Standards: Require projects to adhere to the City’s Municipal Code.

Consistent. As discussed in Finding 3, proposed project would be consistent with the City’s Zoning Code and the Pacific Commercentre Planned Community. Therefore,
the proposed project is consistent with these General
Plan Policies.

Goal LU-2 Compatible Development: A community where new development blends harmoniously into the existing neighborhood fabric.

Policy LU-2.1 Physical Characteristic Compatibility: Ensure that new development fits within the existing community setting and is compatible with surrounding land uses and public infrastructure availability.

Policy LU-2.2 Sensitive Uses: Locate residences away from areas of excessive noise, smoke, or dust and ensure that adequate mitigation measures, including buffers or transitional uses, are made to ensure the health and well-being of existing and future residents.

Policy LU-2.4 Scale and Character: Ensure that the scale and character of new development is appropriate to the setting and intended use.

Policy LU-2.5 Visual Compatibility: Require new development projects achieve visual compatibility with surrounding
development through building, site, or design techniques, such as landscaping and architectural design, to achieve visual compatibility.

Policy LU-2.7 Interface with Residential Areas: Promote compatibility of adjacent land uses along the interface of different residential density and non-residential intensity categories by paying special attention to buffers and transitional areas.

Action LU-2a: As part of the City’s development review process, ensure that commercial projects are designed to be compatible with residential uses, including appropriate building massing and scale and minimization of impacts related to the operation of the use. Review of employment-generating projects should ensure that the following design concepts are addressed in projects that abut residential areas:
 Appropriate building scale and/or siting;
 Site design and noise-attenuating features to avoid exposure to excessive noise due to long hours of operation or
inappropriate location of accessory structures;
 Site and structure design to avoid excessive glare or excessive impacts from light sources onto adjacent
properties; and
 Site design to avoid unnecessary loss of community and environmental resources (archaeological, historical,
ecological, recreational, etc.).

Consistent. The proposed industrial building is located within the Pacific Commercentre Planned Community.

The Pacific Commercentre Planned Community was
developed as a master planned industrial business park
with local streets providing internal circulation. The
buildings in the Planned Community include a mix of
warehouse, distribution, manufacturing, research and
development, and offices. The proposed industrial
building is consistent with the type, scale, and intensity of the existing industrial development in the Pacific
Commercentre Planned Community. The proposed
project includes the replacement of an existing 2-story concrete tilt-up industrial building with a new 2-story concrete tilt-up industrial building.

The subject site is adjacent to the Meadows residential community to the northeast/east. The project site is not connected to the Meadows residential community by
any streets or walkways. Furthermore, a landscape
buffer separates the Meadows residential community
and the industrial area. The proposed project includes
the installation of additional landscaping and mature
trees along the northeastern corner of the project site, adjacent to the Meadows Community. This new
landscaping will further reduce the visibility of the
industrial site as viewed from the Meadows Community.

Furthermore, the building was designed so that the truck dock and loading area of the proposed building is
oriented to the southeast (not facing the residential
properties), is located over 200 feet away from the
nearest residential property line, and would not be
readily visible from the residences. As such, the new
proposed building is compatible with the surrounding
land uses.

As detailed in Sections 4.13 Noise, 4.1 Aesthetics, and 4.3 Air Quality, the proposed project would not result in
excessive noise, smoke, dust, light or glare that would impact the nearby residences.

The overall building treatment and façade is compatible with the existing architecture of the industrial buildings Item: 9
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“Exhibit A”
General Plan Compliance Table
General Plan Goals, Policies, and Actions General Plan Consistency Analysis Action LU-2b: As part of the City’s development review process, ensure that new developments are designed to minimize glare and light impacts onto adjacent properties.
in the Pacific Commercentre Planned Community. The
proposed building would be constructed of
architecturally enhanced tilt-up concrete panels and
would be painted different shades of gray with a blue
accent. The building architecture utilizes scoring, color transitions, and windows to provide articulation to the facades of the building. The truck doors, which would be painted to match the building, would be located on the
south elevation of the building, and would not be visible from the surrounding streets or residential properties.

All lighting associated with the proposed project would be hooded or shielded to focus the light downward and
prevent light spillage onto adjacent properties. The
Applicant has provided a photometric plan that shows
low-level illumination at the property lines adjacent to the light industrial areas and no illumination at the
property line adjacent to the residential property. The building materials (e.g., concrete, glass, metal) and
proposed uses are typical of those found in the
surrounding areas, are non-reflective, and would not
create unusual or isolated glare effects that would affect daytime visibility or views in the project vicinity.

As detailed in Table 4.11.C, the proposed project would be consistent with the permitted uses and development
standards of the City’s Zoning Code and the Pacific
Commercentre Planned Community. Additionally, as
detailed in the Biological Resources, Cultural Resources, Recreation, and Tribal Cultural Resources sections of this EIR, the proposed project would not result in an
unnecessary loss of community and environmental
resources (archaeological, historical, ecological,
recreational, etc.). The proposed project is consistent with these General Plan Policies and actions.

Goal LU-3 Placemaking: A distinct community image and identity that promotes Lake Forest as a desirable place to live and do business.

Policy LU-3.4 High-Quality Design: Promote high-quality design for all public and private development projects, including building form, site design, landscaping, lighting, signage, and other components which impact the visual quality of a project.

Policy LU-3.6 Architectural Styles: Promote architectural styles that emphasize the established community identity while allowing for the introduction of other appealing architectural design strategies that are compatible with their surroundings.

Consistent. The proposed building would be similar in
design, scale, and character to existing surrounding
industrial uses. The proposed building would be
constructed of architecturally enhanced tilt-up concrete panels and would be painted varying shades of gray with a blue accent. The building architecture utilizes scoring, color transitions, and windows to provide articulation to long facades of the building. The truck doors, which
would be painted to match the building, would be
located on the south elevation of the building, and would not be visible from the surrounding streets, nor
residential properties. The overall building treatment
and façade will be compatible and consistent with the
remainder of the existing, surrounding industrial park.

The proposed project would not impact any existing
parks, trails, or scenic vistas and would enhance
streetscapes by providing a variety of trees, shrubs and Item: 9
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“Exhibit A”
General Plan Compliance Table
General Plan Goals, Policies, and Actions General Plan Consistency Analysis ground cover and maintaining the existing landscaping
around the perimeter of the project site.

The proposed project would result in the redevelopment
of an older and underutilized site with a new industrial building with improved quality and enhanced site and
building design. The proposed project is consistent with these General Plan Policies.

Goal LU-4 Streetscapes: A community with streetscapes that enhance the economic vitality and overall visual quality of the City, support the circulation network, and encourage pedestrian-scale streets and patterns of activity.

Policy LU-4.3 Building Massing: Reduce the bulk and perceived size of large buildings by dividing their mass into smaller parts, stepping down to adjacent structures, recessing openings for doors/windows, and using pedestrian-scale features; singleplane massing is discouraged.

Policy LU-4.4 Building Footprint: Require and enforce
appropriate residential and nonresidential development
standards, including adequate building setbacks, to ensure that a building’s footprint does not negatively affect adjacent uses or the visual quality of the area.

Consistent. The proposed project would enhance
streetscapes by providing a variety of trees, shrubs and ground cover and maintaining the existing landscaping
around the perimeter of the project site.

The proposed project would include an on-site
accessible path of travel through the parking lot that
would lead to a paved walkway along the north side of
the building and would connect to an existing striped
crosswalk across Enterprise Way.

The proposed building would be constructed of
architecturally enhanced tilt-up concrete panels and
would be painted different varying shades of gray with a blue accent. The building’s main entrances would be
emphasized with vertical and horizontal bands,
windows, and decorative light sconces. The building
architecture utilizes scoring, color transitions, and
windows to provide articulation to long facades of the
building. The proposed building would be consistent
with allowable building setbacks and as detailed in
Finding 3 of this resolution, the proposed project would be consistent with the City’s Zoning Code and permitted uses and developed standards of the Pacific
Commercentre Planned Community.

Additionally, the proposed project would include the
installation of landscaping and mature trees around the project site and proposed building with densely placed
mature trees along the northeastern corner of the
proposed building and project site to reduce the visibility of the project site from adjacent residential uses and to improve the overall visual quality of the site The
proposed project is consistent with these General Plan
Policies.

Goal M-1 Regional and Local Roads: A transportation system that meets and balances local and regional mobility needs.

Action M-1b: As part of the development review process, the Community Development Department and the Public Works
Department shall require developers to complete and fund the following:

1. A local transportation analysis to ensure that the site plan incorporates City transportation goals, policies, and
standards, that identifies the effects of the project on the local transportation system, and identifies improvements to Consistent. As part of the proposed project, off-site
improvements would be made at 5 intersections to
enhance public safety and address concerns related to
large truck turning movements. Based on the results of
the TIA, the proposed project would not result in any
level of service (LOS) deficiencies or impacts. Therefore, the existing intersections and roadways would be able to accommodate all traffic (passenger vehicles and trucks) associated with implementation of the proposed
project.

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“Exhibit A”
General Plan Compliance Table
General Plan Goals, Policies, and Actions General Plan Consistency Analysis maintain adopted LOS standards for
operations at signalized city-controlled
intersections;

2. The project’s proportional share of the effects on the City’s circulation network through payment of fees; and

3. For local project-related circulation effects requiring improvements that are not included in an adopted fee
program, either complete the necessary improvements or
pay a proportional share of the cost.

The TIA is consistent with the objectives and
methodologies set forth in the City’s TA Guidelines, the 2021 Congestion Management Program (CMP) for
Orange County, and applicable provisions of CEQA. The
proposed project would not conflict with a program plan, ordinance or policy addressing the circulation system,
including transit, roadway, bicycle, and pedestrian
facilities.

Items 2 and 3 of this action are not applicable to the
proposed project. The proposed project is consistent
with these General Plan Policies and actions.

Goal M-5 Bicycle, Pedestrian, and Equestrian Use: Support and promote the use of pedestrian, bicycle, and equestrian facilities.

Policy M-5.1 Promote Non-Vehicular Modes: Promote the
provision of non-vehicular circulation modes within Lake Forest.

Policy M-5.2 Pedestrian Access Between Uses: Improve
pedestrian access between complementary uses such as
residential and commercial areas and seek to increase the number of bridges and/or grade-separated crossings over freeways and major roadways.

Consistent. The proposed project would include bike
racks (31 spaces total) and pedestrian connections to
nearby sidewalks and crosswalks. The proposed project
is consistent with these General Plan Policies.

Goal M-6 Safety: Provide a safe transportation system for all users.

Policy M-6.3 Site Designs and Safety: Ensure, through the development review process, that development projects follow best design practices to reduce conflicts between multiple travel modes.

Consistent. The project includes off-site improvements
at five intersections to enhance public safety and
address concerns related to large truck turning
movements, which would be completed consistent with
design standards to reduce conflicts between multiple
travel modes. By incorporating intersection
improvements into the design of the proposed project,
the proposed project does not include any geometric
design features or incompatible uses that could
substantially increase circulation/traffic hazards. The proposed project is consistent with this General Plan
Policy.

Goal M-9 Goods Movement: Accommodate safe goods movement through the City’s transportation network.

Policy M-9.1 Goods Movement Along City Arterials: Continue to restrict truck traffic through the City to its arterial roadways in order to facilitate goods movement to regional facilities; continue to prohibit truck traffic on residential streets.

M-9.2 Roadway Design: Maintain roadway design standards along City arterials to facilitate truck access to light industrial, manufacturing, commercial, and mixed-use areas along
designated truck routes.

Consistent. Truck traffic associated with the proposed
project would be restricted to arterial roadways and
truck traffic would not be allowed on residential streets.

The City does not have any designated truck routes.

The project site is not located along a City arterial;
however, the proposed off-site intersection
improvements are located along City arterials. The offsite improvements are proposed to enhance public safety and facilitate large truck turning movements and would be completed consistent with design standards to
facilitate truck access.

The proposed project is anticipated to generate 727 total daily trips (in passenger car equivalents [PCEs]), which is broken down to 455 daily passenger vehicle trips and
272 daily truck trips (in PCEs). Based on the results of the TIA, the proposed project would not result in any level of service (LOS) deficiencies or impacts. Therefore, the
existing intersections and roadways would be able to
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“Exhibit A”
General Plan Compliance Table
General Plan Goals, Policies, and Actions General Plan Consistency Analysis accommodate all traffic (passenger vehicles and trucks) of the proposed project.

The proposed project is consistent with these General
Plan Policies.

Goal M-10 Funding: Ensure the utilization of various financing methods to improve and provide a fiscally sound transportation system.

Policy M-10.2 New Developments: Ensure that new
development projects contribute their appropriate fair share to transportation network improvements and that existing funding commitments are met.

Consistent. As detailed in Chapter 3.0, Project
Description, the proposed project would include off-site improvements at five intersections within the City to
enhance public safety and facilitate large truck turning movements. These improvements will be paid for by the
applicant for this project. The proposed project is
consistent with this General Plan Policy.

Goal RR-3 Cultural Resources: A community that values its history and preserves its cultural features to bolster community identity and protect sensitive resources.

Policy RR-3.1 Preservation: Protect areas containing significant historic, archaeological, and paleontological resources, as defined by the California Public Resources Code.

Policy RR-3.3 Development: Ensure that human remains are treated with sensitivity and dignity, and ensure compliance with the provisions of California Health and Safety Code Section 7050.5 and California Public Resources Code Section 5097.98.

Policy RR-3.4 Tribal Consultation: Consult with Native American tribes that may be impacted by proposed development, as necessary, and in accordance with state, local, and tribal intergovernmental consultation requirements.

Action RR-3a: City staff shall require applicants for future proposed ground disturbing projects to provide a technical cultural resources assessment consisting of a record search, survey, background context and project specific
recommendations performed by a qualified archaeologist
meeting Secretary of the Interior Standards and certified by the County of Orange. If resources are known or reasonably
anticipated the recommendations shall provide a detailed mitigation plan which shall require monitoring during grading and other earthmoving activities in undisturbed sediments, provide a treatment plan for potential resources that includes data to be collected, requires professional identification, other special studies as appropriate, requires curation at an accredited museum such as the John D. Cooper Center operated by the County of Orange for artifacts meeting significance criteria, requires a comprehensive final mitigation compliance report including a catalog of specimens with museum numbers and an appendix containing a letter from the museum stating that they are in possession of the materials.

Action RR-3b: Require all new development, infrastructure, and other ground-disturbing projects to comply with the following conditions in the event of an inadvertent discovery of cultural resources or human remains:
 If construction or grading activities result in the discovery of significant historic or prehistoric archaeological artifacts or unique paleontological resources, all work within 100 feet of the discovery shall cease, the Director of Community
Consistent. As detailed in Section 4.5, Cultural
Resources, and Section 4.7, Geology and Soils, the
proposed project would not result in significant impacts to historic, archaeological, and paleontological
resources. Human remains, if discovered, would be
handled in compliance with the provisions of California Health and Safety Code Section 7050.5 and California
Public Resources Code Section 5097.98. As detailed in
Section 4.18, Tribal Cultural Resources, consultation with Native American tribes has occurred in accordance with
state, local, and tribal intergovernmental consultation requirements.

A Cultural Resources Assessment was prepared for the
proposed project by BCR Consulting (BCR Consulting
2021), which included a record search, survey,
background context and project-specific
recommendations performed by a qualified
archaeologist meeting the Secretary of the Interior’s
Standards and certified by the County of Orange. The
Cultural Resources Assessment indicated that no
additional cultural resources work or monitoring is
necessary during proposed activities associated with the development of the project site. However, in the unlikely event that previously undocumented cultural resources
are identified during earthmoving activities, a qualified archaeologist should be contacted to assess the nature
and significance of the find, diverting construction
excavation if necessary. In the unlikely event
archaeological resources are discovered at any time
during construction, those activities would be halted in the vicinity of the find until the find can be assessed for significance by a qualified archaeologist (Mitigation
Measure CUL-1).

To mitigate adverse impacts to unknown buried
paleontological resources that may exist on site,
Mitigation Measure GEO-3 would be implemented,
which requires the preparation and implementation of a
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“Exhibit A”
General Plan Compliance Table
General Plan Goals, Policies, and Actions General Plan Consistency Analysis Development shall be notified, the resources
shall be examined by a qualified
archaeologist, paleontologist, or historian for
appropriate protection and preservation
measures; and work may only resume when
appropriate protections are in place and have
been approved by the Community
Development Director; and
 If human remains are discovered during any ground
disturbing activity, work shall stop until the Director of Community Development and the Orange County Coroner
have been contacted. If the human remains are determined to be of Native American origin, the Native American
Heritage Commission and the most likely descendants shall be consulted; and work may only resume when appropriate measures have been taken and approved by the Community
Development Director.

Action RR-3d: Require all development, infrastructure, and other ground-disturbing projects to comply with the following conditions in the event of an inadvertent discovery of a paleontological resource:
 If construction or grading activities result in the discovery of significant prehistoric archaeological artifacts or unique paleontological resources, all work within 100 feet of the discovery shall cease, the Director of Community
Development shall be notified, the resources shall be
examined by a qualified archaeologist, paleontologist, or historian for appropriate protection and preservation
measures; and work may only resume when appropriate
protections are in place and have been approved by the
Director of Community Development.

Paleontological Resources Impact Mitigation Program,
as detailed in Section 4.7, Geology and Soils.

The proposed project is consistent with these General
Plan Policies or actions.

Goal RR-4 Air Quality and Greenhouse Gas Emissions: A community with optimal air quality for its residents.

Policy RR-4.7 Mitigation: Require the implementation of relevant mitigation measures for all future development upon identification of potential air quality impacts.

Consistent. As detailed in Section 4.3, Air Quality,
implementation of Mitigation Measures AQ-1 and AQ-2
would be required reduce potential air quality impacts
associated with the proposed project, which require use of construction equipment equipped with Tier 4 final
engines or the most effective Verified Diesel Emission
Control Strategies (VDECS) available for the engine type and use of “Super-Compliant” low volatile organic
compounds (VOC) paints for interior and exterior
surfaces and low VOC paint for parking lot surfaces.

The proposed project is consistent with this General Plan Policy.

Policy RR-4.8 Local Reduction Targets: The City of Lake Forest establishes the following per capita GHG reduction targets, in order to meet the requirements established by the state under AB 32 and SB 32, consistent with the CARB’s 2017 Scoping Plan:
 3.99 MT CO2e per capita by 2030
Partially Consistent. As detailed in Section 4.8,
Greenhouse Gas Emissions, the City’s GHG reduction
targets have not been formally adopted by the City as GHG reduction thresholds for development projects. The
proposed project would result in a significant and
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“Exhibit A”
General Plan Compliance Table
General Plan Goals, Policies, and Actions General Plan Consistency Analysis  2.66 MT CO2e per capita by 2040; and
 1.33 MT CO2e per capita by 2050.
unavoidable impact related to VMT even after
implementation of Mitigation Measure TRA-1 (addition of bike lanes). Therefore, the proposed project would
conflict with SB 743 and the goals of the 2022 Scoping Plan for the purpose of reducing the emissions of greenhouse gases and would result in a significant and unavoidable Item: 9
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“Exhibit A”
General Plan Compliance Table
General Plan Goals, Policies, and Actions General Plan Consistency Analysis impact related to GHG. As such, the proposed project
would not meet the overall goals established by AB 32 and SB 32 for the reduction of GHGs and would not be
consistent with the CARB’s 2017 and 2022 Scoping Plans.

However, with implementation of Mitigation Measure
GHG-1 requiring provisions be made at the project site for emerging electric truck technology and supporting the
operation of zero-emissions trucks at the project site as such technology is commercially deployed and available, the proposed project would have the potential to further lower mobile source emissions associated with operation of the proposed project. Mitigation Measure GHG-1 is
required to contribute to the project’s “fair share” of GHG emissions reductions required to support SB 743 and the goals of the 2017 and 2022 Scoping Plan (including SB 32 and AB 32).

Based on the above, the proposed project would be
partially consistent with this General Plan Policy.

Action RR-4a: Review all new industrial and commercial
development projects for potential air quality impacts to residences and other sensitive receptors. Ensure that
mitigation measures and best management practices are
implemented to reduce significant emissions of criteria pollutants.

Consistent. As detailed in Section 4.3, Air Quality, with implementation of Mitigation Measures AQ-1 and AQ2, the proposed project would not result in the exposure of nearby sensitive receptors to significant emissions of criteria pollutants.

The proposed project is consistent with this General Plan Action.

Action RR-4b: Review development, infrastructure, and
planning projects for consistency with SCAQMD requirements during the CEQA review process. Require project applicants to prepare air quality analyses to address SCAQMD and General Plan requirements, which include analysis and identification of:

1. Air pollutant emissions associated with the project during construction, project operation, and cumulative conditions.

1. Potential exposure of sensitive receptors to toxic air contaminants.

2. Significant air quality impacts associated with the project for construction, project operation, and cumulative conditions.

Mitigation measures to reduce significant impacts to less than significant or the maximum extent feasible where impacts cannot be mitigated to less than significant.

Consistent. An Air Quality, Greenhouse Gas, and Energy
Impact Report was completed for the proposed project,1
which addresses all SCAQMD and General Plan
requirements. As detailed in Section 4.3, Air Quality, the proposed project would meet local and regional air
quality standards and SCAQMD requirements and
emissions thresholds with the implementation of
Mitigation Measures AQ-1 and AQ-2, which require use
of construction equipment equipped with Tier 4 final
engines or the most effective Verified Diesel Emission
Control Strategies (VDECS) available for the engine type and use of “Super-Compliant” low volatile organic
compounds (VOC) paints for interior and exterior
surfaces and low VOC paint for parking lot surfaces.

The proposed project is consistent with this General Plan Action.

Action RR-4d: Continue to review development projects to ensure that all new public and private development complies with the California Code of Regulations (CCR), Title 24 standards as well as the energy efficiency standards established by the Lake Forest Municipal Code.

Consistent. As detailed in Section 4.6, Energy, the
proposed project would comply with the CCR Title 24
standards as well as energy efficiency standard
established by the Lake Forest Municipal Code.

The proposed project is consistent with this General Plan Action.
1 LSA Associates, Inc. 2025a. Air Quality, Greenhouse Gas, and Energy Impact Report. IPT Enterprise Business Center LLC Project, Lake Forest, California. August.

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“Exhibit A”
General Plan Compliance Table
General Plan Goals, Policies, and Actions General Plan Consistency Analysis Action RR-4n: Future development projects implemented
under the General Plan will be required to demonstrate
consistency with SCAQMD construction emission thresholds.

Where emissions from individual projects exceed SCAQMD
thresholds, the following actions shall be incorporated as necessary to minimize impacts. These measures do not exclude the use of other, equally effective mitigation measures.

1. Require all off-road diesel equipment greater than 50 horsepower (hp) used for this Project to meet USEPA Tier 4 final off-road emission standards or equivalent. Such
equipment shall be outfitted with Best Available Control Technology (BACT) devices including a California Air
Resources Board Certified Level 3 Diesel Particulate Filter (DPF) or equivalent. This DPF will reduce diesel particulate matter and NOx emissions during construction activities.

1. Require a minimum of 50 percent of construction debris be diverted for recycling.

2. Require building materials to contain a minimum 10 percent recycled content.

Require materials such as paints, primers, sealants, coatings, and glues to have a low volatile organic compound
concentration compared to conventional products. If low VOC materials are not available, architectural coating phasing should be extended sufficiently to reduce the daily emissions of VOCs.

Consistent. Refer to the General Plan Consistency
Analysis for Action RR-4b, above.

The proposed project would not conflict with this
General Plan Action.

Action RR-4o: Future development projects implemented
under the General Plan will be required to demonstrate
consistency with SCAQMD’s operational emission thresholds.

For projects where operational emissions exceed regulatory thresholds, the following measures may be used to reduce impacts. Note the following measures are not all inclusive and developers have the option to add or substitute measures that are equally or more appropriate for the scope of their project.  Develop a project-specific TDM program for residents and/or employees that provides opportunities for carpool/vanpools.  Provide onsite solar/renewable energy in excess of
regulatory requirements.
 Require that owners/tenants of non-residential or multifamily residential developments use architectural coatings that are 10 grams per liter or less when repainting/repairing properties.
 Require dripless irrigation and irrigation sensor units that prevent watering during rain storms.

Ensure all parking areas are wired for capability of future EV charging and include EV charging stations that exceed
regulatory requirements.

Consistent. Refer to the General Plan Consistency
Analysis for Policy RR-4b, above.

The proposed project would not conflict with this
General Plan Action.

Goal RR-5 Biological Resources: A community that harmoniously coexists with existing plant and animal life.

Policy RR-5.7 Development: Require that all new development identify potential impacts to existing biological resources and provide mitigation measures as necessary pursuant to CEQA in order to protect these resources from negative externalities.

Consistent. As detailed in Section 4.4, Biological
Resources, the proposed project would result in less
than significant impacts to sensitive, rare, or endangered plant and wildlife species with the implementation of
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“Exhibit A”
General Plan Compliance Table
General Plan Goals, Policies, and Actions General Plan Consistency Analysis Action RR-5b: Require new development, as well as
infrastructure projects, long-range planning projects, and other projects, to comply with the requirements of the Orange County Central-Coastal Natural Community Conservation Plan/Habitat Conservation Plan (NCCP/HCP) to ensure that potentially significant impacts to special-status species and sensitive resources are adequately addressed.

Action RR-5c: Require new development which has the
potential to result in water quality impacts to the City’s creeks and the local groundwater basin to implement all feasible mitigation measures to reduce impacts.

Regulatory Compliance Measure (RCM) BIO-1, which
requires compliance with the Migratory Bird Treaty Act
(MBTA) and the California Fish and Game Code. A
Biological Resources Report (ELMT Consulting, 2021) was completed for the proposed project, which did not identify any potential significant impacts to biological resources.

Additionally, the proposed project would be consistent
with the rules and regulations of the NCCP/HCP.

A variety of trees, shrubs, and groundcover surrounding the proposed industrial building is proposed.

As detailed in Section 4.10, Hydrology and Water Quality, the proposed project would implement RCMs WQ-1, WQ2, WQ-3, and WQ-4 to reduce water quality impacts to the City’s creeks and the local groundwater basin.

The proposed project would not conflict with these
General Plan Policies or actions.

Goal PS-1 Seismic and Geologic Hazards: A community that is adequately prepared for natural hazards related to landslides, geologic instability, and seismic activity.

Policy PS-1.2 Earthquake Protection: Enforce State Seismic design guidelines and all relevant building codes to reduce the risk of damage associated with seismic activity.

Policy PS-1.4 Development: Require assessment and mitigation of hazards related to liquefaction, landslides, and flooding for new development projects or City improvement projects that are identified by the City as susceptible to these hazards.

Consistent. As detailed in Section 4.7, Geology and Soils, the proposed project would comply with the most
current California Building Code (CBC) and the City
Building Code, which stipulate appropriate seismic
design provisions. A Geotechnical Investigation was
completed for the proposed project (Southern California Geotechnical 2021a), which did not identify the project site as susceptible to liquefaction, landslides, or flooding.

The proposed project would not conflict with these
General Plan Policies.

Goal PS-2 Fire Safety: A City that is safe and adequately prepared for urban and wildfire emergencies.

Policy PS-2.1 Building Fire Codes: Require that all buildings and facilities within Lake Forest comply with local, state, and federal regulatory standards such as the California Building and Fire Codes as well as other applicable fire safety standards.

Consistent. The proposed project would comply with
local, state, and federal regulatory standards such as the California Building and Fire Codes as well as other
applicable fire safety standards as detailed in Section

4.20, Wildfire.

The proposed project would not conflict with these
General Plan Policies.

Goal PS-4 Hazardous Waste and Materials: A community that is protected from the potential for hazardous waste and materials contamination.

Action PS-4b: Continue to require the submittal of information regarding hazardous materials manufacturing, storage, use, transport, and/or disposal by existing and proposed businesses and developments to the Orange County Fire Authority.

Consistent. As detailed in Section 4.9, Hazards and
Hazardous Materials, the proposed project would
comply with existing hazardous materials regulations
and programs, including requirements for HMBPs and
RMPs for facilities handling significant quantities of
hazardous materials, OSHA and Cal/OSHA regulations,
CCR Title 8; the CGP; and DOT, RCRA, Orange County
Health Care Agency regulations, Orange County Fire
Authority (OCFA) regulations and State regulations.

The proposed project would not conflict with these
General Plan Policies or actions.

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“Exhibit A”
General Plan Compliance Table
General Plan Goals, Policies, and Actions General Plan Consistency Analysis Goal PS-6 Noise: A comfortable community environment that is free from excessive noise pollution.

Policy PS-6.1 Land Use Planning: Require development and infrastructure projects to be consistent with the maximum allowable noise exposure standards identified in Table PS-1 to ensure acceptable noise levels for existing and future
development.

Policy PS-6.3 Site Design: Require site planning and project design techniques to minimize noise impacts adjacent to sensitive uses in order to comply with City standards.

Policy PS-6.4 Noise Control: Ensure that noise levels do not exceed the limits established in the Municipal Code by
incorporating sound-reduction design in new construction and retrofit projects impacted by non-transportation-related noise sources.

Policy PS-6.8 Commercial Noise: Require the use of noise attenuation measures, including screening and buffering techniques, for all new commercial development expected to produce excessive noise; in existing cases where the City’s noise standards are exceeded, work with Code Enforcement to
require compliance.

Action PS-6b: To ensure that noise does not adversely affect new sensitive receptors, the City will use land use compatibility noise criteria for various land use types in Table PS-1 when making planning and development decisions. The criteria in Table PS-1 represent the acceptable noise level for new sensitive receptors.

Existing and future noise contours from transportation noise in the City will be used as a guide for land use and development decisions. If the noise level at a project does not exceed the outdoor activity area allowable noise level in Table PS-1, the project is considered compatible with the noise environment.

If the project will exceed the allowable outdoor activity area and interior space noise levels in Table PS-1, the project proponent shall be required to demonstrate (with an acoustical analysis) that the project is designed to attenuate noise to meet the criteria in Table PS-1, and California Building Standards Code, and California Green Building Standards Code (Title 24) interior noise standards. If the project is not designed to meet the noise criteria, noise reduction measures may be recommended in the analysis. If the analysis demonstrates that the noise criteria can be met with implementation of the noise reduction measures, the project may be approved with the noise reduction measures required as conditions of project approval.

Action PS-6c: To ensure that noise from new development does not adversely affect existing sensitive receptors, the City will require acoustical studies for all new discretionary projects, including those related to development and transportation, which have the potential to generate stationary noise impacts which exceed the criteria identified in the Municipal Code. The studies shall include existing ambient noise measurements, estimates of projected noise levels, and noise reduction measures necessary to ensure compliance with this element.

Consistent. As detailed in Section 4.13, Noise, a Noise and Vibration Impact Analysis was completed for the
proposed project, which included an acoustical study
with representative noise measurements, estimates of
existing and projected noise measures, and mitigation
measures as necessary to ensure compliance with
applicable regulatory documents.

The project would implement design techniques to
minimize noise impacts to adjacent sensitive uses
including shielding by the proposed building and a 16-
foot-high, 60-foot-long wall located at the eastern end of the loading docks, west of the proposed trash enclosure.

The proposed project would not exceed the maximum
allowable noise exposure standards or the noise limits
established in the Municipal Code, or result in a
substantial increase in ambient noise levels as detailed in Action PS-6d.

The proposed project would comply with the City’s noise ordinance with implementation of RCM NOI-1 and
would not result in any significant noise impacts during the construction period. Vibration impacts during
construction would be less than significant level with
implementation of RCM NOI-2.

The proposed project would not conflict with these
General Plan Policies or actions.

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“Exhibit A”
General Plan Compliance Table
General Plan Goals, Policies, and Actions General Plan Consistency Analysis Action PS-6d: In making a determination of traffic noise impact under the California Environmental Quality Act (CEQA), a significant impact will occur if ambient noise levels have a substantial increase and the resultant noise levels are in excess of the City’s guidelines. Generally, a 3 A-weighted decibel (dBA) increase in noise levels is barely perceptible. Therefore, increases in noise levels shall be considered substantial when the following occurs:
 When existing noise levels are between 60 dBA Ldn and 65 dBA Ldn, a 3 dBA increase in noise will be considered
substantial;
 When existing noise levels exceed 65 dBA Ldn, a 1.5 dBA increase in noise will be considered substantial.

Goal PF-5 Storm Drain System: A community with an efficient, attractive, and environmentally sound storm drain.

Policy PF-5.3 Stormwater Runoff: Encourage that stormwater be directed towards permeable surfaces to allow for more percolation of stormwater into the ground.

Policy PF-5.4 Stormwater Capture: Encourage the use of
professionally designed stormwater capture methods to aid in the reuse of rain water for non-potable uses in compliance with applicable State regulations.

Policy PF-5.6 Stormwater Treatments: Promote Best
Management Practices (BMPs) and Low Impact Development
measures (LID) to treat stormwater before discharge from the site. The facilities shall be sized to meet regulatory
requirements.

Action PF-5b: Project designs shall minimize drainage
concentrations, minimize impervious coverage, utilize pervious paving materials, utilize low impact development (LID)
strategies, and utilize Best Management Practices (BMPs) to reduce stormwater runoff.

Action PF-5c: Promote the use of LID strategies in new
development and redevelopment projects, including but not limited to the use of canopy trees and shrubs, vegetated swales, and permeable paving.

Action PF-5d: Require new development to mitigate increases in stormwater peak flows and/or volume. Mitigation measures, such as LID strategies, should take into consideration impacts on adjoining lands in the City.

Consistent. As detailed in Section 4.10, Hydrology and
Water Quality, the proposed project would include three modular wetland systems and three underground
detention chambers to reduce site discharge during the
100-year, 24-hour peak runoff rate by 40 percent in
accordance with City requirements to reduce flows and
associated erosion potential in Serrano Creek. The
proposed project would also be required to prepare a
Final Water Quality Management Plan (WQMP), as
detailed in RCM WQ-3, consistent with the requirement
of the City’s MS4 permit, because the project consists of significant redevelopment that would replace 5,000 sq ft or more of impervious surface. The Final WQMP would
specify the Site Design, Source Control, LID, and
Treatment Control BMPs that would be implemented to
capture, treat, and reduce pollutants of concern in storm water runoff. Additionally, as specified in RCM WQ-4, a Final Hydrology Study would be required to be prepared, which would demonstrate that the final design of the
proposed project meets the hydromodification
requirements and that, with implementation of
detention facilities and modular wetland systems, the
peak flow of stormwater runoff in the proposed
condition would be less than existing conditions.

The proposed project would not conflict with these
General Plan Policies or actions.

Goal PF-6 Energy Management: A community with adequate power, provided through economically and environmentally sustainable means.

Policy PF-6.2 New Development: Continue to require new
development and redevelopment to provide verification from energy utilities that states they are able to accommodate the additional demand for service.

Policy PF-6.5 Conservation: Promote conservation strategies during design, construction, and maintenance of facilities.

Consistent. As detailed in Section 4.6, Energy, the
proposed project would not result in the inefficient,
wasteful, or unnecessary consumption of energy and SCE
would be able to accommodate the additional demand
for service. The proposed project would obtain
verification from SCE prior to development of the
proposed project. The proposed project would be
required to adhere to all federal, State, and local
requirements for energy efficiency, including the Title 24 standards. Title 24 building energy efficiency standards establish minimum efficiency standards related to
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“Exhibit A”
General Plan Compliance Table
General Plan Goals, Policies, and Actions General Plan Consistency Analysis various building features, including appliances, water
and space heating and cooling equipment, building
insulation and roofing, and lighting, which would reduce energy usage. Additionally, the proposed project will be seeking Leadership in Energy and Environmental Design
(LEED) certification through the applicant’s LEED Volume program. Some of the features included in the design
include, but are not limited to, drought-tolerant
landscaping, low-flow fixtures, high-efficiency lighting and infrastructure for EV charging.

The proposed project would not conflict with these
General Plan Policies.

Goal PF-8 Community Safety: A community protected from illicit activities and crime by high-quality public safety services, facilities, and technology.

Policy PF-8.3 Department Consultation: Promote coordination between the City of Lake Forest and Police and Fire services during the review of new development applications to ensure that adequate attention is being paid to fire and safety concerns during the design and planning of a project.

Policy PF-8.6 Site Design: Recognize the role of site design in crime prevention and implement best practices into existing plans and new development strategies.

Action PF-8a: The Orange County Fire Authority and City Engineer will review proposed development projects and street networks to evaluate the accessibility for fire engines and other emergency response functions.

Consistent. As detailed in Section 4.15, the proposed
project would be required to comply with all Orange
County Fire Authority (OCFA) access requirements and
California Fire Code requirements and all development
projects submitted for review by OCFA must use a fair
share approach to mitigate fire service response impacts and facility/equipment needs.

The proposed project would implement Crime
Prevention through Environmental Design (CPTED)
techniques that would discourage and or reduce crime
from occurring on site. Such CPTED techniques would
include, but not be limited to, surface drive aisle/parking lighting, building façade lighting, low-lying landscaping designed to minimize opportunities for concealment,
continued maintenance activities on the site, and
deadbolts/locks on building exterior doors.

The proposed project would not conflict with these
General Plan Policies or actions.

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Attachment 3
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Planning Commission Agenda Report
Meeting Date: June 4, 2026
Department: Community Development
INITIATED BY: Jennifer Mansur, AICP, Senior Planner
SUBMITTED BY: Gayle Ackerman, AICP, Director of Community Development REVIEWED BY: Amy Stonich, AICP, Assistant Director of Community Development
SUBJECT: SITE DEVELOPMENT PERMIT 06-21-5437 AND
ENVIRONMENTAL IMPACT REPORT (SCH #2024030755)

FOR DEMOLITION OF AN EXISTING BUILDING AND
CONSTRUCTION OF A NEW 165,803 SQUARE FOOT
INDUSTRIAL BUILDING LOCATED AT 26200

ENTERPRISE WAY
EXECUTIVE SUMMARY:

Site Development Permit (SDP) 06-21-5437 is the proposed redevelopment of an

8.83-acre site located at 26200 Enterprise Way. The property is zoned Light Industrial in the Pacific Commercentre Planned Community, which provides for a broad range of industrial uses. The project includes demolition of an existing twostory 144,906 square foot office/industrial building and construction of a new 165,803 square foot, 35-foot tall concrete tilt-up industrial building. Although the tenant for the building has not yet been determined, the proposed project is designed to accommodate a mix of office, manufacturing, and warehouse uses.

The project’s site improvements include 262 parking stalls, a gated truck loading area, landscape improvements, along with off-site intersection improvements at five locations to enhance public safety and address truck turning movements. The project has been designed to meet all applicable requirements in the Pacific Commercentre Planned Community, the City’s Zoning Code, and the Citywide Design Guidelines.

An Environmental Impact Report (“EIR”) was prepared to evaluate potential project-related environmental impacts. The EIR analyzed a full range of environmental topics including aesthetics, agricultural resources, air quality, biological resources, cultural resources, energy, geology/soils , greenhouse gas emissions, hazards and hazardous materials, hydrology and water quality, land use and planning, mineral resources, noise, population and housing, public Item: 2
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services, recreation, transportation and traffic, tribal cultural resources, utilities and service systems, and wildfire.

The analysis identified two areas of significant unavoidable impacts related to greenhouse gas emissions and transportation/vehicle miles travelled (VMT).

Therefore, approval of the project would require adoption of a Statement of Overriding Considerations (SOC) by the Planning Commission. A SOC is a formal finding that a project’s benefits outweigh its significant, unavoidable environmental impacts, allowing the project to be approved under CEQA.

SITE INFORMATION:

Site Address 26200 Enterprise Way
Assessor Parcel Number(s) 610-401-06
Applicant/Agent Chris Sanford, IPT Enterprise
Business Center LLC
Property Owner IPT Enterprise Business Center LLC
General Plan Designation Light Industrial
Zoning District
Light Industrial in Pacific
Commercentre Planned Community (LI
in the PCPC)
Surrounding Area
Land Uses Zoning
North:

Industrial/Office
Condominiums/Neighborhood
Park
LI in the PCPC/
Neighborhood Park in the Nakase
Planned Community
South: Industrial/Office Buildings LI in the PCPC
East: Industrial/Office Buildings/
Single-family Residences
LI in the PCPC,
Estate Homes/Backyard Towns in the
Nakase Planned Community
West: Industrial/Office Buildings LI in the PCPC
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Location Map
RECOMMENDED ACTION(S):

Adopt the following resolutions

1. A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF

LAKE FOREST ADOPTING ENVIRONMENTAL FINDINGS PURSUANT

TO THE CALIFORNIA ENVIRONMENTAL QUALITY ACT, ADOPTING A

STATEMENT OF OVERRIDING CONSIDERATIONS, CERTIFYING THE

IPT ENTERPRISE BUSINESS CENTER LLC PROJECT FINAL
ENVIRONMENTAL IMPACT REPORT (SCH #2024030755), ADOPTING

THE MITIGATION MONITORING AND REPORTING PROGRAM,
APPROVING SITE DEVELOPMENT PERMIT 06-21-5437, AND
APPROVING THE PROJECT;

2. A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF LAKE FOREST, APPROVING SITE DEVELOPMENT PERMIT 06-21-5437 FOR THE

DEMOLITION OF AN EXISTING BUILDING AND THE CONSTRUCTION OF A NEW INDUSTRIAL BUILDING LOCATED AT 26200 ENTERPRISE WAY Item: 2
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BACKGROUND:

In 1942, the Federal government established a 4,682-acre military base adjacent to the future western boundary of Lake Forest, known as the Marine Corps Air Station (MCAS)- El Toro. The base served as the major west coast jet fighter facility and included 4 aircraft runways. The departure path for Runway 7 crossed directly over the center of the Lake Forest. Due to safety concerns and extreme noise levels, the land directly under
the flight path was restricted to nonresidential uses, such as agriculture, open space, and
industrial/office use (See Graphic
1). In the 1980’s, the County of
Orange approved the planned
communities of Foothill Ranch,
Portola Hills, Baker Ranch and
Pacific Commercentre, each of
which restricted the land under the
flight path to non-residential uses.

During the 1990’s, significant
construction occurred in these
communities, except for portions of
Baker Ranch, Portola Hills and the
Nakase Nursery site, which
remained as open space and
agriculture.

The closure of MCAS- El Toro was
announced in 1993 and a plan to
redevelop the Base property with
residential and open space use
was approved by the City of Irvine
in 2002. This allowed for the
reconsideration of the remaining
vacant land in Lake Forest, which
was no longer constrained by the
former flight path. From 2004-2010,
the city studied land use changes
through “The Opportunities Study”
(OSA) and adopted new plans for
Portola Hills, Baker Ranch, and other vacant properties that allowed for approximately 5,000 residential units to be constructed adjacent to the existing industrial and business park uses. In 2020, the Nakase Nursery site was Graphic 1: Non-Residential Land Use
Restriction Area
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purchased by Toll Brothers, and the City ultimately approved 663 residential units as part of the Meadows residential development (“Meadows”). The Meadows is adjacent to industrial/business park properties in the Pacific Commercentre community, which was approved by the County of Orange in 1987, and developed with business park/industrial uses in the 1990’s and early 2000’s. The timeline of development is shown in Graphic 2.

Enterprise Way and Enterprise Court Industrial Areas
The project site is located in the existing industrial area on the southeast corner of Dimension Drive and Bake Parkway in the Pacific Commercentre Planned Community. The Pacific Commercentre Planned Community was adopted by the County of Orange in 1987. The original Planned Community included 4 zoning designations, including Business Park, High Technology, Light Industrial and Open Space. This industrial area (accessed from Enterprise Way) is zoned Light Industrial in the Pacific Commercentre Planned Community. As shown in Graphic 3, this industrial area is accessed via the private street, Enterprise Way, which intersects Dimension Drive in two locations, and a driveway on Bake Parkway. In the 1990s and 2000s, the 8 industrial parcels adjacent to Enterprise Way were developed. Enterprise Way is a private street that is located on the 8 adjacent parcels and maintained by the MSGW/Pacific Commercentre Owner Association.

In addition, as shown by the yellow dashed lines on Graphic 3, the properties were developed with reciprocal access between some of the parcels. Subsequently, the properties accessed off Enterprise Court, a private drive aisle, were developed.

Graphic 2: Development Timeline
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These parcels also have reciprocal access between the parcels (orange dashed line on Graphic 3), but do not have any reciprocal access to the project site. The is no direct vehicular access from this industrial area to the adjacent Meadows.

History of Project Site
The project site, 26200 Enterprise Way, is located within the Pacific Commercentre Planned Community with a zoning designation of LI – Light Industrial. With the exception of the northeast portion of the project site, which appears to have been utilized for orchards from approximately 1938 to 1952, the proposed project site was vacant and undeveloped land from at least 1930 until 2000. The City’s Planning Commission originally approved Site Development Permit 1997-53, which included the development of the building at 26200 Enterprise Way in 1997.

Graphic 3: Enterprise Way and Enterprise Court Industrial Area Item: 2
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Subsequent Changed Plans and a Site Development Permit were approved to modify the building and add fuel cells in the parking lot. The existing two-story tiltup building is 144,906 square feet and a certificate of occupancy was issued for the building in 2000. From 2000 to 2021 the existing building was occupied by avionic corporations (Matsushita Avionics Systems (2000–2005), and Panasonic Avionics Corporation (2006–2021)). Panasonic Avionics Corporation used the building as an office, manufacturing, and research testing facility. The existing building has been vacant since the Panasonic Avionics Corporation left the facility in 2021.

Meadows Residential Development
The Meadows is located northeast/east of the project site. In 2020, the Lake Forest City Council certified an Environmental Impact Report, and approved a General Plan Amendment, Zone Change, Area Plan, Vesting Tentative Tract Map, and Development Agreement for the Meadows Residential Project. The EIR for the project identified two potential areas of significant unavoidable impacts, Agricultural Resources and Greenhouse Gas Emissions, for which the City Council adopted a Statement of Overriding Considerations. The EIR and Area Plan for the Meadows recognized the proximity of the adjacent industrial properties and Graphic 4: Landscape Buffers
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included a block wall and ensured there were landscape buffers (on three different properties) between the uses (See Graphic 4). Landscaping on the project site (26200 Enterprise Way) is only directly adjacent to one lot at the Meadows. This landscape area is circled in red on Graphic 4 and Graphic 5 includes photos that show the existing landscaping in this area (as viewed from the project site). The photos also include the existing landscape berm that buffers the Meadows from the adjacent industrial property (26210 Enterprise Way) and the perimeter landscaping on the project site.

Additionally, the residential and industrial properties were not connected by any streets or walkways. When the residential development was approved, the City determined that the Meadows, which included the block wall and landscape buffers, was compatible with the surrounding area, including the existing adjacent light industrial zoned properties.

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Environmental Background
The City initially prepared and released an Initial Study/Mitigated Negative Declaration (IS/MND) for the project on September 5, 2023. During public review, commentors raised concerns regarding the potential for significant environmental impacts, prompting the City to require preparation of an Environmental Impact Report (EIR).

The purpose of an EIR is to identify and evaluate the potential environmental impacts of a proposed project, disclose those impacts to decision-makers and the public, and identify feasible ways to avoid or mitigate significant effects.

A Notice of Preparation (NOP) was issued on March 20, 2024, and circulated for an extended 56-day review period, during which public and agency comments were received and two public scoping meetings were held. Based on input received, the City prepared a Draft EIR evaluating the project’s environmental impacts, including completion of AB 52 tribal consultation. The City completed AB 52 consultation with the Gabrieleño Band of Mission Indians – Kizh Nation on May 11, 2025. Further, three alternatives were evaluated to provide additional information to the decision-makers when considering the Project.

The Draft EIR was released for public review from July 10 through September 15, 2025, during which 122 comment letters were received. Responses to comments were prepared, and no significant new information requiring recirculation was identified. The Final EIR has been completed and is now presented for Planning Commission consideration.

PROJECT DESCRIPTION:

The proposed project consists of the demolition of the existing 144,906 square foot (sq ft), two-story office/industrial building. The building will be replaced with a new 35-foot-tall, 165,803 sq ft tilt-up concrete industrial building on the 8.83-acre site at 26200 Enterprise Way. The proposed project is designed to accommodate a mix of permitted light industrial uses, including office, manufacturing, and warehouse operations, and includes on-site parking, truck loading areas, landscaping, and five associated off-site intersection improvements. Specifically, up to 10,000 sq ft could serve as office space, up to 65,000 sq ft for manufacturing, and 90,803 sq ft of warehouse use. The applicant proposes 24-hour operation of the future industrial use; however, a specific tenant has not been identified, which is typical for this type of development.

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Proposed Site Plan
Vehicular access to the project site would continue to be provided via two existing driveways on Enterprise Way and the existing shared drive aisle that connects to the adjacent property at the north corner of the site. Graphic 6 includes the proposed site plan for the project. Generally, the main drive aisle and parking stalls are designed around the building. The southwest side of the building includes a truck loading area comprised of 23 truck doors that are elevated off the ground to allow trucks to be loaded from the building or unloaded directly into the building.

This area is gated and has been designed to allow for WB 40 trucks at all truck doors, and WB 67 trucks at the truck doors on either end of the loading area. A WB 40 truck is a medium-sized semi-trailer truck with a roughly 40-foot wheelbase, which is the distance between the center of the front axle and the center of the rear axle group. Similarly, a WB 67 is a large semi-trailer truck with a roughly 67-foot wheelbase. WB 67s are commonplace and used by many businesses serving industrial and commercial businesses. The truck
loading area includes a 16-foot tall 60-foot long
wall (#3 on Graphic 6) along the east side of the
area to minimize noise impacts from trucks in the
loading area, two roofed trash enclosures (#4 on
Graphic 6), and a 14-foot tall, approximately 500
square foot enclosed pump room (#5 on the
Graphic 6) for fire sprinkler equipment. These
structures will be constructed of tilt-up concrete
and painted to match the primary building.

Vehicle and Bicycle Parking
The project includes 262 parking stalls. In
accordance with state and zoning regulations,
some of the parking stalls have special
designations. The types and number of
designated parking stalls are listed in Table 1.

The project also provides 31 bicycle parking
spaces, including interior and exterior racks, and
secure indoor storage, in compliance with State
requirements.

Table 1: Vehicle Parking
Designations
Type of Parking
Designation # of stalls
Accessible
(Handicapped) 8
Electrical Vehicle
Supply
Equipment
(EVSE)
14 EVSE Accessible 2
Electrical Vehicle
(EV) Capable1 53
Carpool 24
Vanpool 2
Rideshare
loading spaces 4
Standard parking
stalls 155

1. EV Capable stalls provide
electrical infrastructure for
future EV chargers.

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Landscaping and Lighting
Landscaping and mature trees are present around the perimeter of the site. The project proposes to maintain this existing perimeter landscaping, including many mature trees. New trees are proposed where there is a gap in the trees in the perimeter landscaping and new shrubs and ground cover are proposed in the landscape area between the driveways along Enterprise Way. As shown on the landscape plans (sheet L1.0 of PC Attachment 4), new landscaping is proposed around the new building, which includes trees, shrubs, and groundcover.

Graphic 6: Proposed Site Plan
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Additionally, as noted on the plans, the electrical transformers on the site will be screened with landscaping (per Southern California Edison Guidelines) and the trash enclosure will be screened with vines and shrubs
In addition, the size and location of the existing landscape buffer between the Meadows and project site, as described in the background section and shown on Graphic 4, is proposed to remain. Landscaping adjacent to the property line shared with the Meadows (area circled red in Graphic 4) would be enhanced with 5 new trees (minimum 36” box size) to provide additional screening from the residential development.

New proposed on-site lighting includes new parking lot lights (maximum height of 25 feet), and accent lighting on the building. All lighting would be LEDs (light emitting diodes) and would be downlit to prevent light spillage onto adjacent sites.

Architecture
The proposed building is a maximum of 35 feet tall and would be constructed of architecturally enhanced tilt-up concrete panels. The building is proposed to be painted different shades of gray with a blue accent color. Architectural detailing includes articulated facades, varied rooflines, windows, and enhanced entry features. The truck doors, which would be painted to match the building, would be located on the south elevation of the building, and would not be readily visible from the surrounding streets nor from residential properties. PC Attachment 5, are simulated views of the building from the adjacent residential properties, as provided by the applicant.

Sustainability Features
The proposed project will be seeking Leadership in Energy and Environmental Design (LEED) certification through the applicant’s LEED Volume program. Some of the features included in the design will include, but not be limited to, droughttolerant landscaping, low-flow fixtures, high-efficiency lighting, solar, and infrastructure for EV charging. A condition of approval has been included in the draft resolution to ensure the project obtains this LEED certification.

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Proposed Intersection Improvements
The project includes five off-site intersection improvements to enhance public safety and facilitate large truck (WB 67) turning movements for the proposed project and existing truck traffic from nearby businesses. The off-site improvement plans for the five intersections are included with the project plans (Attachment 4).

The location of the five intersection improvements can be seen on Graphic 8 and the following is a summary:

1. Bake Parkway and Commercentre Drive: Update signal to protected left turns, add dual westbound left-turn lanes as a shared through/right lane, and upgrade signal equipment.

2. Bake Parkway and Dimension Drive: Extend the westbound left-turn lane (430 ft), modify the median, and upgrade signal equipment.

3. Dimension Drive/Commercentre Drive – Enterprise Way: Upgrade signal to protected left turns, widen the southeast corner for truck turning, and update signal equipment.

4. Lake Forest Drive and Dimension Drive: Add/extend northbound (250 feet) and eastbound (205 feet) left-turn lanes and upgrade signal equipment.

5. Lake Forest Drive and Rancho Parkway: Add a northbound right-turn lane (225 feet) and extend left-turn lanes (470 feet northbound, 440 feet southbound), along with signal upgrades. Impacts from these improvements are evaluated in the EIR.

ANALYSIS:

Compliance with General Plan:

The project site is designated Light Industrial (“LI”) on the General Plan Land Use Element Map. The LI designation “provides for a variety of light industrial uses that are non-polluting and which can co-exist with surrounding land uses, and which do not create smoke, gas, dust, noise, vibration, soot, or glare which might be obnoxious or offensive to persons residing or conducting business in the City.” The proposed industrial use is consistent with the purpose and intent of the LI designation, as is not expected to generate obnoxious or offensive conditions, as documented in detail in the technical studies prepared for the project and included in the EIR (PC Attachment 3). Furthermore, the maximum allowable floor area ratio (FAR) for the LI designation is 0.6:1 and the proposed facility meets this requirement with a FAR of 0.43: 1.0. Lastly, as detailed in the “General Plan Policy Item: 2
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Compliance Table” (Exhibit A of PC Attachment 2) the project is consistent with the applicable goals and policies in the General Plan. Accordingly, the project is in compliance with the City’s General Plan.

Compliance with Zoning Code:

The project site is located in the Light Industrial (LI) zoning district in the Pacific Commercentre Planned Community, which requires a Site Development Permit for the development of the new industrial building. The LI Zoning District is intended to provide for a broad range of industrial uses, as specified in the City’s Municipal Code Section 9.72.090 (Non-Residential Land Use Matrix), column “I” (Attached as PC Attachment 6). Pursuant to this Code Section, the proposed office, manufacturing and warehouse uses are considered “Permitted Uses” in this zoning district.

As shown in Table 2, the proposed project is in compliance with all applicable zoning site development standards, including but not limited to, the minimum setbacks and maximum building height. In addition, the proposed boundary Graphic 8: Proposed Street Intersection Improvement Locations Item: 2
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landscaping adjacent to Enterprise Way, has a minimum depth of 12 feet 10 inches, which is in compliance with the Planned Community requirements for boundary landscaping minimum depth (5 feet) and the minimum average depth (10 feet). Furthermore, as conditioned, the project will comply with the City’s water efficient landscape requirements, in Zoning Code Section 9.146.110.

Parking and Circulation
The proposed circulation and parking layout was designed in compliance with applicable zoning requirements (Chapter 9.168 of the Zoning Code), including but not limited to the parking stall size requirements and drive aisle minimum width requirements. Additionally, the project plans (PC Attachment 4) demonstrate that the on-site drive aisles provide sufficient clear widths and turning radii to accommodate WB-67 truck circulation at the site. The City’s traffic engineer reviewed the plans and determined that the plans meet engineering standards.

Table 2: Applicable Building Development Standards
Zoning Development Standards Requirement Proposed
Minimum Setbacks
from property line on Enterprise
Way
15 feet 92 feet 6 inches1
from Enterprise Court 15 feet 90 feet 4 inches1
from north property line
abutting industrial property
(26190 & 26180 Enterprise Way)
0 feet 70 feet 6 inches1
From east property line abutting
multiple industrial properties
(26210 Enterprise Way, 26220,
26222, 26242, 26248 Enterprise
Court)
0 feet 64 feet 6 inches1
From north property line abutting
the Meadows Residential
Community
N/A 160 feet1
Maximum Building Height No maximum 2 35 feet

1. Approximate distances based on scaled plans

2. “Except that building heights shall comply with the provisions of Section

9.144.050 (Height Limits) of the Lake Forest Municipal Code. Within the High Technology and Light Industrial Planning Areas, prior to the issuance of any building permit for any structure or buildings which are proposed to be greater than 35 feet above the proposed grade elevation, applicant shall obtain approval of a Use Permit.”
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Additionally, as demonstrated in Table 3, the proposed project provides 262 parking stalls, which exceeds the required 261 parking stalls Compliance with Chapter 9.160 (Facility Design Requirements) The City’s Zoning Code Chapter 9.160 (Facility Design Requirements) includes transportation demand management strategies to mitigate the impacts that development projects may have on transportation mobility, congestion and air quality. Based on the employment generation factors in Zoning Code Section

9.160.030(D), which estimate the building could have 250 employees, the regulations in this Chapter are applicable to this project. Zoning Code Section

9.160.040 includes regulations related to carpool and vanpool parking stalls, bicycle parking, shower and locker facilities, a commuter information area, rideshare vehicle loading spaces, and bus shelters. The proposed site plan (Sheet A1-2P of PC Attachment 4) for the project shows the location for the required carpool parking stalls, vanpool parking stalls, bicycle parking stalls, and rideshare loading parking stalls, in compliance with the code requirements. Additionally, the proposed floor plan (Sheet A2-1P of PC Attachment 4) provides for the required shower facilities, locker facilities, and commuter information area.

Staff has recommended conditions of approval, that are documented in the draft resolution for the SDP (PC Attachment 2), to ensure compliance with applicable code requirements as reflected on the project plans. Additionally, in accordance with Zoning Code Section 9.16.040, a condition of approval has been recommended requiring the applicant to design and construct a bus shelter with a solar-powered light, bus bench, and trash receptacle for the existing bus stop located on the northwest corner of the intersection of Dimension Drive at Commercentre Drive/Enterprise Way, per Orange County Transportation Authority Guidelines. These conditions are also documented as regulatory compliance measure in the EIR. Accordingly, the project, as conditioned, is in compliance with Zoning Code Chapter 9.160.

Table 3: Parking Compliance
Use Parking Requirement
Bldg.

Square
Feet
Stall
Required
Office 1 for each 250 sf of floor area 10,000 40
Manufacturing 1 for each 500 sf of floor area 65,000 130 Warehouse 1 for each 1,000 sf of floor area 90,803 91
Total Required: 261
Total Provided: 262
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Compliance with Citywide Design Guidelines:

The Citywide Design Guidelines provide general guidelines for site layout, architecture/building design, and landscaping. The guidelines may be interpreted with some flexibility and are evaluated on overall consistency with their purpose and intent. The project site is located in the Pacific Commercentre/Baker Ranch Business Park Design Guideline Area. The project complies with applicable design guidelines, as summarized below:
• Transitions in Land Use section of the Design Guidelines - The building would be located over 150 feet from the closest property line to a single-family residence, and an approximately 60-foot-wide (minimum) onsite landscaped slope would buffer the industrial project from the shared property line of the adjacent single-family residential community. • Architecture and Building Design section of the Design Guidelines - The building architecture would utilize scoring, color transitions, and windows to provide articulation to long facades of the building to create visual interest.
• Architecture and Building Design section of the Design Guidelines - The building architecture features low, medium, and high elevation elements.
• Architecture and Building Design section of the Design Guidelines - The main building entrance, which faces Enterprise Way, would be emphasized with vertical and horizontal bands, windows, and decorative light sconces. Building articulation would be provided at the entrance by changes in the façade planes and height variation in roof line. These architectural features make the main entrance easily identifiable and the architectural focal point of the building.
• Architecture and Building Design section of the Design Guidelines - The building has been designed with a built-in rooftop well to screen the rooftop mechanical equipment.
• Vehicular Access/Circulation/Parking section of the Design Guidelines - The vehicular entrances to the site would be flanked by landscaping that includes, trees, hedges and landscaped berms.
• Parking Lot Landscaping section of the Design Guidelines - The project would maintain and/or enhance the existing perimeter landscaping around the entire site, which screens the parking areas.

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Compliance with Building, Fire and State Code Requirements The City’s Building Official provided a preliminary review of the plans for compliance with California Building Standards Code (CBSC) requirements that may affect the project design. This review included, but was not limited to, proposed accessible (handicapped) parking, accessible pathways, EV charging, bicycle parking requirements, building exiting, height, shade tree requirements, and area per occupancy classification and construction type. The City’s Building Official determined that based on the preliminary review, the plans were in compliance with these requirements. A full review of the project’s compliance with the CBSC will occur during the review of the construction drawings for building permit issuance.

Additionally, this project has been preliminarily reviewed by the Orange County Fire Authority for compliance with OCFA’s codes and guidelines. OCFA has recommended several conditions of approval providing for Code compliance and fire safety, which are included in the attached draft resolution (PC Attachment 2).

Additionally, OCFA has review processes for future tenant of the building, including but not limited to, any hazardous materials storage, equipment, processes or operations, high-piled storage, and battery systems.

Business Association Approvals
The project has received preliminary approvals from the Master Pacific Commercentre Owners Association and the MSGW/Pacific Commercentre Owner Association. The applicant is required to comply with these Association’s CC&Rs and any required future approvals.

Intersection Improvements
As previously discussed, the project includes intersection improvements to five different intersections in the vicinity to accommodate the turning radii for WB 67 trucks to the site. The City’s traffic engineer reviewed all five intersection improvement plans (included in the plans, PC Attachment 4) and determined that the plans meet all applicable engineering standards. Conditions of approval have been included in the draft resolution for the SDP (PC Attachment 2) requiring the applicant to obtain encroachment permits for street improvements and traffic signal modification plans for the 5 intersection projects prior to issuance of building permits for the project. Additionally, a condition of approval has been recommended requiring all intersection improvements to be constructed prior to issuance of a certificate of occupancy for the industrial building. These intersection improvements will provide safer truck routes for all the existing industrial businesses in the Light Industrial area that already utilize WB 67 trucks.

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Compatibility with Surrounding Uses
The project site is bordered to the north, south, and west by existing one- and twostory industrial buildings. The recently constructed Meadows residential development, which consists of single-family residences, a senior apartment complex, and local parks, is located to the northeast/east of the project site.

As previously discussed, the proposed industrial building is located within the Light Industrial district of the Pacific Commercentre Planned Community. The Pacific Commercentre Planned Community was developed as a master planned industrial business park with local streets providing internal circulation. The buildings in the Planned Community include a mix of warehouse, distribution, manufacturing, research and development, and offices. The proposed industrial building is consistent with the type, scale, and intensity of the existing industrial development in the Pacific Commercentre Planned Community.

Additionally, the proposed building is compatible with the architecture of the existing industrial buildings in the Pacific Commercentre Planned Community. The proposed building would be constructed of architecturally enhanced tilt-up concrete panels and would be painted varying shades of gray with a blue accent.

The building architecture utilizes scoring, color transitions, and windows to provide articulation to the facades of the building. The truck doors, which would be painted to match the building, would be located on the south elevation of the building, and would not be readily visible from the surrounding streets or residential properties.

Meadows Residential Community
As discussed in the background section, the adjacent Meadows residential community was approved by the City Council in 2020. The EIR and Area Plan for the Meadows recognized the proximity of the adjacent industrial properties, included a block wall, and ensured there were landscape buffers between the uses (See Graphic 4). Additionally the residential and industrial properties were not connected by any streets or walkways. This project will maintain the block wall and landscape buffers that separate the Meadows and the industrial area. Additionally, the proposed project will enhance the landscaping, including adding trees, along the northeastern corner of the project site, adjacent to the Meadows. This new landscaping will further reduce the visibility of the project site as viewed from the Meadows. A condition of approval has been recommended in the resolution that requires the applicant to propose new landscaping in any existing landscape areas where the landscaping has not been maintained.

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Planned Community text, there is no minimum building setback required from the adjacent properties. However, as shown in Graphic 9, the proposed building would provide a setback approximately 150-160 feet from the side/rear yard property lines of the adjacent single-family residential properties along Burwood.

Furthermore, the project is designed so that the truck docks and loading area of the proposed building are oriented to the southeast (i.e., not facing the residential properties), are located over 200 feet away from the nearest residential property line, and would not be readily visible from the residences.

The EIR for this project, which included technical studies and analysis, concluded that there were no significant impacts to the surrounding area, including the sensitive receptors at the Meadows, related to noise, vibration, local traffic impacts, health risks, and lighting/glare.

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Environmental Review Summary (CEQA Process and Findings) The City of Lake Forest, as Lead Agency under the California Environmental Quality Act (CEQA), prepared an Environmental Impact Report (EIR), through the City’s consultant LSA, to evaluate the potential environmental effects of the proposed IPT Enterprise Business Center project. The EIR was initiated following preparation of an Initial Study/Mitigated Negative Declaration (IS/MND) in September 2023, after which public comments identified the potential for significant environmental impacts requiring a higher level of review.

A Notice of Preparation (NOP) was issued in March 2024, and the City conducted an extended public scoping process, including agency consultation and public meetings, to identify environmental issues for analysis. The NOP was distributed to responsible and trustee agencies in accordance with CEQA Guidelines Section 15082. The Draft EIR was subsequently prepared using technical studies and public input to evaluate a full range of environmental topics, including aesthetics, agriculture and forestry resources, air quality, biological resources, cultural resources, energy, geology and soils, greenhouse gas (GHG) emissions, hazards, hydrology and water quality, land use, mineral resources, noise, population and housing, public services, recreation, transportation and traffic (VMT), tribal cultural resources, utilities, and wildfire.

The Draft EIR identified several key areas of concern raised during the environmental public review process, including air quality, greenhouse gas emissions, and traffic impacts through vehicle miles traveled (VMT). These issues were fully analyzed and, where feasible, mitigation measures were incorporated into the project to reduce impacts. Mitigation measures were identified that would reduce impacts to less-than-significant levels in areas such as air quality, geology and soils, and tribal cultural resources. However, the EIR determined that the project would result in significant and unavoidable impacts in two areas:
transportation/ VMT and GHG emissions.

Transportation/VMT:

The project would generate additional employee and truck trips, resulting in an increase in vehicle miles traveled (VMT) on the regional roadway network. Under CEQA Guidelines Section 15064.3(b), VMT is the primary metric used to evaluate transportation impacts. The project’s VMT exceeds applicable thresholds, primarily due to the nature of employment uses and associated employee trip generation. The VMT analysis does not take into consideration the previous VMT generated by the existing office/industrial building, because the building is vacant. However, it should be noted that the existing office/industrial building when occupied, would potentially generate more employees than the proposed building.

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Mitigation Measures added to this project to reduce VMT include the installation of new bicycle lanes in both directions on Commercentre Drive between Alton Parkway and Dimension Drive. These bike lanes on Commercentre Drive would connect the proposed project site on Enterprise Way to the existing bike lanes on Alton Parkway, which eventually connects to the Irvine Transportation Center, a multi-model transit hub including Metrolink and Amtrak commuter train services and OCTA bus services.

Additionally, a mitigation measure was included for this project requiring the installation of pedestrian-scale lighting along the on-site pedestrian pathway between the primary building entrance and the public right-of-way, leading to the existing bus stops. These mitigation measures encourage alternative forms of transportation including bikes, OCTA buses, and the Metrolink.

Although the project includes operational features and off-site improvements, and incorporates feasible mitigation measures to improve circulation, safety, and truck access, these measures do not reduce the project’s VMT impacts to a less-than-significant level. Thus, impacts to transportation and traffic would be significant and unavoidable.

Therefore, the project would result in a significant and unavoidable projectlevel VMT impact. Additionally, because VMT is influenced by regional travel patterns and cumulative development, the project’s contribution would be cumulatively considerable, resulting in a significant and unavoidable cumulative transportation impact.

Greenhouse Gas (GHG) Emissions:

The project would generate GHG emissions from building operations, energy use, and vehicle trips associated with employees and truck activity.

The Draft EIR determined that the Project would not result in any significant impacts related to mass emissions, and no mitigation is required for this threshold.

However, because the Project will have significant and unavoidable impacts to VMT, the proposed Project would not contribute its “fair share” of emission reductions required to support SB 743 and the 2022 Scoping Plan. As a result, the Project would conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing GHG emissions.

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under CEQA thresholds. Therefore, the project’s contribution to cumulative climate change impacts remains significant and unavoidable.

Significant and Unavoidable Impacts
Under CEQA, when a project would result in significant unavoidable impacts, the decision-making body must make specific findings prior to project approval. These findings document the Lead Agency’s conclusions regarding each significant impact and the feasibility of mitigation.

The Final EIR, which consists of the Draft EIR, technical appendices, all written comment letters received, and any errata to the Draft EIR represents the City’s independent judgement of the environmental impacts of the proposed project. As identified in the Final EIR, the project would result in significant and unavoidable impacts.

Accordingly, following adoption of
the required findings of fact,
CEQA Guidelines Section 15093
requires adoption of a Statement
of Overriding Considerations
(SOC), which is a written
determination that the project’s
economic, legal, social,
technological, or other benefits
outweigh its unavoidable
environmental impacts. The
findings of fact and SOC are
included in Attachment 1 and
acknowledge these impacts while
determining that the project
benefits justify approval. In the
last 15 years, the City has
approved 5 EIRs, all of which
included the adoption of a SOC by
the City Council. Table 4 provides
a list of the 5 EIRs and the
significant and unavoidable
impacts from each project. Four of
these EIRs (all except the
General Plan Update), were certified prior to the requirement for EIRs to provide a VMT analysis.

Table 4: Project Level EIRs certified by
the City with SOC
Project EIR Significant and
Unavoidable Impacts
General Plan
Update (2020)
Agricultural Resources,
Air Quality, and
Wildfires (Hazards)
Irreversible Effects
Meadows
residential
development
(2020)
Agricultural Resources
and Greenhouse Gas
Emissions
Portola Center
residential
development
(2013)
Air Quaility, Greenhouse
Gas Emissions
Shea Baker
residential
development
(2012)
Air Quaility, Greenhouse
Gas Emissions
Serrano Summit
residential
development
(2011)
Air Quality
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EIR Public Review
The Draft EIR was circulated for an extended 67-day public review period, exceeding CEQA’s minimum requirements. During this time, the document was made available at multiple public locations and online, and the City received a substantial number of comment letters from agencies and the public. The City has prepared written responses to all written comments received and has provided written proposed responses to public agency comments at least 10 days prior to considering the Final EIR, as required by State CEQA Guidelines section 15088.

None of the comments on the Draft EIR presented significant new information requiring recirculation of the EIR under State CEQA Guidelines section 15088.5.

CONCLUSION:

The proposed IPT Enterprise Business Center project represents the redevelopment of an underutilized industrial property with a modern facility that is consistent with the City’s General Plan, applicable zoning regulations, and Citywide Design Guidelines. The project has been designed to be compatible with surrounding land uses and incorporates features to minimize potential impacts to adjacent properties.

The City has conducted a comprehensive environmental review in accordance with CEQA, including an extended public engagement process. The EIR provides a thorough evaluation of the project’s potential environmental effects and identifies mitigation measures to reduce impacts where feasible.

While the majority of environmental impacts can be mitigated to less-thansignificant levels, the EIR identifies significant and unavoidable impacts related to greenhouse gas emissions and transportation/VMT. These impact areas reflect broader regional and cumulative conditions that cannot be fully addressed at the project level, despite implementation of all feasible mitigation measures.

The Planning Commission, as the decision-making body, must consider the EIR, the recommended findings, and all public testimony in determining whether the project should be approved. If the Commission determines that the project’s benefits, such as redevelopment of an underutilized site, job creation, and consistency with planned industrial land uses, outweigh the identified significant unavoidable impacts, they may consider adoption of a Statement of Overriding Considerations in compliance with CEQA.

Based on the analysis provided in the staff report, the Final EIR, and the proposed conditions of approval, the project has been reviewed for consistency with applicable regulations and environmental standards and is presented for the Planning Commission’s consideration.

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RECOMMENDATION:

Staff recommends that the Planning Commission adopt the two attached draft resolutions for this project. The first resolution is related to the EIR (PC Attachment 1) and includes the following actions:
• Adoption of environmental findings of fact pursuant to CEQA, • Adoption of a Statement of Overriding Considerations, • Certification of the EIR, and
• Adoption of the mitigation and monitoring reporting program for the Project. • Direction to staff to prepare, execute, and file a Notice of Determination with the Orange County Clerk and SCH within five (5) working days of Project approval.

The second resolution (PC Attachment 2) will approve the Site Development Permit for the project based on the findings documented in the resolution with the staff recommended conditions of approval. The adoption of this resolution is contingent upon the adoption of the first resolution related to the EIR.

PUBLIC NOTICING:

In accordance with the requirements of Section 9.184.040(C)(2) of the Municipal Code of the City of Lake Forest, this project has been noticed in a newspaper of general circulation and public notices were posted at City Hall and sent to owners of all property within 300 feet of the project boundary on May 21, 2026. In addition, on May 21, 2026, the public notice was emailed to the project’s interest list, that includes anyone who provided written comments during the EIR public review periods. Since the public notice was made available, the City has received written public comments regarding the project. Comments received prior to May 28, 2026 (at noon) are included in PC Attachment 7.

ATTACHMENTS:

1. Draft Resolution adopting environmental findings pursuant to CEQA, adopting statement of overriding considerations, certifying the IPT Enterprise Business Center, LLC project final EIR, and adopting a mitigation monitoring and reporting program.

2. Draft Resolution approving SDP 06-21-5437
a. General Plan Compliance Table

3. Final and Draft EIR (link to documents on City’s website)

4. Plans

5. Simulated View of Project from Residential properties

6. Zoning Code Section 9.72.090 (A)- Land Use Matrix

7. Public Comment Letters
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PC ATTACHMENT 1
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RESOLUTION NO. PC 2026-____

A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY

OF LAKE FOREST ADOPTING ENVIRONMENTAL FINDINGS

PURSUANT TO THE CALIFORNIA ENVIRONMENTAL QUALITY

ACT, ADOPTING A STATEMENT OF OVERRIDING

CONSIDERATIONS, CERTIFYING THE IPT ENTERPRISE

BUSINESS CENTER LLC PROJECT FINAL ENVIRONMENTAL
IMPACT REPORT (SCH #2024030755), ADOPTING THE

MITIGATION MONITORING AND REPORTING PROGRAM,
APPROVING SITE DEVELOPMENT PERMIT 06-21-5437, AND

APPROVING THE PROJECT
WHEREAS, the Project involves the demolition of the existing 144,906- square-fot (sq ft), two-story office/industrial building and redevelopment, construction and operation of a 35-foot (ft) tall, 165,803 sq ft tilt-up concrete industrial building. The project includes a gated truck loading area, truck and auto parking spaces, and new landscaping throughout the site. Although the tenant has not been determined yet, the proposed project includes a mix of office, manufacturing, and warehouse space. Additionally, the project includes off-site improvements at five intersections within the City to enhance public safety and address concerns related to large truck turning movements. The project will require approval of Site Development Permit 06-21-5437 by the City, Secured Fire Protection Agreement and Fire Master Plan by the Orange County Fire Authority (OCFA), a Warehouse Operations Notification and annual documentation demonstrating compliance with Rule 2305 to the South Coast Air Quality Management District (SCAQMD); and
WHEREAS, The 8.83-acre project site is located at 26200 Enterprise Way in the north-central portion of Lake Forest in Orange County, California, 92630 (Assessor’s Parcel Number [APN] 610-401-06). The project site currently consists of a 144,906-square-foot (sq ft), two-story tilt-up office/industrial building which was previously used as an office, manufacturing, and research testing facility by Panasonic Avionics but has been vacant since 2021. The areas surrounding the project site consist of a mix of land uses, including industrial and residential uses.

The project site is bordered to the north, south, and west by existing industrial buildings that include a mix of allowable uses including office, manufacturing, and warehouse uses. The recently constructed Meadows Residential Development (formerly the Nakase Nursery site) is to the northeast/east of the project site. Local access to the project site is provided by Enterprise Way, which is accessed from Dimension Drive. Bake Parkway is approximately 0.11 miles north, Lake Forest Item: 2
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Drive is approximately 0.4 miles south, and SR-241 is approximately 0.7 miles north of the project site; and
WHEREAS, pursuant to section 21067 of the Public Resources Code, and section 15367 of the State CEQA Guidelines (Cal. Code Regs., tit. 14, § 15000 et seq.), the City of Lake Forest is the lead agency for the proposed Project; and WHEREAS, in accordance with State CEQA Guidelines section 15063, the City evaluated the Project by preparing an Initial Study, to determine whether an Environmental Impact Report (“EIR”) was required; and
WHEREAS, based on the Initial Study, the City determined that a Mitigated Negative Declaration should be prepared; and
WHEREAS, the City received subsequent comments indicating the potential for significant environmental impacts; and
WHEREAS, in accordance with State CEQA Guidelines section 15082, on March 20, 2024, the City sent to the Office of Planning and Research and each responsible and trustee agency a Notice of Preparation (“NOP”) stating that an Environmental Impact Report (“EIR”) (State Clearinghouse Number #2024030755) would be prepared; and
WHEREAS, 120 comment letters were received in response to the NOP; and
WHEREAS, pursuant to Public Resources Code section 21083.9 and State CEQA Guidelines sections 15082(c) and 15083, the City held duly noticed Scoping Meetings on April 3, 2024 and April 24, 2024, to solicit comments on the scope of the environmental review of the proposed Project; and
WHEREAS, a Draft Environmental Impact Report (“Draft EIR”) was prepared, incorporating comments received in response to the NOP; and WHEREAS, the Draft EIR determined that mitigation measures were required to mitigate impacts to a less than significant level for the following resource areas: air quality, geology and soils, and tribal and cultural resources; and
WHEREAS, the Draft EIR further concluded that despite the incorporation of all feasible mitigation measures, the proposed Project would nonetheless result in significant and unavoidable impacts relating to greenhouse gas emissions and transportation and traffic; and
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WHEREAS, in accordance with State CEQA Guidelines section 15085, a Notice of Completion was prepared and filed with the California Governor’s Office of Land Use and Climate Innovation on July 10, 2025; and WHEREAS, as required by State CEQA Guidelines section 15087(a), the City provided Notice of Availability of the Draft EIR to the public at the same time that the City sent Notice of Completion to the California Governor’s Office of Land Use and Climate Innovation on July 10, 2025; and
WHEREAS, during the public comment period, copies of the Draft EIR and technical appendices were available for review and inspection at Lake Forest City Hall, on the City’s website, and at the Foothill Ranch and El Toro public libraries; and
WHEREAS, pursuant to State CEQA Guidelines section 15087(e), the Draft EIR was circulated for at least a 45-day public review and comment period from July 10, 2025 to September 15, 2025; and
WHEREAS, during the public review and comment period, the City consulted with and requested comments from all responsible and trustee agencies, other regulatory agencies, and others pursuant to State CEQA Guidelines section 15086; and
WHEREAS, the City received 122 written comment letters on the Draft EIR, including an acknowledgement from the State Clearinghouse that the City has complied with CEQA environmental review requirements; and WHEREAS, pursuant to Public Resources Code section 21092.5, the City provided copies of its responses to commenting public agencies at least ten (10) days prior to the City’s consideration of the Final EIR on June 4, 2026; and WHEREAS, on June 4, 2026, the Planning Commission conducted the public hearing to consider the Draft EIR, adopt a Mitigation Monitoring Program, adopt a Statement of Overriding Considerations, approve Site Development Permit 06-21-5437 for the Project and solicited comments on the document. After hearing all relevant testimony from staff, the public and the City’s consultant team, the Planning Commission voted to certify the EIR for the Project; and WHEREAS, on May 21, 2026, the City released the Final EIR (“Final EIR”), which consists of the Draft EIR) all technical appendices prepared in support of the Draft EIR) all written comment letters received on the Draft EIR) written responses to all written comment letters received on the Draft EIR) and errata to the Draft EIR and technical appendices; and
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WHEREAS, the “EIR” consists of the Final EIR and its attachments and appendices, as well as the Draft EIR and its attachments and appendices (as modified by the Final EIR); and
WHEREAS, all potentially significant adverse environmental impacts were sufficiently analyzed in the EIR; and
WHEREAS, as contained herein, the City has endeavored in good faith to set forth the basis for its decision on the Project; and WHEREAS, all of the requirements of the Public Resources Code and the State CEQA Guidelines have been satisfied by the City in connection with the preparation of the EIR which is sufficiently detailed so that all of the potentially significant environmental effects of the Project have been adequately evaluated; and
WHEREAS, the EIR prepared in connection with the Project sufficiently analyzes the Project’s potentially significant environmental impacts and identifies all significant and unavoidable impacts; and
WHEREAS, the City has made certain findings of fact, as set forth in Exhibit A to this Resolution, attached hereto and incorporated herein, based upon the oral and written evidence presented to it as a whole and the entirety of the administrative record for the Project, which are incorporated herein by this reference; and
WHEREAS, the City finds that environmental impacts that are identified in the EIR as less than significant and do not require mitigation are described in Section III of Exhibit A; and
WHEREAS, the City finds that environmental impacts that are identified in the EIR that are less than significant with incorporation of mitigation measures are described in Section IV of Exhibit A; and
WHEREAS, the City finds that even with the incorporation of all feasible mitigation measures, the environmental impacts that are identified in the EIR that are significant and unavoidable are described in Section V of Exhibit A; and WHEREAS, the cumulative impacts of the Project identified in the EIR and set forth in the applicable impact discussions throughout Sections II through V of Exhibit A; and
WHEREAS, the potential significant irreversible environmental changes that would result from the proposed Project identified in the EIR and set forth herein, are described in Section VI of Exhibit A; and
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WHEREAS, the existence of any growth-inducing impacts resulting from the proposed Project identified in the EIR and set forth herein, are described in Section VII of Exhibit A; and
WHEREAS, alternatives to the proposed Project that might further reduce the already less than significant environmental impacts are described in Section VIII of Exhibit A; and
WHEREAS, all the mitigation measures identified in the EIR and necessary to reduce the potentially significant impacts of the proposed Project to a level of less than significant are set forth in the Mitigation Monitoring and Reporting Program (MMRP) in Exhibit B to this Resolution, attached hereto and incorporated herein; and
WHEREAS, prior to taking action, the City has heard, been presented with, reviewed and considered all of the information and data in the administrative record, including but not limited to the EIR and all oral and written evidence presented to it during all meetings and hearings; and
WHEREAS, the EIR reflects the independent judgment of the City and is deemed adequate for purposes of making decisions on the merits of the Project; and
WHEREAS, no comments made in the public hearings conducted by the City and no additional information submitted to the City have produced substantial new information requiring recirculation of the EIR or additional environmental review of the Project under Public Resources Code section 21092.1 and State CEQA Guidelines section 15088.5; and
WHEREAS, on June 4, 2026, the City conducted a duly noticed public hearing on this Resolution, at which time all persons wishing to testify were heard and the Project was fully considered; and
WHEREAS, all other legal prerequisites to the adoption of this Resolution have occurred.

NOW, THEREFORE, BE IT RESOLVED BY THE PLANNING
COMMISSION OF THE CITY OF LAKE FOREST:

SECTION 1. The above recitals are true and correct and incorporated herein by reference.

SECTION 2. The Planning Commission hereby finds that it has been presented with the EIR, which it has reviewed and considered, and further finds that the EIR is an accurate and objective statement that has been completed in full Item: 2
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compliance with CEQA and the State CEQA Guidelines. The Planning Commission finds that the EIR reflects the independent judgment and analysis of the City. The Planning Commission declares that no evidence of new significant impacts or any new information of “substantial importance” as defined by State CEQA Guidelines section 15088.5, has been received by the City after circulation of the Draft EIR that would require recirculation. Therefore, the Planning Commission hereby certifies the EIR based on the entirety of the record of proceedings.

SECTION 3. The Planning Commission hereby adopts the “CEQA Findings of Fact” where were prepared in accordance with State CEQA Guidelines sections 15091 and which are attached hereto as Exhibit A and incorporated herein by this reference.

SECTION 4. Pursuant to Public Resources Code section 21081.6, the Planning Commission hereby adopts the Mitigation Monitoring and Reporting Program attached hereto as Exhibit B and incorporated herein by this reference.

Implementation of the Mitigation Measures contained in the Mitigation Monitoring and Reporting Program is hereby made a condition of approval of the Project. In the event of any inconsistencies between the Mitigation Measures set forth in the EIR or the Findings of Fact and the Mitigation Monitoring and Reporting Program, the Mitigation Monitoring and Reporting Program shall control.

SECTION 5. The Planning Commission hereby approves the Site Development Permit 06-21-5437 for the Project.

SECTION 6. Based upon the entire record before it, including the EIR, Findings of Fact, and all written and oral evidence presented, the Planning Commission hereby approves the proposed Project.

SECTION 7. The documents and materials that constitute the record of proceedings on which this Resolution has been based are located at City Hall, located at 100 Civic Center Drive, Lake Forest, California. The custodian for these records is the City Clerk. This information is provided pursuant to Public Resources Code section 21081.6.

SECTION 8. City staff shall cause a Notice of Determination to be filed and posted with the County Clerk and the State Clearinghouse within five working days of the adoption of this Resolution.

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APPROVED this 4th day of June 2026, by the following vote, to wit:

AYES: COMMISSIONERS
NOES: COMMISSIONERS
ABSENT: COMMISSIONERS
ABSTAINED: COMMISSIONERS

MICHAEL STANNARD DATE
CHAIR

LAKE FOREST PLANNING COMMISSION
ATTEST:

GAYLE ACKERMAN, AICP DATE

DIRECTOR OF COMMUNITY DEVELOPMENT
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EXHIBIT A
Findings of Fact and Statement of Overriding Considerations Item: 2
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SECTION I: INTRODUCTION
Public Resources Code (PRC) Section 21002 states that “public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of such projects[.]” Section 21002 further states that the procedures required by the California Environmental Quality Act (CEQA) “are intended to assist public agencies in systematically identifying both the significant effects of proposed projects and the feasible alternatives or feasible mitigation measures which will avoid or substantially lessen such significant effects.” Pursuant to Section 21081 of the PRC, the City may only approve or carry out a project for which an Environmental Impact Report (EIR) has been completed that identifies any significant environmental effects if the City makes one or more of the following written finding(s) for each of those significant effects accompanied by a brief explanation of the rationale for each finding:

1. Changes or alterations have been required in, or incorporated into, the project which mitigate or avoid the significant effects on the environment.

2. Those changes or alterations are within the responsibility and jurisdiction of another public agency and have been, or can and should be, adopted by that other agency.

3. Specific economic, legal, social, technological, or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or alternatives identified in the environmental impact report.

As indicated above, Section 21002 requires an agency to “avoid or substantially lessen” significant adverse environmental impacts. Thus, mitigation measures that “substantially lessen” significant environmental impacts, even if not completely avoided, satisfy section 21002’s mandate (Laurel Hills Homeowners Association v. City Council (1978) 83 Cal.App.3d 515, 521 [“CEQA does not mandate the choice of the environmentally best feasible project if through the imposition of feasible mitigation measures alone the appropriate public agency has reduced environmental damage from a project to an acceptable level”]; Las Virgenes Homeowners Federation, Inc. v. County of Los Angeles (1986) 177 Cal.App.3d 300, 309 [“[t]here is no requirement that adverse impacts of a project be avoided completely or reduced to a level of insignificance . . . if such would render the project unfeasible”].) While CEQA requires that lead agencies adopt feasible mitigation measures or alternatives to substantially lessen or avoid significant environmental impacts, an agency need not adopt infeasible mitigation measures or alternatives. (PRC § 21002.1(c) [if “economic, social, or other conditions make it infeasible to mitigate one or more significant effects on the environment of a project, the project may nonetheless be carried out or approved at the discretion of a public agency”]; see also State CEQA Guidelines § 15126.6(a) [an “EIR is not required to consider alternatives which are infeasible”].) CEQA defines “feasible” to mean “capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, and technological factors.” (PRC § 21061.1.) The State CEQA Guidelines, add “legal” considerations as another indicia of feasibility (State CEQA Guidelines § 15364.) Project objectives also inform the determination of “feasibility.” (Jones v. U.C. Regents (2010) 183 Cal. App. 4th 818, 828-829.) “‘[F]easibility’ under CEQA encompasses ‘desirability’ to the extent that desirability is based on a reasonable balancing of the relevant economic, environmental, social, and technological factors.” (City of Del Mar v. City of San Diego (1982) 133 Cal.App.3d 401, 417; see also Sequoyah Hills Homeowners Assn. v. City of Oakland Item: 2
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(1993) 23 Cal.App.4th 704, 715.) “Broader considerations of policy thus come into play when the decision making body is considering actual feasibility[.]” (Cal. Native Plant Soc’y v. City of Santa Cruz (2009) 177 Cal.App.4th 957, 1000 (“Native Plant”); see also PRC § 21081(a)(3) [“economic, legal, social, technological, or other considerations” may justify rejecting mitigation and alternatives as infeasible] (emphasis added).)
Environmental impacts that are less than significant do not require the imposition of mitigation measures. (Leonoff v. Monterey County Board of Supervisors (1990) 222 Cal.App.3d 1337, 1347.)
The California Supreme Court has stated, “[t]he wisdom of approving . . . any development project, a delicate task which requires a balancing of interests, is necessarily left to the sound discretion of the local officials and their constituents who are responsible for such decisions.

The law as we interpret and apply it simply requires that those decisions be informed, and therefore balanced.” (Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 576.) In addition, perfection in a project or a project’s environmental alternatives is not required; rather, the requirement is that sufficient information be produced “to permit a reasonable choice of alternatives so far as environmental aspects are concerned.” Outside agencies (including courts) are not to “impose unreasonable extremes or to interject [themselves] within the area of discretion as to the choice of the action to be taken.” (Residents Ad Hoc Stadium Com. v.

Board of Trustees (1979) 89 Cal.App.3d 274, 287.)
SECTION II: FINDINGS REGARDING ENVIRONMENTAL EFFECTS THAT WERE

DETERMINED NOT TO BE POTENTIALLY AFFECTED BY THE PROPOSED

PROJECT
The Planning Commission hereby finds that based upon the environmental analysis presented in the Final EIR (FEIR), and the comments received by the public on the Draft EIR (DEIR), no substantial evidence has been submitted to or identified by the City that indicates that the proposed project would have an impact on the following environmental areas:

Aesthetics:
• Threshold 4.1.1: The proposed project would not have a substantial adverse effect on a scenic vista and would not substantially damage scenic resources, including scenic vistas from public parks and views from designated scenic highways or arterial roadways. (DEIR at 4.1-16 to 4.1-18) • Threshold 4.1.2: The proposed project would not substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a State Scenic Highway. (DEIR at 4.1-18) • Threshold 4.1.3: The proposed project would not conflict with applicable zoning and other regulations governing scenic quality and would not substantially degrade the existing visual character or quality of the site and its surroundings where:
• The project exceeds the allowed height or bulk regulations or exceeds the prevailing height and bulk of existing structures;
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where that development had been constructed adhering to a common architectural style or theme;
• The project is located on a visually prominent site and, due to its height, bulk, architecture or signage, would be in vivid contrast to the surrounding development or environment degrading the visual unity of the area;
• The project would include unscreened outdoor uses or materials; or • The project would result in the introduction of an architectural feature or building mass that conflicts with the character of the surrounding development. (DEIR at 4.1-18 to 4.1-25)
Agricultural and Forestry Resources:
• Threshold 4.2.1: The proposed project would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use. (DEIR at 4.2-8)
• Threshold 4.2.2: The proposed project would not conflict with existing zoning for agricultural use, or a Williamson Act contract. (DEIR at 4.2-8) • Threshold 4.2.3: The proposed project would not conflict with existing zoning for, or cause rezoning of, forest land, timberland, or timberland zoned Timberland Production. (DEIR at 4.2-9)
• Threshold 4.2.4: The proposed project would not result in the loss of forest land or conversion of forest land to non-forest use. (DEIR at 4.2-9) • Threshold 4.2.5: The proposed project would not involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use. (DEIR at 4.2-9)
• Cumulative Impact: The proposed project would have no impact on agricultural and forestry resources. Because the proposed project would have no impact on agricultural and forestry resources, it would not contribute to a cumulatively considerable impact on agricultural and forestry resources.

Therefore, there would be no cumulatively significant impact on agricultural and forestry resources. (DEIR at 4.2-10)
Biological Resources:
• Threshold 4.4.2: The proposed project would not have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the California Department of Fish and Wildlife or United States Fish and Wildlife Service. (DEIR at 4.4-11)
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• Threshold 4.4.3: The proposed project would not have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means. (DEIR at 4.4-11)
• Threshold 4.4.5: The proposed project would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. (DEIR at 4.4-12)
• Threshold 4.4.6: The proposed project would not conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan with any local policies or ordinances protecting biological resources. (DEIR at 4.4- 12)
Geology and Soils:
• Threshold 4.7.1(i): The proposed project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault. (DEIR at 4.7-12)
• Threshold 4.7.1(iii): The proposed project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving seismic-related ground failure, including liquefaction. (DEIR at 4.7-13)
• Threshold 4.7.1(iv): The proposed project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving landslides. (DEIR at 4.7-13)
• Threshold 4.7.5: The proposed project would not have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater. (DEIR at 4.7-16)
Hazards and Hazardous Materials:
• Threshold 4.9.4: The proposed project would not be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, it would not create a significant hazard to the public or the environment. (DEIR at 4.9-14) • Threshold 4.9.5: The proposed project is not located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport and would not result in a safety hazard or excessive noise for people residing or working in the project area. (DEIR at

4.9-14)
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• Threshold 4.9.7: The proposed project would not expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires. (DEIR at 4.9-16)
Hydrology and Water Quality:
• Threshold 4.10.3(iv): The proposed project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would impede or redirect flood flows; would not place housing within a 100-year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map; and would not place within a 100-year flood hazard area structures which would impede or redirect flood flows.. (DEIR at 4.10-34) Land Use and Planning:
• Threshold 4.11.1: The proposed project would not physically divide an established community. (DEIR at 4.11-7)
• Threshold 4.11.2: The proposed project would not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect; would not substantially conflict with existing on-site or adjacent land use due to project-related significant unavoidable indirect effects (e.g., noise, aesthetics, etc.) that precludes use of the land as it was intended by the General Plan; and would not conflict with the Central and Coastal Natural Communities Conservation Program/Habitat Conservation Plan (NCCP/HCP) of which the City of Lake Forest is a participant. (DEIR at 4.11-8 to 4.11-27) • Cumulative Impact: The proposed project would not have a land use or planning impact; therefore, it would not contribute to a cumulatively considerable impact relative to these topics. No cumulatively significant impact related to land use and planning would result from development of the proposed project. (DEIR 4.11-27)
Mineral Resources:
• Threshold 4.12.1: The proposed project would not result in the loss of availability of a known mineral resource that would be a value to the region and the residents of the state. (DEIR at 4.12-3 to 4.12-4) • Threshold 4.12.2: The proposed project would not result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan. (DEIR at 4.12-4) • Cumulative Impact: The proposed project would have no impact on mineral resources; therefore, it would not contribute to a cumulatively considerable impact relative to this topic. No cumulatively significant impact related to mineral resources would result from development of the proposed project. (DEIR 4.12-4)
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Noise:
• Threshold 4.13.3: The proposed project would not be located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, and would not expose people residing or working in the project area to excessive noise levels. (DEIR at 4.13-21)
Population and Housing:
• Threshold 4.14.2: The proposed project would not displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere. (DEIR at 4.14-8)
Recreation:
• Threshold 4.16.2: The proposed project would not include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment. (DEIR at 4.16-5) SECTION III: FINDINGS REGARDING ENVIRONMENTAL EFFECTS WHICH

WERE DETERMINED TO BE LESS THAN SIGNIFICANT
The FEIR identified certain less than significant effects that could result from implementation of the proposed project. The Planning Commission hereby finds that the following potential environmental impacts of the project are less than significant based on the implementation of project design features and existing regulations and/or regulatory compliance measures.

Aesthetics:

1. Threshold 4.1.4: The proposed project would not create a new source of substantial light or glare which would adversely affect day or nighttime views in the area, and would not create a new source of substantial night lighting that would result in “sky glow” (i.e. illumination of the night sky in urban areas) or “spill light” (i.e. light that falls outside of the area intended to be lighted) onto adjacent sensitive land uses.

Impact: The proposed project would not create a new source of substantial light or glare which would adversely affect day or nighttime views in the area and would not create a new source of substantial night lighting that would result in “sky glow” or “spill light” onto adjacent sensitive land uses. Impacts would be less than significant. (DEIR at 4.1-25 to

4.1-26)
a. Finding: No changes or alterations have been required or incorporated into the project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.1-25 to 4.1-26) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.1-25 to 4.1-26)
d. Supporting Explanation: During construction, illumination during evening and nighttime hours would be used for safety and security purposes only, would be Item: 2
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downlit to minimize light spillage onto adjacent properties, and would occur only for the duration required for the temporary construction process; therefore, it would not substantially impact sensitive uses, substantially alter the character of surrounding uses, or interfere with the performance of off-site activities. Because (1) relatively few construction vehicles and pieces of construction equipment would be used on the project site, and (2) the construction site would be fenced and shielded from pedestrian and vehicular views. Additionally, construction vehicles would not be operating at night. Therefore, daytime and nighttime impacts associated with new, temporary sources of light and glare associated with construction activity would be less than significant. (DEIR at 4.1-25)
Similar to the existing condition, the proposed project would provide parking lot lights consistent with the City’s requirements for parking lot safety and building lighting. All project lighting would be hooded or shielded to focus the light downward and prevent light spillage onto adjacent properties. All new lighting would comply with applicable regulations of the 2019 State Building Energy Efficiency Standards (Title 24) and with Section 9.72.085 of the City of Lake Forest Municipal Code (requiring site lighting be confined to the project site). The proposed building materials (e.g., concrete, glass, metal) and uses of these materials are typical of those found in the surrounding areas and are not anticipated to create unusual or isolated glare effects that would affect daytime visibility or views in the project vicinity. The rooftop of the proposed building would be flat; therefore, the proposed photovoltaic panels are not anticipated to generate significant amounts of glare onto adjacent properties. As sources of light and glare associated with the proposed project would be consistent with the existing surrounding uses during both the daytime and nighttime hours and because the project would comply with applicable lighting standards set forth in City’s Municipal Code and General Plan and Title 24 requirements, the proposed project would not create a new source of substantial light or glare that would adversely affect day or nighttime views in the area, or create a new source of substantial night lighting that would result in “sky glow” (i.e. illumination of the night sky in urban areas) or “spill light” (i.e. light that falls outside of the area intended to be lighted) onto adjacent sensitive land uses. Impacts would be less than significant. (DEIR at 4.1-26)

2. Cumulative Impact: Project development, together with cumulative projects, would not result in significant impacts related to aesthetics in the project area. (DEIR at 4.1-26 to

4.1-27)
a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.1-27)
c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR 4.1-27)
d. Supporting Explanation: The proposed project would have no impact on scenic vistas, no impact on scenic resources including, but not limited to, trees, rock outcroppings, and historic buildings within a State Scenic Highway, and no impact related to conflicts with applicable zoning and other regulations governing scenic Item: 2
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quality; therefore, no cumulative impact would occur. If the project would result in no impact with respect to a particular threshold, by definition, it would not contribute to a cumulative impact.

Similar to the proposed project, cumulative development would also be required to comply with existing regulatory requirements related to light and glare including Title 24 and the City’s Municipal Code to reduce potential impacts associated with light and glare and if significant light and glare impacts are anticipated, appropriate mitigation measures would be implemented as part of the CEQA environmental review process. Therefore, the proposed project would not result in cumulatively considerable impacts related to light and glare. Cumulative impacts would be less than significant and no mitigation is required. (DEIR at 4.1-27) Air Quality:

3. Threshold 4.3.1: The proposed project would not conflict with or obstruct implementation of the applicable air quality plan.

Impact: The proposed project would not conflict with or obstruct implementation of the applicable air quality plan. Impacts would be less than significant. (DEIR at 4.3-22 to

4.3-24)
a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.3-22 to 4.3-24) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.3-22 to 4.3-24)
d. Supporting Explanation: The proposed project would not exceed the significance criteria for daily emissions of criteria pollutants (DEIR Tables 4.3.J and 4.3.K, at

4.3-28 and 4.3-29); therefore, construction and operation of the proposed project would not result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in nonattainment under an applicable federal or State ambient air quality standard. Therefore, the proposed project would not result in an increase in the frequency or severity of an air quality standards violation or cause a new air quality standards violation and is consistent with the 2022 Air Quality Management Plan (AQMP).

The projections in the 2022 AQMP for achieving air quality goals are based, in part, on assumptions in regional population, housing, and growth forecasts, as well as assumptions and projections of local planning agencies. The proposed project is consistent with City’s existing General Plan and zoning designations. The proposed project would not result in direct population growth because the proposed project is not a residential use and does not include a residential component; therefore, it would not add new residents at the project site. Project development would generate approximately 187 new jobs in Lake Forest, representing approximately 17 percent and less than one percent of the job growth estimated in Lake Forest and Orange County, respectively. Given that approximately 1,800 and 64,100 people are Item: 2
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currently unemployed in Lake Forest and Orange County, respectively, it is reasonable to conclude that the majority of these positions would be filled by existing City or County residents. The growth projections of the proposed project would be within the parameters of expected overall growth in the City. Therefore, the proposed project would not result in growth in the area or in Lake Forest beyond that which was planned for by the Southern California Association of Governments (SCAG) or used in the development of the 2022 AQMP; therefore, impacts associated with conflicts with the applicable air quality plan would be less than significant. (DEIR at

4.3-22- to 4.3-24)

4. Threshold 4.3.4: The proposed project would not result in other emissions such as those leading to odors adversely affecting a substantial number of people.

Impact: The proposed project would not result in other emissions (including odors) affecting a substantial number of people. Impacts would be less than significant. (DEIR at 4.3-38-to 4.3-39)
a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.3-38-to 4.3-39) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.3-38-to 4.3-39)
d. Supporting Explanation: Objectionable odors may be generated during the operation of diesel-powered construction equipment and/or asphalt paving during project construction. Those odors would be temporary and would not result in long-term odor impacts. The proposed uses associated with the project are not anticipated to generate objectionable odors during operation. Therefore, the proposed project would not result in significant permanent impacts related to odors on nearby sensitive receptors (e.g., residential uses). (DEIR at 4.3-38 to 4.3-39) Biological Resources:

5. Threshold 4.4.1: The proposed project would not result in a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special- status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or the United States Fish and Wildlife Service.

Impact: The proposed project would not result in a substantial adverse effect on species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or the United States Fish and Wildlife Service. Impacts would be less than significant with compliance with applicable regulatory requirements. (DEIR at 4.4-10 to 4.4-11) a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) Item: 2
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b. Applicable Regulatory Compliance Measures: The following regulatory compliance measure is applicable to this topical area. (DEIR at 4.4-10 to 4.4-11, and 4.4-14) RCM BIO-1 Nesting Bird Clearance Survey. If construction/ground disturbing activities, including demolition, occurs between February 1 and August 31, a Qualified Biologist shall conduct a pre-construction clearance survey for nesting birds within 3 days of the start of any construction, vegetation clearing, or grading activities (including disking and demolition) to ensure that no nesting birds are disturbed during construction. The Qualified Biologist shall be retained by the Construction Contractor. The Qualified Biologist conducting the clearance survey shall document a negative survey with a brief letter report indicating that no impacts to active avian nests would occur. If an active avian nest is discovered during the pre-construction clearance survey, construction activities shall stay outside of a nodisturbance buffer. In general, the no-disturbance buffer shall be a minimum of 50 feet for passerines and 250 feet for raptors. However, a species’ sensitivity to disturbance can vary among species, the level of noise or construction disturbance, and the line of sight between the nest and the disturbance. Limits of construction to avoid an active nest shall be established in the field with flagging, fencing, or other appropriate barriers; and construction personnel shall be instructed on the sensitivity of nest areas. A biological monitor, with experience in monitoring active nests, shall be present to delineate the boundaries of the buffer area and to monitor daily all active nests to observe the efficacy of the no-disturbance buffers and to document any new nesting occurrences to ensure that nesting behavior is not adversely affected by the construction activity. Adversely affected nesting behavior, as determined by the biological monitor, includes, but is not limited to, disrupting reproductive behavior, nest abandonment, and/or prolonged absences of parents while incubating eggs. Once the young have fledged and left the nest, or the nest otherwise becomes inactive under natural conditions, construction, vegetation clearing, or grading activities (including disking and demolition) within the buffer area can occur. Field memorandums shall be prepared by the biological monitor within 24 hours of each day of monitoring and shall be submitted to the City of Lake Forest to document compliance with the applicable resource protection measures.
c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.4-10 to 4.4-11)
d. Supporting Explanation: The entire project site is developed with an existing office/ industrial building and supporting infrastructure. No evidence of listed, candidate, non-listed sensitive, or special-status plant or wildlife species on the site was identified during biological resource surveys. Due to the on-site absence of suitable habitat, no such species are expected to occur on site. Additionally, there are no native plant communities or natural communities of special concern on site.

Potential noise, vibration, light, dust, or human disturbance associated with project activities would only temporarily deter wildlife from using areas in the immediate vicinity. These indirect effects could temporarily alter migration behaviors, territories, Item: 2
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or foraging habitats in adjacent areas. However, because these are temporary effects, it is likely that any wildlife already living and/or moving in close proximity to the project site would temporarily alter their normal functions during active construction activities and then re-establish those functions once temporary construction activities have ceased.

Despite the disturbed condition of the project site and the lack of vegetation communities, the project site does have existing landscaping that could provide suitable habitat for nesting birds. Nesting birds are protected pursuant to the Migratory Bird Treaty Act (MBTA) and the California Fish and Game Code. To reduce potential impacts to nesting birds from implementation of the proposed project, if construction/ground disturbing activities, including demolition, occurs between February 1 and August 31, a nesting bird clearance survey would be required prior to removal of any landscaped vegetation, as detailed in Regulatory Compliance Measure (RCM) BIO-1. RCM BIO-1 includes provisions for appropriate buffering and monitoring of active nests during construction operations. With implementation of RCM BIO-1, the proposed project would not have a substantial adverse effect on any species identified as a candidate, sensitive, or special-status species, and impacts would be less than significant. No mitigation is required. (DEIR at 4.4-10 to 4.4-11)

6. Threshold 4.4.4: The proposed project would not interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites.

Impact: The proposed project would not interfere substantially with the movement of any native resident or migratory fish or wildlife species, with established wildlife corridors, or impede the use of native wildlife nursery sites. Impacts would be less than significant with compliance with applicable regulatory requirements. (DEIR at 4.4-11 to 4.4-12) a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR.(State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: The following regulatory compliance measure is applicable to this topical area. (DEIR at 4.4-11 to 4.4-12, and 4.4-14) RCM BIO-1 Nesting Bird Clearance Survey. If construction/ground disturbing activities, including demolition, occurs between February 1 and August 31, a Qualified Biologist shall conduct a pre-construction clearance survey for nesting birds within 3 days of the start of any construction, vegetation clearing, or grading activities (including disking and demolition) to ensure that no nesting birds are disturbed during construction. The Qualified Biologist shall be retained by the Construction Contractor. The Qualified Biologist conducting the clearance survey shall document a negative survey with a brief letter report indicating that no impacts to active avian nests would occur. If an active avian nest is discovered during the pre-construction clearance survey, construction activities shall stay outside of a nodisturbance buffer. In general, the no-disturbance buffer shall be a minimum of 50 feet for passerines and 250 feet for raptors. However, Item: 2
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a species’ sensitivity to disturbance can vary among species, the level of noise or construction disturbance, and the line of sight between the nest and the disturbance. Limits of construction to avoid an active nest shall be established in the field with flagging, fencing, or other appropriate barriers; and construction personnel shall be instructed on the sensitivity of nest areas. A biological monitor, with experience in monitoring active nests, shall be present to delineate the boundaries of the buffer area and to monitor daily all active nests to observe the efficacy of the no-disturbance buffers and to document any new nesting occurrences to ensure that nesting behavior is not adversely affected by the construction activity. Adversely affected nesting behavior, as determined by the biological monitor, includes, but is not limited to, disrupting reproductive behavior, nest abandonment, and/or prolonged absences of parents while incubating eggs. Once the young have fledged and left the nest, or the nest otherwise becomes inactive under natural conditions, construction, vegetation clearing, or grading activities (including disking and demolition) within the buffer area can occur. Field memorandums shall be prepared by the biological monitor within 24 hours of each day of monitoring and shall be submitted to the City of Lake Forest to document compliance with the applicable resource protection measures.
c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.4-11 to 4.4-12)
d. Supporting Explanation: The project site and adjacent areas are entirely developed.

Furthermore, there are no riparian corridors, creeks, or useful patches of habitat within or connecting the project site to any identified wildlife corridors or linkages.

Therefore, the proposed project would not interfere with the movement of any wildlife species or with established wildlife corridors. While no active nests or birds displaying nesting behavior were observed during the breeding season field investigation, landscaped areas on the project site have the potential to provide minimal foraging and nesting habitat for year-round and seasonal avian residents, as well as migrating songbirds that could occur in the area that are adapted to urban environments. RCM BIO-1 includes measures to prevent potential impacts to nesting birds during construction activities. With implementation of RCM BIO-1, the proposed project would not interfere with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors or impede the use of native wildlife nursery sites, and impacts would be less than significant. No mitigation is required. (DEIR at 4.4-11 to 4.4-12)

7. Cumulative Impact: Project development, together with cumulative projects, would not result in significant impacts related to biological resources in the project area. (DEIR at

4.4-13)
a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.4-13)
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c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.4-13)
d. Supporting Explanation: The proposed project would have no impact on sensitive wildlife species (aside from nesting birds), plant communities, habitat fragmentation, jurisdictional waters, wildlife movements, wildlife migratory wildlife corridors, wildlife nursery sites, habitat conservation plans, or local ordinances or regulations protecting biological resources. Because the proposed project would have no impact on the biological resources listed above, it would not contribute to a cumulatively considerable impact on biological resources. Therefore, there would be no cumulatively significant impact related to biological resources.

All cumulative projects would be required to comply with the MBTA and the California Fish and Game Code to address potential impacts to nesting birds, which would ensure project impacts on nesting birds are evaluated and appropriately mitigated by each cumulative project. When considered together, impacts to biological resources (particularly impacts to nesting birds) would not be cumulatively considerable and no cumulatively significant impact on biological resources, would result from development of the proposed project. (DEIR at 4.4-13) No mitigation is required.

Cultural Resources:

8. Threshold 4.5.1 The proposed project would not cause a substantial adverse change in the significance of a historic resource as defined in Section 15064.5.

Impact: The proposed project would not cause a substantial adverse change in the significance of a known historic resource. Compliance with applicable regulatory requirements would reduce potential construction-related impacts to unknown historical resources to less than significant levels. (DEIR at 4.5-7 to 4.5-8) a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: The following regulatory compliance measure is applicable to this topical area. (DEIR at 4.5-7 to 4.5-8, and 4.5-10 to 4.5- 11)
RCM CUL-1 Unknown Archaeological Resources. In the event that archaeological resources are discovered during excavation, grading, or construction activities, work shall cease within 100 feet of the find until a qualified archaeologist from the Orange County List of Qualified Archaeologists has evaluated the find in accordance with federal, State, and local guidelines to determine whether the find constitutes a “unique archaeological resource,” as defined in Section 21083.2(g) of the California Public Resources Code (PRC). Personnel of the proposed project shall not collect or move any archaeological materials and associated materials. Construction activity may continue unimpeded beyond 100 feet from the find on other portions of the project site. The found deposits shall be treated in accordance with federal, State, and local guidelines, including those set forth in PRC Section 21083.2. Prior to issuance of a grading permit, the Item: 2
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Director of Community Development, or designee, shall ensure that this regulatory compliance measure is documented on the grading plans.
c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.5-7 to 4.5-8)
d. Supporting Explanation: The project site is occupied by a modern building and parking lot. The existing building was developed in 1999. Since the building is less than 50 years old, it is not considered to be of historical significance. There are no known archaeological resources on the project site that would qualify as “historical resources” as defined by CEQA. In the unlikely event that a previously undocumented historical or unique archaeological resource is encountered during construction, the provisions specified in California Code of Regulations (CCR), Title 14, Chapter 3, Section 15064.5(f) would be followed as specified in RCM CUL-1.

Therefore, with implementation of RCM CUL-1, the proposed project would not result in impacts associated with a substantial adverse change in the significance of a historical resource as defined in Section 15064.5. No mitigation is required. (DEIR at

4.5-7 to 4.5-8)

9. Threshold 4.5.2: The proposed project would not cause a substantial adverse change in the significance of an archaeological resource as defined in §15064.5.

Impact: The proposed project would not cause a substantial adverse change in the significance of a known archaeological resource. Compliance with applicable regulatory requirements would reduce potential construction-related impacts to unknown archaeological resources to less than significant levels. (DEIR at 4.5-8 to 4.5-9) a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: The following regulatory compliance measure is applicable to this topical area. (DEIR at 4.5-8 to 4.5-11 ) RCM CUL-1 Unknown Archaeological Resources. In the event that archaeological resources are discovered during excavation, grading, or construction activities, work shall cease within 100 feet of the find until a qualified archaeologist from the Orange County List of Qualified Archaeologists has evaluated the find in accordance with federal, State, and local guidelines to determine whether the find constitutes a “unique archaeological resource,” as defined in Section 21083.2(g) of the California Public Resources Code (PRC). Personnel of the proposed project shall not collect or move any archaeological materials and associated materials. Construction activity may continue unimpeded beyond 100 feet from the find on other portions of the project site. The found deposits shall be treated in accordance with federal, State, and local guidelines, including those set forth in PRC Section 21083.2. Prior to issuance of a grading permit, the Director of Community Development, or designee, shall ensure that this regulatory compliance measure is documented on the grading plans.

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c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.5-8 to 4.5-9)
d. Supporting Explanation: The project site is occupied by a modern building and parking lot and has been subject to over excavation and compaction that has disturbed sediments beyond depths at which buried cultural resources are likely. No evidence of any cultural resources (including prehistoric or historic archaeological sites or historic-period buildings) was identified within the project site during the archaeological field survey. Due to previous site disturbance, the site-specific archaeological assessment concluded that the discovery of buried cultural resources during project construction was unlikely. The assessment further determined no additional cultural resources work or monitoring was necessary during project-related ground disturbance and construction activities.

In the unlikely event that archaeological resources are discovered at any time during construction, those activities would be halted in the vicinity of the find until the find can be assessed for significance by a qualified archaeologist as required by the Public Resource Code and City of Lake Forest General Plan 2040 Action RR-3b in accordance with RCM CUL-1. RCM CUL-1 establishes the procedure for the avoidance, protection, assessment, and treatment of any archaeological resource uncovered during the course of project-related ground disturbance and construction activities. With implementation of RCM CUL-1 potential impacts to previously undiscovered archaeological resources would be less than significant. No mitigation is required. (DEIR at 4.5-8 to 4.5-9)

10. Threshold 4.5.3: The proposed project would not disturb human remains, including those interred outside of dedicated cemeteries.

Impact: The proposed project would not disturb known human remains, including those interred outside of dedicated cemeteries. Compliance with applicable regulatory requirements would reduce potential construction-related impacts to human remains to less than significant levels. (DEIR at 4.5-9)
a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: The following regulatory compliance measure is applicable to this topical area. (DEIR at 4.5-9, and 4.5-11) RCM CUL-2 Human Remains. If human remains are encountered, State Health and Safety Code Section 7050.5 states that no further disturbance shall occur until the County Coroner has made a determination of origin and disposition pursuant to State PRC Section 5097.98. The County Coroner must be notified of the find immediately. If the remains are determined to be Native American, the County Coroner would notify the Native American Heritage Commission (NAHC), which would determine and notify a Most Likely Descendant (MLD).

With the permission of the landowner or his/her authorized representative, the MLD may inspect the site of the discovery. The MLD shall complete the inspection and make recommendations or preferences for treatment within 48 hours of being granted access to Item: 2
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the site. The MLD recommendations may include scientific removal and nondestructive analysis of human remains and items associated with Native American burials, preservation of Native American human remains and associated grave goods in place, relinquishment of Native American human remains and associated items to the descendants for treatment, or any other culturally appropriate treatment. Prior to issuance of a grading permit, the Director of Community Development, or designee, shall ensure that this regulatory compliance measure is documented on the grading plans. c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.4-9)
d. Supporting Explanation: The project site has been previously disturbed including over excavation and compaction during development of the existing building and site infrastructure. No human remains are documented/known to be on the project site.

Due to the developed nature and past disturbance of the site, the likelihood of discovering unknown human remains during construction of the proposed project is extremely low. In the unlikely event that human remains are discovered during construction activities, the Construction Contractor would be required to implement RCM CUL-2, which requires compliance with the State’s Health and Safety Code for the treatment of human remains. With implementation of RCM CUL-2 potential impacts to previously undiscovered human remains would be less than significant.

No mitigation is required. (DEIR at 4.5-9)

11. Cumulative Impact: Project development, together with cumulative projects, would not result in significant impacts related to cultural resources in the project area. (DEIR at 4.5- 9 to 4.5-10)
a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.5-9 to 4.5-10) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.5-9 to 4.5-10)
d. Supporting Explanation: The project would have no impact on historic resources.

Implementation of RCM CUL-1 and RCM CUL-2, which would ensure potential impacts to previously undiscovered archaeological resources and/or human remain less than significant during development of the proposed project.

All discretionary cumulative development would be required to comply with CEQA and implement applicable regulatory compliance and mitigation measures to ensure the appropriate identification and mitigation of cultural resource impacts specific to each development. Since all such projects would be required to implement appropriate regulatory compliance measures and mitigation measures, impacts to cultural resources resulting from development of the proposed project would not be cumulatively considerable. No cumulatively significant impact relative to cultural resources would occur and no mitigation is required. (DEIR at 4.5-9 to 4.5-10) Item: 2
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Energy:

12. Threshold 4.6.1: The proposed project would not result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation.

Impact: The proposed project would not result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation. Impacts would be less than significant. (DEIR, at 4.6-7 to 4.6-10)
a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.6-7 to 4.6-10) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.6-7 to 4.6-10)
d. Supporting Explanation: The proposed project would increase the annual construction generated fuel use in Orange County by approximately 0.1 percent for diesel fuel usage and by less than 0.01 percent for gasoline fuel usage. Impacts related to energy use during construction would be temporary and relatively small in comparison to the County’s overall use of the State’s available energy sources.

Project construction would not result in the wasteful, inefficient, or unnecessary consumption of energy resources. Impacts would be less than significant, and no mitigation is required. (DEIR at 4.6-7 to 4.6-8)
During operation, the proposed project would increase the annual electricity consumption in Orange County by less than 0.01 percent. Additionally, vehicle and truck trips associated with the proposed project would increase the annual fuel use in Orange County by less than 0.01 percent for gasoline fuel usage and by approximately 0.1 percent for diesel fuel usage. The proposed project would be required to adhere to all federal, State, and local requirements for energy efficiency, including the Title 24 standards. Title 24 building energy efficiency standards establish minimum efficiency standards related to various building features, including appliances, water and space heating and cooling equipment, building insulation and roofing, and lighting, which would reduce energy usage. In addition, the proposed project will be seeking Leadership in Energy and Environmental Design (LEED) certification through the Applicant’s LEED Volume program. The proposed project would not result in the wasteful, inefficient, or unnecessary consumption of fuel or energy and would incorporate renewable energy or energy efficiency measures into building design, equipment use, and transportation. Impacts related to consumption of energy resources during operation would be less than significant. (DEIR at 4.6-9 to 436-10)

13. Threshold 4.6.2: The proposed project would not conflict with or obstruct a State or local plan for renewable energy or energy efficiency.

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Impact: The proposed project would not conflict with or obstruct a State or local plan for renewable energy or energy efficiency. Impacts would be less than significant. (DEIR at

4.6-10 to 4.6-11)
a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.6-10 to 4.6-11) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.6-10 to 4.6-11)
d. Supporting Explanation: Energy usage associated with operation of the proposed project would be relatively small in comparison to the overall use in Orange County, and the State’s available energy resources and energy impacts at the regional level would be negligible. Because California’s energy conservation planning actions are conducted at a regional level, and because the proposed project’s total impact on regional energy supplies would be minor, the proposed project would not conflict with or obstruct California’s energy conservation plans. Potential impacts related to conflict with or obstruction of a State or local plan for renewable energy or energy efficiency would be less than significant, and no mitigation is required. (DEIR at 4.6- 10 to 4.6-11)

14. Cumulative Impact: Project development, together with cumulative projects, would not result in significant impacts related to energy in the project area. (DEIR at 4.6-11 to 4.6- 12)
a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.6-11 to 4.6-12) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.6-11 to 4.6-12)
d. Supporting Explanation: The proposed project’s share of cumulative electricity consumption is negligible, while its share of cumulative natural gas consumption is zero. The proposed project, in combination with cumulative development, is well within SCE’s system-wide net annual increase in electricity supplies over the 2018 to 2030 period, and there are sufficient planned electricity supplies in the region for estimated net increases in energy demands. Transportation energy use would not represent a major amount of energy use compared to the amount of existing development and to the total number of vehicle trips throughout Orange County and the region. The proposed project and cumulative development are required to comply with various federal and State government legislation to improve energy efficiency in buildings, equipment, and appliances and to reduce vehicle miles traveled; therefore, the proposed project in combination with cumulative development would not result in an inefficient, wasteful, and unnecessary consumption of energy Item: 2
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and would not be cumulatively considerable. No mitigation is required. (DEIR, at 4.6- 11 to 4.6-12)
Geology and Soils:

15. Threshold 4.7.2: The proposed project would not result in substantial soil erosion or the loss of topsoil.

Impact: Construction and operation of the proposed project would not result in substantial soil erosion or the loss of topsoil with compliance with applicable regulatory requirements. Impacts would be less than significant. (DEIR at 4.7-13 to 4.7-14) a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: The following Regulatory Compliance Measures are applicable to this topical area. (DEIR at 4.7-13 to 4.7-14 and 4.10-39 to 4.10-41)
RCM WQ-1 Construction General Permit. Prior to the issuance of a grading permit, the Construction Contractor shall obtain coverage under the State Water Resources Control Board (SWRCB) National Pollutant Discharge Elimination System (NPDES) General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities (Order No. 2022-0057-DWQ, NPDES No.

CAS000002) (Construction General Permit). This shall include submission of Permit Registration Documents (PRDs), including a Notice of Intent for coverage under the permit to the SWRCB via the Stormwater Multiple Application and Report Tracking System (SMARTs). The Construction Contractor shall provide the Waste Discharge Identification Number (WDID) to the Lake Forest Public Works Director, or designee, to demonstrate proof of coverage under the Construction General Permit. Project construction shall not be initiated until a WDID is received from the SWRCB and is provided to the City, or designee.

BMP implementation shall be consistent with the BMP requirements in the most recent version of the California Stormwater Quality Association’s Stormwater Best Management Handbook: Construction.

The SWPPP shall include a construction site monitoring program that identifies requirements for dry weather visual observations of pollutants at all discharge locations, and as appropriate (depending on the Risk Level), sampling of the site effluent and receiving waters. A Item: 2
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Qualified SWPPP Practitioner shall be responsible for implementing the BMPs at the site and performing all required monitoring and inspection/maintenance/repair activities.

Upon completion of construction and stabilization of the site, a Notice of Termination shall be submitted via SMARTs.

8.30 of the City of Lake Forest Municipal Code from the Lake Forest Public Works Director, or designee. The Erosion Control Plan shall be submitted to the City of Lake Forest Building Official for approval by September 15 each year for projects under a grading permit. All grading shall be undertaken in accordance with the BMPs for pollution prevention adopted by the City, the City’s NPDES Permit regulating discharges into and from its Municipal Separate Storm Sewer System (MS4), the Drainage Area Management Plan (DAMP), and any other conditions, requirements and water quality management plans adopted by the City. Additionally, the project Applicant shall adhere to the erosion and sediment control and water quality system maintenance requirements listed in Section 8.30.154 of the Lake Forest Municipal Code.

RCM WQ-3 Final Water Quality Management Plan. Prior to issuance of a grading permit, the project Applicant shall submit and obtain approval of a Final Water Quality Management Plan (WQMP) to the Lake Forest Public Works Director, or designee. The project shall implement project design features identified in the Final WQMP. The Final WQMP shall demonstrate that any proposed on-site
development plan includes BMPs for source control, pollution prevention, site design, low impact development (LID)
implementation, and structural treatment control. BMPs shall be designed and implemented to address 303(d) listed pollutants and retain the project site’s minimum design capture volume and hydromodification volume to ensure that post-development storm water runoff volume or time of concentration does not exceed predevelopment storm water runoff by more than 10 percent of the 2-year peak flow in accordance with the Santa Ana Regional Water Quality Control Board Order Number R8-2009-0030, NPDES Permit No.

CAS618030, as amended by Order No. R8-2010-0062, also known as the North Orange County MS4 permit. The proposed LID BMPs specified in the Final WQMP shall be incorporated into the grading and development plans submitted to the City of Lake Forest for review and approval. Periodic maintenance of any required BMPs and landscaped areas during project occupancy and operation shall be in accordance with the schedule outlined in the Final WQMP.

RCM WQ-4 Final Hydrology and Hydraulic Analyses. Prior to issuance of grading permits, the project Applicant shall submit and obtain approval of the Final Hydrology and Hydraulic Analyses to the Lake Forest Director of Public Works, or designee, and the Orange County Item: 2
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Flood Control District (OCFCD). The Final Hydrology and Hydraulic Analyses shall be prepared consistent with the requirements of the Orange County Hydrology Manual (Orange County Environment Agency 1986) and Orange County Hydrology Manual Addendum No. 1 (Orange County Environment Agency 1996), or subsequent guidance manuals. The Final Hydrology and Hydraulic Analyses shall confirm that the on-site storm drains, on-site detention basins, and any other drainage structures are appropriately sized to accommodate stormwater runoff from the design storm so that the peak flow of stormwater discharge from the project site is less than existing conditions. The Final Hydrology and Hydraulic Analyses shall also demonstrate that the detention facilities meet the hydromodification requirements of the Waste Discharge Requirements for the County of Orange, Orange County Flood Control District and the Incorporated Cities of Orange County within the Santa Ana Region Areawide Urban Storm Water Runoff Orange County (North Orange County MS4 Permit), Order R8-2009-0030, NPDES No. CAS618030 (as amended by Order No. R8-2010-0062). In compliance with the
hydromodification requirements, the post-project runoff discharge volume for the 2-year storm shall not exceed that of the predevelopment condition by more than 5 percent, and the time of concentration of post-development runoff for the 2-year storm event shall not be greater than 5 percent less than that of the predevelopment condition. The Director of the City of Lake Forest Public Works Department, or designee, shall ensure that the drainage facilities specified in the Final Hydrology and Hydraulic Analyses are incorporated into the final project design.
c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.7-13 to 4.7-14)
d. Supporting Explanation: During construction of the proposed project, soil would be exposed and there would be increased potential for soil erosion and siltation compared to existing conditions. During storm events, erosion and siltation could occur at an accelerated rate. To address the potential for erosion, the proposed project would be required to implement a Storm Water Pollution Prevention Plan (SWPPP) including BMPs during construction, which would reduce erosion in accordance with the requirements of the Construction General Permit as detailed in RCM WQ-1 The proposed project must further comply with Article XIII of the City’s Municipal Code, which requires the preparation and submission of an Erosion Control Plan, and that all grading be undertaken in accordance with BMPs for pollution as detailed in RCM WQ-2. Furthermore, the proposed project would be required to implement a project-specific Water Quality Management Plan (WQMP), which would contain post-construction measures as detailed in RCM WQ-3 and RCM WQ-4. During project operations, the majority of the project site would be covered with impervious surfaces (e.g., asphalt, concrete, an industrial building), which are not subject to erosion. Compliance with existing regulatory requirements as detailed in RCMs WQ-3 and WQ-4 would ensure that the proposed project would result in a less than significant impact related to soil erosion or loss of topsoil. (DEIR 4.7-13 to

4.7-14)
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16. Threshold 4.7.4: The proposed project would not be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property.

Impact: The proposed project would not be located on expansive soil, creating substantial direct or indirect risks to life or property. (DEIR at 4.7-15 to 4.7-16) a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.7-15 to 4.7-16) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.7-15 to 4.7-16)
d. Supporting Explanation: Soils with an expansion index of greater than 20 are classified as expansive for building purposes and therefore have a potentially significant impact. Based on laboratory testing completed as part of the Geotechnical Investigation, the soils on the project site were classified to have very low expansion potential (Expansion Index = 12). Therefore, impacts related to expansive soils would be less than significant, and no mitigation is required. (DEIR at 4.7-15 to 4.7- 16)

17. Cumulative Impact: Project development, together with cumulative projects, would not result in significant impacts related to geology and soils in the project area. (DEIR at 4.7- 17 to 4.7-18)
a. Finding: Changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this cumulative impact (DEIR at 4.7-17 to 4.7-18) c. Applicable Mitigation Measures: No mitigation measures are applicable to this cumulative impact. (DEIR at 4.7-17 to 4.7-18)
d. Supporting Explanation: The proposed project would have no impact related to: (1) potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map; (2) potential substantial adverse effects, including the risk of loss, injury, or death involving seismic-related ground failure, including liquefaction; (3) the risk of loss, injury, or death involving landslides; (4) a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, or liquefaction or (5) the soils' capability to adequately support the use of septic tanks or alternative wastewater disposal systems. Therefore, the proposed project would not contribute to a cumulatively considerable impact relative to these issues. (DEIR at

4.7-17 to 4.7-18)
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With implementation of project-specific mitigation measures MM GEO-1 and MM GEO-2, which require compliance with applicable recommendations of the projectspecific geotechnical report and applicable codes, regulations, and design standards (MM GEO-1) and the protection of ferrous metal against corrosion (MM GEO-2); and adherence to RCMs WQ-1 through RCM WQ-4, project-level impacts associated with soil erosion and loss of topsoil would be less than significant. Development within the cumulative study area would also be required to comply with recommendations in site-specific geotechnical investigation reports, a SWPPP, and applicable codes, regulations, and design standards including the City of Lake Forest Building Code and CBC, which would reduce potential impacts associated with geologic hazards for those projects. Therefore, the proposed project would not result in cumulatively considerable impacts related to collapsible or corrosive soil, or the soil erosion of topsoil; and the proposed project’s contribution to any cumulative geologic impact would be less than significant and no mitigation is required to reduce cumulative impacts. (DEIR at 4.7-17 to 4.7-18)
Each development project in the cumulative study area would be subject to CEQA requirements, mitigation measures, and design review, if applicable. If during this review, a project is determined to have a potential to result in significant impacts to a paleontological resources or unique geologic feature, an investigation would be required to determine the nature and extent of the potentially impacted resources and identify appropriate mitigation measures. When resources are assessed and/or protected as they are discovered, cumulative impacts on these resources are less than significant. Therefore, implementation of project-specific mitigation measures MM GEO-1 and MM GEO-2 would ensure that the proposed project, together with cumulative projects, would not contribute a cumulatively considerable impact on unique paleontological resources or sites, or unique geologic features. (DEIR at 4.7- 18)
Greenhouse Gas:

18. Threshold 4.8.1: The proposed project would not generate greenhouse gas (GHG) emissions, either directly or indirectly, that may have a significant impact on the environment.

Impact: The proposed project would not generate GHG emissions, directly or indirectly, that may have a significant impact on the environment. Impacts would be less than significant. (DEIR at 4.8-14 to 4.8-16)
a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.8-14 to 4.8-16) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.8-14 to 4.8-16)
d. Supporting Explanation: The proposed project would result in approximately 2,884.8 metric tons of carbon dioxide equivalents per year (MT CO2e/yr). (DEIR Table 4.8.B., at 4.3-16) This volume includes construction-related GHG emissions which have Item: 2
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been amortized over a 30-year period. The volume of GHG emitted by the proposed project would not exceed the SCAQMD threshold of 3,000 MT CO2e/yr. Therefore, operation of the proposed project would not generate significant GHG emissions that would have a significant effect on the environment. Impacts would be less than significant. (DEIR at 4.8.14 to 4.8-16)
Hazards and Hazardous Materials:

19. Threshold 4.9.1: The proposed project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials.

Impact: The proposed project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials.

Impacts would be less than significant. (DEIR at 4.9-9 to 4.9-12) a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.9-9 to 4.9-12) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.9-9 to 4.9-12)
d. Supporting Explanation: Future activities at the project site, including both construction and operation, would be subject to existing federal, State, and local regulatory programs for hazardous materials. Compliance with the existing hazardous materials regulations and programs described above, including requirements for Hazard Materials Business Plan (HMBP) and Risk Management Plan (RMPs) for facilities handling significant quantities of hazardous materials, Occupational Safety and Health Administration (OSHA) and Division of Occupational Safety and Health of California (Cal/OSHA) regulations, CCR Title 8; the Construction General Permit (CGP); and United States Department of Transportation (USDOT), Resource Conservation and Recovery Act (RCRA), and State regulations, would ensure that the proposed project would not create a significant hazard to the public or the environment from the routine transport, use, or disposal of hazardous materials associated with the proposed project by ensuring that these materials are properly handled during construction and operation. Therefore, impacts associated with the routine transport, use, or disposal of hazardous materials would be less than significant. No mitigation is required. (DEIR at 4.9-9 to 4.9-12)

20. Threshold 4.9.2: The proposed project would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment.

Impact: The proposed project would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. Impacts would be less than significant. (DEIR at 4.9-12 to 4.9-13)
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a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.9-12 to 4.9-13) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.9-12 to 4.9-13)
d. Supporting Explanation: The site-specific Phase I Environmental Site Assessment (ESA) did not identify any recognized environmental condition (REC), historic RECs, or controlled RECs in connection with the existing uses on or surrounding the project site that would result in a potential release of hazardous materials into the environment during construction. No staining or other evidence of leaks were observed on or around the transformers. Based on the construction date of the existing building, these transformers are unlikely to contain polychlorinated biphenyls (PCBs). PCBs were manufactured in the United States between 1930 and 1977.

Therefore, construction of the proposed project would not require the transport of PCBs off site or result in a potential release of PCBs into the environment during construction. Based on the construction date of the existing building, lead-based paint was unlikely to be found at the subject property. Therefore, construction of the proposed project which would include demolition of the existing building would not require the transport of PCBs off site or result in a potential release of PCBs into the environment during construction.

Asbestos containing materials were identified in the existing on-site structures. The demolition of these structures could result in the release of hazardous materials into the environment. Prior to any activities that could disturb suspect ACMs or presumed ACMS (PACMs), these and similar materials should be analyzed for possible asbestos content. If these materials are confirmed to contain asbestos, the construction contractor would be required to comply with applicable United States Environmental Protection Agency (USEPA), OSHA, National Emission Standards for Hazardous Air Pollutants (NESHAPs), and State and local regulations. Compliance with federal and State regulations pertaining to the handling of ACMs, PACMs, and other hazardous materials would ensure the impacts associated with the associated with the reasonably foreseeable upset and accident conditions involving the release of hazardous materials would be less than significant.

Although the tenant for the proposed project is not known at this time, should the tenant of the proposed project use hazardous materials, compliance with existing federal, State, and local regulations that are intended to prevent the reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment would ensure protection of human health and the environment during operation of the proposed project. Therefore, compliance with the existing hazardous materials regulations and programs including requirements for HMBPs and RMPs for facilities handling significant quantities of hazardous materials, OSHA and Cal/OSHA regulations, CCR Title 8; the CGP; and USDOT, RCRA, and State regulations, would ensure that operation of the proposed project would not result in impacts associated with the reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. Therefore, impacts associated with the reasonably foreseeable upset Item: 2
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and accident conditions involving the release of hazardous materials into the environment during project operation would be less than significant, and no mitigation is required. (DEIR at 4.9-12 to 4.9-13)

21. Threshold 4.9.3: The proposed project would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school.

Impact: The proposed project would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school. Impacts would be less than significant. (DEIR 4.9-14) a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.9-14)
c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.9-14)
d. Supporting Explanation: The closest school to the project site is located approximately 733 feet (0.14 mile) south of the project site. Any hazardous materials associated with construction of the proposed project or future operations on the project site would be contained, stored, and used in accordance with manufacturers’ instructions and handled in compliance with applicable federal, State, and local standards and regulations as described above. Therefore, impacts related to hazardous emissions or handling of hazardous or acutely hazardous materials, substances, or waste within 0.25 mile of an existing or proposed school would be less than significant. No mitigation is required. (DEIR at 4.9-14)

22. Threshold 4.9.6: The proposed project would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan.

Impact: The proposed project would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. Impacts would be less than significant. (DEIR 4.9-15)
a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.9-15)
c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.9-15)
d. Supporting Explanation: The proposed project would require temporary lane closures to complete the proposed intersection improvements and may require temporary lane closures on Enterprise Way for the completion of utility connections. However, Item: 2
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the proposed project would be required to comply with the California Manual on Uniform Traffic Control Devices (CA MUTCD), which provides uniform standards and specifications for all official traffic control devices in California. Compliance with standards included in the CA MUTCD would ensure that any temporary lane closures that may result from the proposed project would not result in inadequate emergency access at the project site or in the project vicinity. Therefore, construction of the proposed project would not physically impair or otherwise interfere with emergency response or evacuation in the project vicinity. Impacts related to emergency response and evacuation in the project vicinity would be less than significant. (DEIR at 4.9-15)
All site access points and driveway aprons would be designed and constructed to adequate widths for public safety pursuant to the OCFA. Compliance with standard and emergency OCFA and City requirements, such as the size and location of fire access routes and fire truck turning radii, would allow for proper site evacuation, if necessary, during project operations; therefore, the proposed project would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan and impacts would be less than significant. No mitigation is required. (DEIR at 4.9-15)

23. Cumulative Impact: Project development, together with cumulative projects, would not result in significant impacts related to hazards and hazardous materials in the project area. (DEIR 4.9-15)
a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.9-16 to 4.9-18) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.9-16 to 4.9-18)
d. Supporting Explanation: The proposed project would have no impact related to: (1) a significant hazard to the public or the environment because it is on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5; (2) a safety hazard or excessive noise associated with a nearby airport; or (3) a significant risk of loss, injury or death involving wildland fires. Therefore, the proposed project would not contribute to cumulatively considerable impacts associated with a hazardous materials site, excessive noise, or significant risk of loss, injury or death involving a wildland fire. (DEIR at 4.9-16 to 4.9-17) Project compliance with existing hazardous materials regulations including the USEPA, USDOT, RCRA, OSHA, and Cal/OSHA, the California Fire Code, California Health and Safety Code, CCR, the California Department of Transportation (Caltrans), and other federal, State, and local regulations would ensure that projectrelated impacts involving the routine transport, use, or disposal of hazardous materials or release of hazardous materials into the environment, including hazardous emissions near schools, would be less than significant. The proposed project would not result in cumulatively considerable impacts related to the routine transport, use, or disposal of hazardous materials or accidental release of hazardous Item: 2
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materials into the environment, including hazardous emissions near schools. The project’s contribution to any cumulative impacts would be less than significant.

Where hazardous materials are used or located, cumulative development would similarly be required to comply with these existing hazardous material regulations. (DEIR 4.9-17)
Implementation of the City’s General Plan policies and programs would ensure that the City maintains an effective emergency response program that accounts for development of the project and projects in the cumulative study area. When considered in combination with all development within the cumulative study area, the proposed project would not cumulatively impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan.

Therefore, the proposed project would not contribute to a cumulatively considerable impact related to emergency response or evacuation plans within the City, and cumulative impacts would be less than significant. No mitigation is required. (DEIR at

4.9-18)
Hydrology and Water Quality:

24. Threshold 4.10.1: The proposed project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality; would not cause a significant alteration of receiving water quality during or following construction; would not substantially degrade water quality by discharge which affects the beneficial uses (i.e. swimming, fishing, etc.) of the receiving or downstream waters; and would not cause an increase in any pollutant for which the receiving water body is already impaired as listed on the Clean Water Act Section 303(d) list..

Impact: Construction and operation of the proposed project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality; would not cause a significant alteration of receiving water quality during or following construction; would not substantially degrade water quality by discharge which affects the beneficial uses (i.e. swimming, fishing, etc.) of the receiving or downstream waters; and would not cause an increase in any pollutant for which the receiving water body is already impaired as listed on the Clean Water Act Section 303(d) list with compliance with applicable regulatory requirements. Impacts would be less than significant. (DEIR at 4.10-29 to 4.10-31) a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: The following regulatory compliance measures are applicable to this topical area. (DEIR at 4.10-29 to 4.10-31, and 4.10- 39 to 4.10-41)
RCM WQ-1 Construction General Permit. Prior to the issuance of a grading permit, the Construction Contractor shall obtain coverage under the State Water Resources Control Board (SWRCB) National Pollutant Discharge Elimination System (NPDES) General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities (Order No. 2022-0057-DWQ, NPDES No. CAS000002) (Construction General Permit). This shall include submission of Permit Item: 2
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Registration Documents (PRDs), including a Notice of Intent for coverage under the permit to the SWRCB via the Stormwater Multiple Application and Report Tracking System (SMARTs). The Construction Contractor shall provide the Waste Discharge Identification Number (WDID) to the Lake Forest Public Works Director, or designee, to demonstrate proof of coverage under the Construction General Permit.

Project construction shall not be initiated until a WDID is received from the SWRCB and is provided to the City, or designee.

A Storm Water Pollution Prevention Plan (SWPPP) shall be prepared by a Qualified SWPPP Developer in accordance with the requirements of the Construction General Permit and submitted vis SMARTs. These include: Best Management Practices (BMPs) for erosion and sediment control, site management/housekeeping/ waste management, management of non-storm water discharges, run-on and runoff controls, and BMP inspection/maintenance/repair activities. BMP implementation shall be consistent with the BMP requirements in the most recent version of the California Stormwater Quality Association’s Stormwater Best Management Handbook: Construction.

The SWPPP shall include a construction site monitoring program that identifies requirements for dry weather visual observations of pollutants at all discharge locations, and as appropriate (depending on the Risk Level), sampling of the site effluent and receiving waters. A Qualified SWPPP Practitioner shall be responsible for implementing the BMPs at the site and performing all required monitoring and inspection/ maintenance/repair activities.

Upon completion of construction and stabilization of the site, a Notice of Termination shall be submitted via SMARTs.

RCM WQ-2 City of Lake Forest Municipal Code. Prior to the issuance of a grading permit, the Project Applicant shall submit and obtain approval of an Erosion Control Plan in compliance with Article XIII of Chapter 8.30 of the City of Lake Forest Municipal Code from the Lake Forest Public Works Director, or designee. The Erosion Control Plan shall be submitted to the City of Lake Forest Building Official for approval by September 15 each year for projects under a grading permit. All grading shall be undertaken in accordance with the BMPs for pollution prevention adopted by the City, the City’s NPDES Permit regulating discharges into and from its Municipal Separate Storm Sewer System (MS4), the Drainage Area Management Plan (DAMP), and any other conditions, requirements and water quality management plans adopted by the City. Additionally, the project Applicant shall adhere to the erosion and sediment control and water quality system maintenance requirements listed in Section 8.30.154 of the Lake Forest Municipal Code.

BMPs shall be designed and implemented to address 303(d) listed pollutants and retain the project site’s minimum design capture volume and hydromodification volume to ensure that post-development storm water runoff volume or time of concentration does not exceed predevelopment storm water runoff by more than 10 percent of the 2-year peak flow in accordance with the Santa Ana Regional Water Quality Control Board Order Number R8-2009-0030, NPDES Permit No.

The Final Hydrology and Hydraulic Analyses shall confirm that the onsite storm drains, on-site detention basins, and any other drainage structures are appropriately sized to accommodate stormwater runoff from the design storm so that the peak flow of stormwater discharge from the project site is less than existing conditions. The Final Hydrology and Hydraulic Analyses shall also demonstrate that the detention facilities meet the hydromodification requirements of the Waste Discharge Requirements for the County of Orange, Orange County Flood Control District and the Incorporated Cities of Orange County within the Santa Ana Region Areawide Urban Storm Water Runoff Orange County (North Orange County MS4 Permit), Order R8- 2009-0030, NPDES No. CAS618030 (as amended by Order No. R8- 2010-0062). In compliance with the hydromodification requirements, the post-project runoff discharge volume for the 2-year storm shall not exceed that of the predevelopment condition by more than 5 percent, and the time of concentration of post-development runoff for the 2-year storm event shall not be greater than 5 percent less than that of the predevelopment condition. The Director of the City of Lake Forest Public Works Department, or designee, shall ensure that the drainage facilities specified in the Final Hydrology and Hydraulic Analyses are incorporated into the final project design.
c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.10-29 to 4.10-31)
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d. Supporting Explanation: The proposed project will be required to implement construction BMPs during construction activities, as specified in RCM WQ-1.

Construction BMPs would include, but are not limited to, Erosion Control and Sediment Control BMPs designed to minimize erosion and retain sediment on site as well as Good Housekeeping BMPs to prevent spills, leaks, and discharge of construction debris and waste into receiving waters. Additionally, the proposed project must comply with Article XIII of Chapter 8.30 of the City’s Municipal Code, which requires the preparation and submission of an Erosion Control Plan and that all grading be undertaken in accordance with BMPs for pollution prevention adopted by the City as detailed in RCM WQ-2. Adherence to these measures would ensure construction impacts related to surface water quality standards, waste discharge requirements, and surface water quality would be less than significant; therefore, no mitigation is required. (DEIR at 4.10-29 to 4.10-30)
Development of the proposed project would increase impervious surfaces on the project site, which could decrease on-site infiltration. The proposed project would also be required to prepare a Final WQMP, as detailed in RCM WQ-3, consistent with the requirement of the City’s MS4 permit. The Final WQMP would specify the Site Design, Source Control, LID, and Treatment Control BMPs that would be implemented to capture, treat, and reduce pollutants of concern in storm water runoff. Additionally, as specified in RCM WQ-4, a Final Hydrology Study would be required to be prepared, which would demonstrate that the final design of the proposed project meets the hydromodification requirements. Compliance with the requirements of the City and the North Orange County MS4 Permit, as detailed in RCM WQ-3 and RCM WQ-4, would ensure that the project would not increase any pollutant for which the receiving water bodies are already impaired as listed on the Clean Water Act Section 303(d) list, and that the proposed project would not result in discharge which would affect the beneficial uses of Serrano Creek or result in an increase in any pollutant for which Serrano Creek is already impaired. Therefore, operational impacts to water quality would be less than significant, and no mitigation is required. (DEIR at 4.10-30 to 4.10-31)

25. Threshold 4.10.2: The proposed project would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin; would not substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level (e.g. the production rate of pre-existing nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted); and would not adversely change the rate, direction or flow of groundwater.

Impact: The proposed project would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin; would not substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level (e.g. the production rate of pre-existing nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted); and would not adversely change the rate, direction or flow of groundwater.

Impacts would be less than significant. (DEIR at 4.10-31 to 4.10-32) Item: 2
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a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.10-31 to 4.10-32) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.10-31 to 4.10-32)
d. Supporting Explanation: Groundwater was not encountered during explorations to depths of more than 30 feet below the existing grade on the project site. The proposed project would require excavation to a maximum depth of 6 feet below the existing grade; therefore, groundwater dewatering would not be required during construction of the proposed project and construction of the proposed project would not substantially decrease groundwater supplies, interfere with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level, impede sustainable groundwater management of the basin, or adversely change the rate, direction or flow of groundwater. Impacts would be less than significant and no mitigation is required. (DEIR at 4.10-31) Water supply for operation of the proposed project would likely involve the use of both surface and groundwater sources for use in restrooms and for irrigation of landscaped areas. According to water demand factors included in the California Emissions Estimator Model (CalEEMod) emissions model, the proposed project is estimated to demand approximately 107,410 gallons per day or 120 acre feet per year of water. The 2020 Urban Water Management Plan indicates the IRWD has sufficient water supplies to meet water demands through 2045, including during multiple dry years. Therefore, the proposed project’s water needs would not contribute to a substantial depletion of groundwater supplies. Due to the presence of dense engineered fill soils comprised of silty sands and clayey sands that possess very poor infiltration characteristics, the project site is not a significant source of groundwater recharge. Therefore, the increase in impervious surface area that would result from the development of the proposed project would not significantly decrease groundwater supplies or interfere with groundwater recharge in a manner that may impede sustainable groundwater management, or adversely change the rate, direction or flow of groundwater. Impacts would be less than significant, and no mitigation is required. (DEIR at 4.10-31 to 4.10-32)

26. Threshold 4.10.3(i): The proposed project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would result in substantial erosion or siltation on- or off-site; and would not deposit sediment and debris materials within existing channels obstructing flows.

Impact: Construction and operation of the proposed project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would result in substantial erosion or siltation on- or off-site; and would not deposit sediment and debris materials within existing channels obstructing flows with compliance with applicable regulatory requirements. Impacts would be less than significant. (DEIR at

4.10-32 to 4.10-33)
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a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: RCMs WQ-1 through WQ-4, discussed above, are applicable to this topical area. (DEIR at 4.10-32 to 4.10-33) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.10-32 to 4.10-33)
d. Supporting Explanation: During a storm event, soil erosion and siltation could occur at an accelerated rate on site during construction of the proposed project. As required by RCM WQ-1, construction BMPs will be identified and implemented to reduce impacts on water quality during construction, including those impacts associated with soil erosion and siltation. The proposed project must further comply with Article XIII of Chapter 8.30 of the City’s Municipal Code, which requires the preparation and submission of an Erosion Control Plan and as detailed in RCM WQ2. Compliance with these requirements would ensure that the proposed project would not result in erosion or siltation on- or off-site, and the project would not deposit sediment and debris materials within existing channels obstructing flows.

Construction impacts related to on- or off-site erosion or siltation and deposition of sediment and debris within existing channels would be less than significant, and no mitigation is . (DEIR at 4.10-32)
The underground detention systems included in the project’s design would be used for stormwater control and treatment in compliance with the requirements of the North Orange County MS4 Permit as detailed in RCM WQ-3 and RCM WQ-4; therefore, operational impacts related to on- or off-site erosion or siltation would be less than significant. No mitigation is required. (DEIR at 4.10-33)

27. Threshold 4.10.3(ii): The proposed project would not alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site; and would not exceed the capacity of a channel and cause overflow during design storm conditions.

Impact: Construction and operation of the proposed project would not alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site; and would not exceed the capacity of a channel and cause overflow during design storm conditions with compliance with applicable regulatory requirements. Impacts would be less than significant. (DEIR at 4.10-33) a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: RCMs WQ-3 and WQ-4 discussed above are applicable to this topical area. (DEIR at 4.10-33) Item: 2
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c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.10-33)
d. Supporting Explanation: The proposed drainage facilities would be appropriately sized to detain stormwater runoff so that with implementation of BMPs, on-site flooding would not occur. Therefore, with implementation of BMPs including LID techniques and hydromodification requirements as required by the North Orange County MS4 Permit, the proposed project would not substantially increase the rate or amount of surface runoff in a manner that would exceed the capacity of a channel and cause overflow or result in flooding on- or off site during design storm conditions.

Impacts would be less than significant, and no mitigation is required. (DEIR at 4.10- 33)

28. Threshold 4.10.3(iii): The proposed project would not alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would create or contribute runoff water which would exceed the capacity of existing or planned storm water drainage systems or provide substantial additional sources of polluted runoff; and would not exceed the capacity of a channel and cause overflow during design storm conditions.

Impacts would be less than significant. (DEIR at 4.10-33 to 4.10-34) a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: RCMs WQ-1 through WQ-4 discussed above are applicable to this topical area. (DEIR at 4.10-33 to 4.10-34) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.10-33 to 4.10-34)
d. Supporting Explanation: The proposed project would include three linear modular wetland systems and three underground detention systems to reduce site discharge during the 100-year, 24-hour peak runoff rate by 47 percent. The proposed drainage facilities would be designed in compliance with the North Orange County MS4 Permit as detailed in RCM WQ-3 and RCM WQ-4. The proposed drainage facilities and BMPs needed to accommodate stormwater runoff would be appropriately sized to retain and gradually release stormwater runoff such that drainage facility capacity would not be exceeded during a design storm. Therefore, the proposed project would not result in an exceedance of planned or existing stormwater drainage systems, or the capacity of a channel. Impacts would be less than significant, and no mitigation is required. (DEIR at 4.10-33 to 4.10-34)
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In accordance with RCM WQ-1, the proposed project would be required to identify and implement BMPs to control the discharge of pollutants in stormwater runoff as a result of construction activities. In accordance with RCM WQ-2, the proposed project must comply with Article XIII of Chapter 8.30 of the City’s Municipal Code, which requires the preparation and submission of an Erosion Control Plan and that all grading be undertaken in accordance with BMPs for pollution prevention. With implementation of RCM WQ-1 and WQ-2, construction-related impacts related to polluted stormwater runoff would be less than significant, and no mitigation is required. (DEIR at 4.10-33 to 4.10-34)
With implementation of RCM WQ-3 and RCM WQ-4, requiring compliance with the North Orange County MS4 Permit, the implementation LID techniques, and the incorporation of operational BMPs to target pollutants of concern, the proposed project would not discharge substantial sources of polluted runoff from the project site during project operation. Therefore, operational impacts related to polluted stormwater runoff would be less than significant, and no mitigation is required. (DEIR at 4.10-33 to 4.10-34)

29. Threshold 4.10.4: The proposed project would not risk the release of pollutants due to inundation in a flood hazard, tsunami, or seiche zone; would not expose people or structures to a significant risk of loss, injury or death involving flooding, including flooding as a result of the failure of a levee or dam; and would not cause inundation by seiche, tsunami, or mudflow.

Impact: The proposed project would not risk the release of pollutants due to inundation in a flood hazard, tsunami, or seiche zone; would not expose people or structures to a significant risk of loss, injury or death involving flooding, including flooding as a result of the failure of a levee or dam; and would not cause inundation by seiche, tsunami, or mudflow. Impacts would be less than significant. (DEIR at 4.10-35) a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.10-35)
c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.10-35)
d. Supporting Explanation: The project site is located in Zone X, which is identified as an area of minimal flood hazard. Therefore, the proposed project would not risk release of pollutants due to project inundation due to flood hazard. There are no dam inundation areas in the City of Lake Forest. Therefore, the proposed project would not risk release of pollutants due to dam inundation. The project site is over 10 miles northeast of the Pacific Ocean at an elevation of approximately 700 feet above mean sea level. Therefore, the proposed project would not risk release of pollutants due to a tsunami, cause inundation by a tsunami, or expose people or structures to a significant risk of loss, injury or death as a result of a tsunami. Additionally, there are no nearby enclosed bodies of water in the vicinity of the project site. Therefore, the proposed project would not risk release of pollutants due to project inundation due to seiche or cause inundation by a seiche. As the project site is not located within a Item: 2
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flood, tsunami, seiche, or dam inundation area, implementation of the proposed project would not result in the release of pollutants from a flood, dam inundation, tsunami, or seiche. Additionally, the proposed project is not located within a levee flood protection zone as defined by the State of California Department of Water Resources; therefore, the proposed project would not expose people or structures to a significant risk of loss, injury or death involving flooding as a result of a levee failure. Furthermore, the topography of the project site is primarily flat with no steep slopes with loose soil, earth, or debris. Therefore, the proposed project would not cause inundation by mudflow. Impacts would be less than significant, and no mitigation is required. (DEIR at 4.10-35)

30. Threshold 4.10.5: The proposed project would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan; and would not have an impact on groundwater that is inconsistent with a groundwater management plan prepared by the water agencies with the responsibility for groundwater management.

Impact: Construction and operation of the proposed project would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan; and would not have an impact on groundwater that is inconsistent with a groundwater management plan prepared by the water agencies with the responsibility for groundwater management with compliance with applicable regulatory requirements. Impacts would be less than significant. (DEIR at 4.10-35 to 4.10-37) a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: RCM WQ-1 through RCM WQ-4 discussed above are applicable to this topical area. (DEIR at 4.10-35 to 4.10-37) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.10-35 to 4.10-37)
d. Supporting Explanation: The proposed project would comply with existing National Pollutant Discharge Elimination System (NPDES) permit requirements, including the CGP and North Orange County MS4 Permit, and would implement construction and operational BMPs to reduce pollutants of concern in stormwater runoff as detailed in RCM WQ-1, RCM WQ-2, RCM WQ-3, and RCM WQ-4. Compliance with these regulatory requirements would ensure that the proposed project would not degrade or alter water quality, cause the receiving waters to exceed the water quality objectives, or impair the beneficial use of receiving waters. Therefore, the proposed project would not result in water quality impacts that would conflict with the Water Quality Control Plan for the Santa Ana River Basin (Basin Plan). Construction and operational impacts related to a conflict with the Basin Plan would be less than significant, and no mitigation is required. (DEIR at 4.10-36) The groundwater table is expected to exist at a depth in excess of 30 feet at the project site. The proposed project would require excavation to a maximum depth of 6 feet below the existing grade. Therefore, it is not anticipated that groundwater dewatering would be required during construction of the proposed project. In addition, the project site is not a significant source of groundwater recharge.

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Therefore, construction of the proposed project would not conflict with or obstruct implementation of the Groundwater Sustainability Plan (GSP). Impacts would be less than significant, and no mitigation is required. (DEIR at 4.10-36) As detailed in RCM WQ-3, compliance with the North Orange County MS4 Permit, the implementation of LID techniques, and the incorporation of operational BMPs to target pollutants of concern would ensure that the proposed project would not discharge substantial sources of polluted runoff from the project site; therefore, the proposed project would not conflict with or obstruct the implementation of a sustainable groundwater management plan prepared by the water agencies with the responsibility for groundwater management. Impacts would be less than significant, and no mitigation is required. (DEIR at 4.10-35 to 4.10-37)

31. Cumulative Impact: Project development, together with cumulative projects, would not result in significant impacts related to hydrology and water quality in the project area. (DEIR at 4.10-37 to 4.10-38)
a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.10-37 to 4.10-38) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.10-37 to 4.10-38)
d. Supporting Explanation: The proposed project would not alter drainage patterns in a manner that would impede or redirect flood flows; therefore, there would be no cumulatively considerable impact on flood flows resulting from changes to drainage patterns. New development and redevelopment can result in increased stormwater runoff and increased urban pollutants in stormwater runoff from project sites.

Consistent with the proposed project, each project in the cumulative study area is required to include BMPs to reduce impacts related to hydrology and water quality in compliance with local ordinances and plans adopted to comply with requirements of the various NPDES permits including the CGP, the North Orange County MS4 Permit, and the City of Lake Forest Municipal Code. Each project in the cumulative study area would be required to develop a SWPPP, erosion and sediment control plans, a WQMP, and a hydrology study, and would be evaluated individually to determine appropriate BMPs and treatment measures to reduce impacts to hydrology and surface water quality. Because the proposed project and projects within the cumulative study area would be required to comply with applicable NPDES requirements and would include BMPs to reduce the volume of stormwater runoff and pollutants of concern in stormwater runoff, the proposed project would not result in cumulatively considerable impacts related to hydrology and water quality. Impacts would be less than significant, and no mitigation is required. (DEIR at 4.10-37 to

4.10-38)
Noise:

32. Threshold 4.13.1: The proposed project would not result in the generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the Item: 2
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project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies; would not result in a 3 dBA CNEL increase in noise when existing noise levels are between 60 dBA and 65 dBA CNEL; would not result in a 1.5 dBA CNEL increase in noise when existing noise levels exceed 65 dBA CNEL; would not exceed the stationary source noise criteria for the City of Lake Forest as specified by the exterior noise standards set forth in the Noise Control Chapter (11.16) of the Lake Forest Municipal Code; and during construction, would not exceed 80 dBA Leq (1-hour) between the hours of 7:00 a.m. and 8:00 p.m., Monday through Saturday.

Impact: The proposed project would not result in the generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies; would not result in a 3 dBA CNEL increase in noise when existing noise levels are between 60 dBA and 65 dBA CNEL; would not result in a 1.5 dBA CNEL increase in noise when existing noise levels exceed 65 dBA CNEL; would not exceed the stationary source noise criteria for the City of Lake Forest as specified by the exterior noise standards set forth in the Noise Control Chapter (11.16) of the Lake Forest Municipal Code; and during construction, would not exceed 80 dBA Leq (1-hour) between the hours of 7:00 a.m. and 8:00 p.m., Monday through Saturday with compliance with applicable regulatory requirements. Impacts would be less than significant. (DEIR at 4.13-17 to 4.13-19)
a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: The following regulatory compliance measure is applicable to this topical area. (DEIR at 4.13-17 to 4.13-19, and 4.13-23) RCM NOI-1 City of Lake Forest Municipal Code, Section 11.16.060(D). During construction, construction activities shall be limited to between the hours of 7:00 a.m. and 8:00 p.m. Mondays through Saturdays. No construction shall be permitted outside of these hours or on legal City of Lake Forest holidays, without a specific exemption issued by the City of Lake Forest.
c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.13-17 to 4.13-19)
d. Supporting Explanation: Construction noise levels, when the highest reference noise level is operating from the center of primary construction activity nearest the sensitive receiver location, would average 71 A-weighted decibel equivalent continuous sound level (dBA Leq) at the sensitive receiver locations, and therefore would not exceed the daytime construction noise level threshold of 80 dBA Leq at any receiver location. Compliance with RCM NOI-1 would ensure that construction activities would occur during 7:00 a.m. and 8:00 p.m. Mondays through Saturdays in accordance with the City’s Municipal Code. Therefore, construction-related noise impacts would be less than significant, and no mitigation is required. (DEIR at 4.13- 17)
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Project-related traffic noise would generate the greatest increase of 3.3 dBA along Enterprise Way. There are no noise sensitive uses along this roadway segment, and the resultant noise level would be well below 65 A-weighted decibel day-night noise level (dBA Ldn). All other roadway segments would be less than a 1 dBA increase. (DEIR Table 4.13.H, at 4.13.19) Noise level increases below 3 dBA would not be perceptible to the human ear in an outdoor environment. Furthermore, off-site traffic noise level increases from the project would not result in a 3 dBA CNEL increase in noise at noise sensitive uses when existing noise levels are between 60 dBA and 65 dBA CNEL or a 1.5 dBA CNEL increase in noise levels when existing noise levels exceed 65 dBA CNEL. Therefore, project-related traffic would have a less than significant impact on off-site sensitive receptors, and no mitigation is required. (DEIR at 4.13-17 to 4.13-18)
The noise model considered site topography, the shielding provided by the proposed on-site building, and a planned 16-foot-high, 60-foot-long wall, which would be located at the eastern end of the loading docks, west of the proposed trash enclosure. The hourly noise levels associated with the proposed on-site heating, ventilation, and air conditioning (HVAC) equipment, trash bin emptying activities, parking lot activities, and truck deliveries and loading and unloading activities were modeled at the surrounding sensitive receptors and would range from 50.0 dBA Leq to 52.7 dBA Leq. Therefore, the project would not exceed the stationary source noise criteria for the City of Lake Forest as specified by the exterior noise standards set forth in the Noise Control Chapter (11.16) of the Lake Forest Municipal Code.

Because these levels would be below the City’s daytime and nighttime noise standards, project operations would result in less than significant noise impacts, and no mitigation is required. (DEIR at 4.13-18)

33. Threshold 4.13.2: The proposed project would not result in the generation of excessive groundborne vibration or groundborne noise levels and would not exceed the applicable standards from the Federal Transit Administration (FTA) or Caltrans vibration limits.

Impact: The proposed project would not result in the generation of excessive groundborne vibration or groundborne noise levels and would not exceed the applicable standards from the Federal Transit Administration (FTA) or Caltrans vibration limits with compliance with applicable regulatory requirements. Impacts would be less than significant. (DEIR at 4.13-20 to 4.13-21)
a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: The following regulatory compliance measure is applicable to this topical area. (DEIR at 4.13-20 to 4.13-21, and 4.13-23 to 4.13-24)
RCM NOI-2 Pre-Construction Vibration Assessment. After a specific project equipment list has been determined and prior to the issuance of a building permit, the following actions shall be implemented:

1. A qualified structural engineer, as approved by the Director of Community Development, or designee shall identify all structures that are located within the distances established in Table 2 of Item: 2
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Section 11.16.090 of the City’s Municipal Code and that have the potential to be affected by ground-borne vibration originating from the construction; and

2. A qualified acoustical engineer shall compile a list of proposed construction equipment and compare to the City's accepted vibration criteria. If it is determined that the proposed equipment would generate vibration levels below the City's standard of 0.3 inches per second (in/sec) peak particle velocity (PPV), no further vibration assessment is necessary. However, if vibration levels would potentially exceed the City's standard of 0.3 in/sec PPV, the Project Applicant shall develop a Vibration Monitoring and Construction Contingency Plan for approval by the Director of Community Development, or designee, to ensure that vibration levels would not exceed the City's accepted vibration damage criteria of 0.3 in/sec PPV. If a Vibration Monitoring and Construction Contingency Plan is deemed necessary, monitoring of vibration during initial construction activities shall be required.

Monitoring results may indicate the need for more or less intensive measurements. The Vibration Monitoring and Construction Contingency Plan, at the discretion of the Director of Community Development or designee, shall include the following items as necessary:
• Identification of structures where monitoring would be conducted;
• A vibration monitoring schedule;
• Defined structure-specific vibration limits;
• Photographic, elevation, and crack surveys to document before and after construction conditions; and
• Identification of construction contingencies for when vibration levels approach the limits.

When vibration levels approach the limits specified in Section

11.16.090 of the City’s Municipal Code, construction shall be suspended and contingencies identified in the approved Vibration Monitoring and Construction Contingency Plan shall be
implemented as necessary to lower vibration levels, which could include shielding or protecting the affected building from potential vibration impacts as a possible alternative to changing construction methods.
c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.13-20 to 4.13-21)
d. Supporting Explanation: If large construction equipment with a reference vibration level of 0.089 inch per second (in/sec) peak particle velocity (PPV) is used within 8 feet of the industrial buildings at 26180 and 26190 Enterprise Way, they would Item: 2
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experience vibration levels of up to 0.312 PPV (in/sec). These vibration levels would exceed the 0.3 in/sec PPV threshold. However, with implementation of RCM NOI-2, which details construction vibration assessments pursuant to City Municipal Code Section 11.16.090, construction vibration impacts would be less than significant.

Compliance with the requirements of Municipal Code section 11.16.090 would ensure that the project would meet the applicable Caltrans vibration standards. No mitigation is required. (DEIR at 4.13-20)
Because the proposed stationary equipment would not generate perceptible vibration levels, the proposed project would not result in vibration impacts related to on-site stationary sources. Structures greater than 20 feet from the roadways along which project vehicles would be traveling would experience vibration levels below the standard of 0.3 in/sec PPV. Therefore, vibration levels generated from project-related traffic on site or on the adjacent roadways would be less than significant, and no mitigation is required. (DEIR at 4.13-20 to 4.13-21).

34. Cumulative Impact: Project development, together with cumulative projects, would not result in significant impacts related to noise in the project area. a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.13-21 to DEIR at 4.13-23) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.13-21 to DEIR at 4.13-23)
d. Supporting Explanation: Noise levels dissipate exponentially with distance from the noise source; therefore, noise impacts are generally localized. Hourly noise levels generated by operational activities from Western Realco Projects 1 and 2 were modeled at the closest off-site land uses and would not approach thresholds levels at the nearby sensitive uses; therefore, implementation of the proposed project, when evaluated in combination with Western Realco Projects 1 and 2, would not contribute to cumulatively considerable construction-related noise impacts in excess of standards established in a general plan or noise ordinance. The proposed project would not contribute to a cumulatively considerable operational stationary noise impact in excess of standards established in a general plan or noise ordinance. The proposed project would not contribute to a cumulatively considerable operational traffic noise impact in excess of standards established in a general plan or noise ordinance. The proposed project would not contribute to a cumulatively considerable construction vibration impact. The proposed project would not contribute to a cumulatively considerable on-site stationary source-induced vibration impact. The proposed project would not contribute to a cumulatively considerable traffic-induced vibration impact. Therefore, the proposed project would not result in a cumulatively considerable noise impact, and no mitigation is required. (DEIR at 4.13-21 to 4.13- 23)
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Population and Housing:

35. Threshold 4.14.1: The proposed project would not induce substantial unplanned population growth in an area, either directly (e.g., by proposing new homes and businesses) or indirectly (e.g., through extension of roads or other infrastructure).

Impact: The proposed project would not induce substantial unplanned population growth in an area, either directly or indirectly. Impacts would be less than significant. (DEIR at

4.14-6 to 4.14-8)
a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures area applicable to this topical area. (DEIR at 4.14-6 to 4.14-8) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.14-6 to 4.14-8)
d. Supporting Explanation: The proposed project would provide short-term construction jobs over an approximately 12-month period. The construction jobs would be temporary and would be specific to the variety of construction activities. Given the relatively short duration of construction, project-related construction workers would not be expected to relocate their places of residence as a consequence of working on the project site; therefore, the proposed project would result in a less than significant impact associated with inducing substantial population growth or demand for housing through increased construction employment.

Because the proposed project does not include residential uses, it would not result in direct population growth. Project development would generate approximately 187 new jobs in Lake Forest, representing approximately 17 percent and less than one percent of the estimated job growth estimated in Lake Forest and Orange County, respectively. Given that approximately 1,800 and 64,100 people are currently unemployed in Lake Forest and Orange County, respectively, it is reasonable to conclude that the majority of these positions would be filled by existing City or County residents. Therefore, the proposed project would not result in a significant increase to the City’s population resulting from persons moving to work at the project site. Furthermore, the proposed project is consistent with the site’s General Plan designation and does not represent unplanned growth given that the project site would be developed consistent with its land use and zoning designations. The proposed project would be connected to existing municipal utility infrastructure and would not include the construction of new roadways or infrastructure beyond that could serve areas outside the project site. The proposed project would have a less than significant impact relative to the growth of the City’s or region’s population either directly through the development of housing or indirectly through the extension of infrastructure. (DEIR at 4.14-6 to 4.14-8)

36. Cumulative Impact: Project development, together with cumulative projects, would not result in significant impacts related to population and housing in the project area. (DEIR at 4.14-8 to 4.14-9)
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a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures area applicable to this topical area. (DEIR at 4.14-8 to 4.14-9) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.14-8 to 4.14-9)
d. Supporting Explanation: The project-specific direct and indirect effects relative to unplanned growth would be less than significant. All projects in the cumulative study area would be required to evaluate potential impacts on population and housing and implement mitigation measures, as needed. Since all projects within the cumulative study area would be required to implement appropriate mitigation measures, implementation of the proposed project, in combination with other development in the City, would not contribute to a cumulatively considerable impact on population and housing. Cumulative impacts relative to population and housing would be less than significant, and no mitigation is required. (DEIR at 4.14-8 to 4.14-9) Public Services:

37. Threshold 4.15.1(i): The proposed project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for fire protection.

Impact: The proposed project would not generate the need for new or physically altered fire facilities, the construction of which could cause significant environmental impacts relative to an acceptable service ratio, response times, or other performance objectives for fire protection. Impacts would be less than significant. (DEIR at 4.15-10 to 4.15-12) a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures area applicable to this topical area. (DEIR at 4.15-10 to 4.15-12) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.15-10 to 4.15-12)
d. Supporting Explanation: The proposed project would replace an existing use of similar square footage on the same site and is surrounded by buildings of similar land use type and intensity. Therefore, the proposed project’s increase in demand for new or expanded fire protection services would be negligible. The proposed project is consistent with the site’s General Plan designation and does not represent unplanned growth given that the project site would be developed consistent with its existing land use and zoning designations. Therefore, the proposed project would not induce a substantial increase in population over that which was envisioned in the Item: 2
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build-out of the City’s General Plan and would not result in a demand for more fire protection services beyond what was anticipated and planned for.

Adherence to existing laws would ensure that the proposed project would not have a significant construction-related impact on fire protection service from the OCFA; therefore, construction-related impacts to fire protection would be minimized and the provision of and/or need for new or physically altered governmental facilities (the construction of which could cause significant environmental impacts) would not be required. In order to meet OCFA standards and to comply with the California Fire Code (in effect at the time of the application for the building permit), the proposed project would install fire sprinklers, seven fire hydrants, and appropriate and adequate emergency access. Once operational, project compliance with requirements set forth in the California Fire Code would provide fire protection for people and structures, as well as emergency medical services. Upon review of the proposed project, the OCFA has indicated that the project would have a less than significant impact on fire protection services; therefore, the proposed project would not generate the need for new or physically altered fire facilities, the construction of which could cause significant environmental impacts, to maintain an acceptable service ratio, response times, or other performance objectives for fire protection.

Impacts would be less than significant, and no mitigation is required. (DEIR 4.15-10 to 4.15-12)

38. Threshold 4.15.1(ii): The proposed project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for police protection.

Impact: The proposed project would not generate the need for new or physically altered police facilities, the construction of which could cause significant environmental impacts that impact an acceptable service ratio, response times, or other performance objectives for police protection. Impacts would be less than significant. (DEIR at 4.15-12 to 4.15-14) a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures area applicable to this topical area. (DEIR at 4.15-12 to 4.15-14) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.15-12 to 4.15-14)
d. Supporting Explanation: To minimize criminal trespassing, the project site (construction areas) would be fenced, and access points would be locked during non-construction hours. The project site is located in an area already patrolled by the Orange County Sheriff’s Department (OCSD); therefore, construction of the proposed project would not result in a demand for additional police services or significantly impact existing service ratios or response times.

The proposed project would replace an existing use of similar square footage on the same site and is surrounded by buildings of similar land use type and intensity; Item: 2
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therefore, the proposed project’s increase in demand for new or expanded police protection services would be negligible. The proposed project would not induce a substantial increase in population over that which was envisioned in the build-out of the City’s General Plan and the increased demand for police protection services would be negligible. As the proposed project would not result in a significant impact to any study area intersections; no substantial increase in response times for police or emergency vehicles would result from project development. The proposed project would implement Crime Prevention through Environmental Design (CPTED) techniques that would discourage and or reduce crime from occurring on site. The proposed project would not drive the need for a new police facility or expanded facility, the construction of which could cause significant environmental impacts.

Impacts would be less than significant, and no mitigation is required. (DEIR 4.15-12 to 4.15-14)

No mitigation is required. (DEIR 4.15-14 to 4.15-15)
Item: 2
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4.15-15 to 4.15-16)

Impact: The proposed project would not generate the need for new or physically altered public facilities, the construction of which could cause significant environmental impacts relative to an acceptable service ratio, response times, or other performance objectives for other public facilities. Impacts would be less than significant. (DEIR at 4.15-16) a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures area applicable to this topical area. (DEIR at 4.15-16) Item: 2
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c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.15-16)
d. Supporting Explanation: It is not anticipated that the proposed project would result in a significant increase to the City’s population due to hiring out of area employees that would move to the City to work at the project site. The proposed project is consistent with the site’s General Plan designation and does not represent unplanned growth given that the project site would be developed consistent with its land use and zoning designations. Therefore, the proposed project would not result in a demand for more services at City-owned facilities, such as libraries, beyond what was anticipated and planned for. Impacts would be less than significant, and no mitigation is required. (DEIR at 4.15-16)

Cumulative impacts relative to public services would be less than significant, and no mitigation is required. (DEIR at 4.15-16 to 4.15-17)
Recreation:

Impact: The proposed project would not increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated. Impacts would be less than significant. (DEIR at 4.16-4 to 4.16-5)
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a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.16-4 to 4.16-5) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.16-4 to 4.16-5)
d. Supporting Explanation: The proposed project does not propose any residential use; therefore, it would not directly increase the population of the City. It is reasonable to assume that the majority of the new jobs generated by the proposed project would be filled by existing City residents and residents of nearby cities within Orange County; therefore, the proposed project would not generate a significant increase in the City’s population. The proposed project is consistent with the site’s General Plan designation and does not represent unplanned growth given that the project site would be developed consistent with its land use and zoning designations. Because the proposed project would not significantly increase the City’s population, the proposed project would not cause an increase in the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated. Persons employed on-site may utilize existing park or trail facilities; however, any increased usage would be minimal given the relatively low number of employees on the project site and would not result in substantial physical deterioration of the parks thereby requiring additional improvements. Impacts would be less than significant, and no mitigation is required. (DEIR 4.16-4 to 4.16-5)

44. Cumulative Impact: Project development, together with cumulative projects, would not result in significant impacts related to recreation in the project area. (DEIR 5.16-5 to

When considered with other projects in the City, development of the proposed Item: 2
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project would not contribute a significant cumulative impact related to recreation.

Cumulative impacts to recreation would be less than significant, and no mitigation is required. (DEIR 4.16-5 to 4.16-6)
Transportation and Traffic:

The project is consistent with the applicable City policies relative to bicycle, pedestrian mobility, and maintenance of a safe transportation network. (DEIR Table

47. Threshold 4.17.4: The proposed project would not result in inadequate emergency access.

Item: 2
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Impact: The proposed project would not result in inadequate emergency access.

48. Cumulative Impact: Project development, together with cumulative projects, would not result in significant impacts related to tribal cultural resources in the project area. (DEIR 4-18-11)
a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.18-11)
c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.18-11)
d. Supporting Explanation: Impacts relative to tribal cultural resources would be evaluated and mitigated by each individual cumulative project, applying mitigation as appropriate. As potential tribal cultural resources are assessed and/or protected as they are discovered, impacts to these resources would be reduced to less than Item: 2
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significant. All development projects within the cumulative study area would be required to consult with the appropriate tribes and identify proper mitigation to address any potentially significant impacts to tribal cultural resources. As all projects within the cumulative study area would be required to implement appropriate regulatory compliance measures and mitigation measures to avoid or mitigate impacts to tribal cultural resources, when considered with other projects in the City, development of the proposed project would not contribute a significant cumulative impact related to tribal cultural resources. Cumulative impacts to tribal cultural resources would be less than significant and no mitigation is required. (DEIR 4.18- 11)
Utilities and Service Systems:

Item: 2
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Therefore, impacts related to wastewater treatment are less than significant, and no mitigation is required. (DEIR at 4.19-14)
The proposed project would include three modular wetland systems and three underground detention chambers to reduce site discharge during the 100-year, 24- hour peak runoff rate by 40 percent. The proposed drainage facilities would be designed in compliance with the North Orange County MS4 Permit as detailed in RCM WQ-3 and RCM WQ-4. Therefore, peak discharge would not adversely affect the capacity of downstream networks, and construction or expansion of stormwater drainage facilities would not be required. Impacts related to stormwater drainage would be less than significant, and no mitigation is required. (DEIR at 4.19-14 to

Impact: The proposed project would have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years. Impacts would be less than significant. (DEIR at 4.19-16 to 4.19-17) a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.19-16 to 4.19-17) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.19-16 to 4.19-17)
d. Supporting Explanation: The IRWD is able to meet the projected water demands of existing and planned uses through 2040 under normal year, single dry-year condition, and over five years of consecutive drought. The potable water demand Item: 2
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associated with the proposed project would only represent less than one percent of the surplus water supply in the IRWD’s service area in 2025 through 2040 under the worst-case scenario, the proposed project would not necessitate new or expanded water facilities, and the IRWD would be able to accommodate the increased demand for potable water. Therefore, impacts would be less than significant, and no mitigation is required. (DEIR at 4.19-16 to 4.19-17)

Impact: The proposed project would not generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals. Impacts would be less than significant. (DEIR at 4.19-17 to 4.19-18)
a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.19-17 to 4.19-18) c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.19-17 to 4.19-18)
Item: 2
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d. Supporting Explanation: Construction activities occurring on the project site would generate solid waste; however, the proposed project would be required to comply with the CALGreen Code, which requires that at least 65 percent of non-hazardous construction and demolition waste from non-residential construction operations be recycled and/or salvaged for reuse. Solid waste generated by construction activities associated with the proposed project would not cause the capacity at the Frank R.

4.19-18)

53. Threshold 4.19.5: The proposed project would comply with federal, State, and local management and reduction statutes and regulations related to solid waste.

54. Cumulative Impact: Project development, together with cumulative projects, would not result in significant impacts related to utilities and service systems in the project area. (DEIR at 4.19-19)
a. Finding: No changes or alterations have been required, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect as identified in the FEIR. (State CEQA Guidelines Section 15091(a)(1).) Item: 2
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b. Applicable Regulatory Compliance Measures: No regulatory compliance measures are applicable to this topical area. (DEIR at 4.19-19)
c. Applicable Mitigation Measures: No mitigation measures are applicable to this topical area. (DEIR at 4.19-19)
d. Supporting Explanation: The proposed project would have a less than significant impact on utilities and service systems. The majority of the cumulative projects identified in the DEIR are consistent with applicable General Plan land use designations and zoning designations and therefore have been considered in the projections used to determine appropriate sizing for utilities and service systems.

55. Threshold 4.20.1: The proposed project would not impair an adopted emergency response plan or emergency evacuation plan.

Impact: The proposed project would not impair an adopted emergency response plan or emergency evacuation plan. Impacts would be less than significant. (DEIR at 4.20-8 to

Lake Forest City CouncilJuly 7, 2026

Lake Forest City Council
July 7, 2026