Attachment G - Findings Statement of Overriding Considerations — Lancaster City Council, October 14, 2025

1 EXHIBIT “A”

FINDINGS AND FACTS IN SUPPORT OF FINDINGS / STATEMENT OF OVERRIDING CONSIDERATIONS FOR

THE WESTSIDE ANNEXATION AND NORTH LANCASTER INDUSTRIAL SPECIFIC PLAN

ENVIRONMENTAL IMPACT REPORT
(ANNEXATION NO. 24-002, GENERAL PLAN AMENDMENT NO. 24-002, PRE-ZONE NO. 24-001, SPECIFIC PLAN NO. 24-002)
(STATE CLEARINGHOUSE NO. 2024081372)

1. INTRODUCTION
The California Environmental Quality Act (CEQA), Public Resources Code Section 21081, and the State CEQA Guidelines, 14 Cal. Code of Regs. Section 15091 requires that a public agency consider the environmental impacts of a project before a project is approved and make specific findings. CEQA Guidelines Section 15091 provides:
(a) No public agency shall approve or carry out a project for which an EIR has been certified which identifies one or more significant environmental effects of the project unless the public agency makes one or more findings for each of those significant effect s, accompanied by a brief explanation of the rationale for each finding. The possible findings are:

1. Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect as identified in the Final EIR.

2. Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency.

3. Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, making infeasible the mitigation measures or alternatives identified in the Final EIR. (b) The findings required by subsection (a) shall be supported by substantial evidence in the record.
(c) The finding in substation (a)(2) shall not be made if the agency making the finding has concurrent jurisdiction with another agency to deal with identified feasible mitigation measures or alternatives. The finding in subsection (a)(3) shall describe the sp ecific reasons for rejecting identified mitigation measures and project alternatives. (d) When making the findings required in subsection (a)(1), the agency shall also adopt a program for reporting on and monitoring the changes which it has either required in the project or made a condition of approval to avoid or substantially lessen significant 2 environmental effects. These measures must be fully enforceable through permit conditions, agreements, or other measures.
(e) The public agency shall specify the location and custodian of the documents or other materials which constitute the record of the proceedings upon which its decision is based. (f) A statement made pursuant to Section 15093 does not substitute for the findings required by this section.

Having received, reviewed and considered the Revised Final Environmental Impact Report for the Westside Annexation and North Lancaster Industrial Specific Plan , dated October 2025 (“FEIR”), which includes but is not limited to the Draft Environmental Impact Report (“DEIR”), Responses to Comments on the DEIR, and all other information in the record of proceedings on this matter, the following Findings and Facts in Support of Findings (“Findings”) are hereby adopted by the City of Lancaster (“City”) in its capacity as the CEQA Lead Agency. These Findings set forth the City’s environmental basis for approval of Annexation (ANX) No. 24 -002, General Plan Amendment (GPA) No. 24-002, Pre-Zone No. 24-001, and Specific Plan (SP) No. 24-002 (“project”).

A. Format
These Findings have been organized into the following sections:
(1) Section 1 provides an introduction to these Findings. (2) Section 2 provides a summary of the project and overview of the discretionary actions required for approval of the project, and a statement of the project’s objectives.
(3) Section 3 provides a summary of the environmental review conducted in accordance with CEQA and the CEQA Guidelines by the City for the project and a summary of public participation in the environmental review for the project. (4) Section 4 sets forth findings regarding those environmental impacts which were determined as a result of the Notice of Preparation (NOP), and consideration of comments received during the NOP comment period either not to be relevant to the project or which were determined to clearly not manifest at levels which were deemed to be significant for consideration at the project-specific level. (5) Section 5 sets forth findings regarding significant or potentially significant environmental impacts identified in the FEIR which the City has determined are either not significant or can feasibly be mitigated to a less than significant through the imposition of mitigation measures. In order to ensure compliance and implementation, all of these measures will be included in the Mitigation Monitoring and Reporting Program (MMRP) for the project. (6) Section 6 sets forth findings regarding those significant or potentially significant environmental impacts identified in the FEIR which will or which may result from the project and which the City has determined cannot feasibly be mitigated to a less than significant level.
3 (7) Section 7 sets forth findings regarding alternatives to the Proposed Project. (8) Section 8 consists of a Statement of Overriding Considerations which sets forth the City’s reasons for finding that specific economic, legal, social, technological, and other considerations associated with the project outweigh the project’s potential unavoidable environmental effects.

B. Custodian and Location of Records
The documents and other materials that constitute the administrative record for the City’s actions related to the project are located at the City of Lancaster, Community Development Department, 44933 Fern Avenue, Lancaster, California, 93534. The Community Development Department is the custodian of the administrative record for the project.

2. PROJECT SUMMARY
A. Discretionary Actions
These Findings set forth the environmental basis for current discretionary actions to be undertaken by the City for the approval of the project. These actions include approval of ANX No. 24-002, GPA No. 24-002, Pre-Zone No. 24-001, and the North Lancaster Industrial Specific Plan (SP No. 24-002).

B. Project Location
The Antelope Valley is located in the northern portion of Los Angeles County, in the geographic sub-region of the western tip of the Mojave Desert and is situated between the Tehachapi, Sierra Pelona, and San Gabriel Mountains. On a regional basis, the area is accessible via State Route (SR) 14 and SR 138.

The project site encompasses approximately 7,153 acres of land in unincorporated Los Angeles County generally bound by Avenue B, Sierra Highway/ Edwards AFB, Avenue G, and 30th Street West.

Specifically, the 7,153-acre project site consists of the followin g Assessor Parcel Numbers (APNs): 3114 - 006-001, 002, 004, 005, 006, 008 thru 017, 901, 902, 903; 3114-007-008, 009, 010, 012, 013, 018 thru 027; 3114-008-002, 007 thru 011, 014 thru 021; 3114-009-001 thru 004, 006 thru 024; 3114-010-013, 026, 029, 036, 039, 040, 043, 045 thru 048, 053, 055, 060, 061; 3115- 005-002 thru 006, 008, 010, 011, 012; 3115- 006-001, 003 thru 009, 011 thru 032, 034 thru 043; 3115-007-053, 054; 3115-011-003, 005, 008 thru 024; 3115-012-003 thru 006, 008 thru 011, 013 thru 040; 3116-005-002 thru 006, 008 thru 014, 018 thru 021, 023, 024, 026, 027; 3116-006-064 thru 069, 900 thru 940; 3116-007-900 thru 904; 3116-008-013 thru 015, 017 thru 022, 024, 025, 026, 028, 029, 030, 032, 038, 040, 042 thru 045, 062, 063, 068 thru 072, 082 thru 085; 3116-009-001 thru 011, 014, 017, 019 thru 025, 027 thru 030, 033 thru 040; 3116-010-002 thru 007, 009, 010, 011, 013 thru 019, 022, 024, 025, 026, 031 thru 035, 038 ` 3117- 007-001, 005, 007, 011, 016, 019, 020, 027, 030, 032 thru 039; 3118-001-006, 007, 010 thru 013; 3118-002-002 thru 009, 011, 013, 022, 024, 027, 029 thru 032, 035, 036, 037, 040, 042 thru 045, 047 thru 056, 058 thru 063, 065, 066, 067, 070 thru 076; 3118-003-049, 051, 061 thru 064, 069, 088, 093, 094, 095, 104, 113 thru 117,121, 125 thru 128, 131 thru 134, 143 thru 147; 3118-015-003, 010, 011, 012; 3118-016-001 thru 010, 012 thru 017, 019 thru 022, 024 thru 027, 029 thru 036; 3118-017-003, 005 thru 010, 012 thru 019, 021 thru 031; 3118-018-001, 002, 004, 007 thru 021, 023 thru 028; 3145-005-035, 046, 051, 058, 061, 063, 073, 074, 076 thru 079, 081, 082, 085, 086, 087, 089, 090, 091, 800, 802, 901 thru 921; 3145- 009-001 thru 016, 800; 3145- 011-028, 033, 036, 038, 041, 048, 051 thru 054, 073, 074, 077, 078, 081, 082, 084, 085, 089, 091 thru 096, 099, 100, 105, 106, 108, 110, 113, 117, 119, 120, 124 thru 127, 129 thru 135, 801, 802, 906 thru 920; 3145-012-014, 4 026 thru 032, 034, 043, 044, 045, 048, 051, 052, 056 thru 059, 061 thru 064, 067, 068, 071 thru 075, 077 thru 080, 801; and 3145-040-801, 900 thru 921.

C. Project Description
The project involves two components: 1) annexation of the project site from unincorporated Los Angeles County into the City of Lancaster’s jurisdiction and 2) adoption of the North Lancaster Industrial Specific Plan (NLISP), which would allow up to 38.5 million square feet (sf) of industrial development.

Annexation
This component of the project involves the annexation of 7,153 acres into the City of Lancaster’s jurisdiction. As part of that process, a general plan amendment would be required to amend the General Plan Land Use Map to reflect annexation of the project site and application of the proposed land use designations, including Nonurban Residential (NU), Mixed Use (MU), Light Industry (LI), Public, Multi - family Residential (MR1), and Specific Plan (P). This includes pre -zoning the Specific Plan area as Specific Plan (SP) and the remainder of the annexation area as RR -2.5 (rural residential, minimum lot size 2.5 acres), Public (P), Mobile Home Park (MHP), Light Industrial (LI), and Mixed Use – Employment (MU-E).

The annexation component of the project has been analyzed at a programmatic level.

Specific Plan
The second component of the project consists of the adoption of the NLISP on a 1,860-acre subset of the annexation area. The Specific Plan is proposed to allow for a site -specific land use plan, development standards, design guidelines, infrastructure systems, and implementation strategies on which subsequent development activities would be implemented. The Specific Plan area would be divided into eight planning areas which would allow approximately 38.5 million sf of light and heavy industrial uses based on a 0.5 floor area ratio. The Specific Plan component of the project has been analyzed at a programmatic level.

Within Planning Areas 2, 4, 6 (east), 7 and 8, a total of approximately 11.3 million sf of industrial warehouse buildings and associated site improvements are proposed. This development is anticipated to be constructed over a 5 -year duration. The development of Planning Areas 2, 4, 6 (east), 7 and 8 within the Specific Plan component of the project has been analyzed at a project-level. However, no site specific developments have been proposed. It should be noted the future development within Planning Area 6 (west) was entitled by the County of Los Angeles in early 2024. The development within Planning Area 6 (west) is not considered as part of the proposed project; instead, it is identified as a cumulative project in the DEIR in Table 4-2, Cumulative Projects List.

D. Project Objectives
The following objectives have been established for the proposed project:
• Encourage development of various land use types in northern Lancaster, including residential, mixed-use, industrial, and public uses.
• Accommodate employment-generating land uses in Lancaster that provide jobs to local residents and contribute towards the City’s economic development. 5 • Implement City of Lancaster General Plan policies and objectives relevant to the project and proposed industrial development.
• Expand economic development and facilitate job creation in the City by establishing a new industrial development area.
• Attract new businesses to the City and thereby provide a more equal jobs-housing balance in the Antelope that reduces the need for members of the local workforce to commute outside the area for employment.
• Provide for uses that generate tax revenue for the City, including, but not limited to, increased property tax, in order to support the City’s ongoing municipal operations. • Accommodate new development in a phased, orderly manner that is coordinated with the provision of necessary infrastructure and public improvements. • Maximum development of Class A speculative warehouse industrial buildings in the project area that meet contemporary industry standards for operational design criteria, can accommodate a wide variety of users, and are economically competitive, to assist the City in competing economically on a domestic and international scale through the efficient and cost-effect movement of goods.
• Guide future light and heavy industrial development in northern Lancaster in a manner that is visually cohesive, environmentally sustainable, and compatible with existing and planned uses in the surrounding area.
• Ensure adequate public services and utility services are provided to accommodate future growth in northern Lancaster.

3. ENVIRONMENTAL REVIEW AND PUBLIC PARTICIPATION
The environmental review process for the proposed project is summarized as follows.

On September 3, 2024, the City issued a Notice of Preparation (NOP) for the proposed project in accordance with the requirements of CEQA and the CEQA Guidelines; publication of the NOP occurred in the Antelope Valley Press; was posted at City Hall/website; filed with the State Clearinghouse and the Los Angeles County Clerk; and sent to all property owners within the annexation area and 1,500 feet from the boundaries. The NOP was distributed for a 30-day public review period from September 3, 2024 through October 3, 2024. A public scoping meeting was held on September 26, 2024, at Lancaster City Hall located at 44933 Fern Avenue, Lancaster, California 93534, to solicit comments on the p roposed project. A copy of the NOP comments received can be found in Appendix 11.1 of the DEIR.

The DEIR was made available and distributed to agencies, interested organizations, individuals and property owners by the City for 45-day public review and comment period beginning on May 23, 2025 and ending on July 7, 2025. However, the public review period was extended an additional two weeks to July 21, 2025 due to a missing section in the DEIR to provide the public with additional time to review the complete DEIR. Comments received during the public review period for the DEIR were responded to in the Responses to Comments which was included in the FEIR, dated August 2025. The FEIR was distributed to all commenting parties and posted on the City’s website on August 8, 2025. 6 Three additional comment letters were received on August 15, 2025 and August 18, 2025, after the released of the FEIR. A revised FEIR was prepared to include responses to these comment letters. The revised FEIR, dated October 2025, was distributed to all c ommenting parties and posted on the City’s website on October 3, 2025.

The FEIR consists of the following components in addition to the DEIR:
• Section 1 – Introduction, which provides an introduction to the FEIR; • Section 2 – Responses to Comments, which provides copies of the written comments received on the DEIR and responses to those comments received in accordance with CEQA Guidelines Section 15132;
• Section 3 – Errata, which includes modifications to the DEIR text for consistency and clarification;
The Mitigation Monitoring and Reporting Program (separate document), includes the Mitigation Monitoring and Reporting (MMRP) table intended to provide verification that all applicable mitigation measures relative to significant environmental impacts are monitored and reported in compliance with Public Resources Code Section 21081.6.

The City Planning Commission considered the FEIR and project at its hearing on August 18, 2025 to make a recommendation to the City Council on the certification of the FEIR and adoption of ANX No. 24-002, GPA No. 24 -002, PZ No. 24 -001, and SP No. 24 -002. The City Council considered the FEIR and project at its hearings on October 14, 2025 and October 28, 2025.

4. ENVIRONMENTAL EFFECTS WHICH WERE DETERMINED TO NOT BE POTENTIALLY AFFECTED BY

THE PROJECT
During preparation of the DEIR, the City conducted an analysis of the proposed project’s effect on specific environmental topic areas included as part of the Environmental Checklist form presented in CEQA Guidelines Appendix G. Through the course of this evaluation, certain impacts were identified as “less than significant” or “no impact” due to the inability of a project of this scope t o yield such impacts or the absence of project characteristics producing effects of this type. These effects are not requi red to be included in the primary environmental analysis sections in the DEIR Section 5.0, Environmental Analysis. In accordance with CEQA Guidelines Section 15128, DEIR Section 8.0, Effects Found Not to Be Significant, includes a brief description of potential impacts found to be less than significant or result in no impact.

AESTHETICS: The following issue w as not analyzed in the Draft EIR for the reasons identified below:
• Substantially damage scenic resources, including but not limited to, trees, rock outcroppings, and historic buildings within a State scenic highway? According to the California Department of Transportation’s California State Scenic Highway System Map, there are no officially designated or eligible State scenic highways within or near the project site. The nearest eligible State scenic highways are segm ents of northbound SR- 7 14 and State Route 58 (SR -58); both eligible segments are located approximately 18 miles north of the project site.

The City of Lancaster’s Master Environmental Assessment identifies local roadways that serve as scenic routes, specifically SR-14, Avenue K (110th Street West to 90th Street West), Avenue M (60th Street West to 10th Street West), 60th Street West (Avenue K to Avenue M), and 90th Street West (Avenue K to the Kern County line). However, these scenic roadways are not designated as State scenic highways. Therefore, no impact would occur.

AGRICULTURE AND FORESTRY REESOURCES: The following issues were not analyzed in the Draft EIR for the reasons identified below:
• 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:

According to the California Department of Conservation’s California Important Farmland Finder, no land within the project site is currently mapped as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance. As such, no impacts would occur. • Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g)):

The County and City do not have existing zoning districts for forest land, timberland, or timberland production. Thus, project implementation would not result in the rezoning of forest land, timberland, or timberland zoned Timberland Production. No impact would occur. • Result in the loss of forest land or conversion of forest land to non-forest use:

BIOLOGICAL RESOURCES: The following issues were not analyzed in the Draft EIR for the reasons identified below:
• Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance:

The proposed project would not conflict with any local policies or ordinances, such as a tree preservation policy, protecting biological resources. The proposed project would be subject to the requirements of Ordinance No. 848, Biological Impact Fee, which requires payment of $770 per acre to offset the cumulative loss of biological resources in the Antelope Valley as a result of development (LMC Chapter 15.66). This fee is required for all projects occurring on previously undeveloped land regardless of the biological resources present and is utilized to enhance biological resources through education programs and the acquisition of property for conservation. Therefore, no impact would occur
8 • Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation plan:

There are no Habitat Conservation Plans, Natural Community Conservation Plans, or other approved local, regional, or State habitat conservation plans which are applicable to the project site. The West Mojave Coordinated Habitat Conservation Plan only applies to federal land, specifically land owned by the Bureau of Land Management. In conjunction with the Coordinated Management Plan, a Habitat Conservation (HCP) was proposed which would have applied to all private properties within the Plan Area. However, t his HCP was never approved by the California Department of Fish and Wildlife nor was it adopted by the local agencies (counties and cities) within the Plan Area. As such, there is no HCP that is applicable to the project site and no impacts would occur.

GEOLOGY AND SOILS: The following issues were not analyzed in the Draft EIR for the reasons identified below:
• 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:

Based on the California Geological Survey, there are no Alquist Priolo Fault zones within the project area. The nearest active fault is the San Andreas Fault, located approximately 10 miles to the south of the project site, south of the City of Palmdale. Therefore, there is no potential for surface rupture of a known active fault on the project site. No impact would occur. • Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving landslides:

Based on the California Geological Survey, the project site does not have the potential for earthquake induced landslides. Additionally, the geotechnical reports prepared for Planning Areas 2, 4, 6, 7, and 8 within the Specific Plan area confirmed that they are relatively flat and have a very low landslide hazard risk. Therefore, the project site does not have the potential for earthquake induced landslides. As such, project implementation would not expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving landslides. No impact would occur.

HAZARDS AND HAZARDOUS MATERIALS: The following issues were not analyzed in the Draft EIR for the reasons identified below:
• Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school:

The City is currently serviced by the Antelope Valley Union High School District, Eastside Union School District, Lancaster School District, and Westside Union School District. The closest schools to the project site are Desert View Elementary School located at 1555 Avenue H -10, approximately 1.75 miles to the south and Mariposa Elementary School at 737 Avenue H -6.

There are no schools within one-quarter mile of the project site. Therefore, no impact would occur.
9 • 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, would it create a significant hazard to the public or the environment:

The project site is not listed pursuant to California Government Code Section 65962.5; refer to Appendix 11.6, Hazardous Materials Documentation, of the DEIR. As such, no impacts would occur.

LAND USE AND PLANNING: The following issue was not analyzed in the Draft EIR for the reasons identified below:
• Physically divide an established community:

As there are no established communities within the project site, buildout of the annexation in accordance with the proposed pre-zones and buildout of the specific plan area would not physically divide an established community, and no impacts would occur.

MINERAL RESOURCES: The following issues were not analyzed in the Draft EIR for the reasons identified below:
• Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the State:

According to the California Department of Conservation, no active mining operations currently occur within the project area. Additionally, the project area is designated as Mineral Resource Zone 3 (MRZ -3), which is defined as areas containing mineral depos its the significance of which cannot be evaluated from available data. No impact would occur. • 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:

No locally -important mineral resource recovery sites are located within the project area.

Thus, no impact would occur.

POPULATION AND HOUSING: The following issue was not analyzed in the Draft EIR for the reasons identified below:
• Displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere:

Although there are existing rural residences, mobile home parks, and industrial uses located within the project site, the majority of the project site consists of vacant and undeveloped land. No existing structures, including the rural residences and mobile home parks, would be demolished as part of project implementation. The proposed annexation and NLISP do not propose any new development that could displace existing residences. No impact would occur.

10 WILDFIRE: The following issues were not analyzed in the Draft EIR for the reasons identified below:
• If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:
o Substantially impair an adopted emergency response plan or emergency evacuation plan;
o Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire;
o 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;
o 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:

According to the California Department of Forestry and Fire Protection’s Fire Hazard Severity Zone Viewer, the project site is not located in or near a State Responsibility Area (SRA) or Local Responsibility Area nor classified as a Very High Fire Hazard Severity Zone. The nearest area classified as a Very High Fire Hazard Severity Zone is approximately eight miles southwest of the site in the Rancho Vista neighborhood in the City of Palmdale. As such, no impact would occur.

5. FINDINGS ON POTENTIALLY SIGNIFICANT IMPACTS OF THE PROPOSED PROJECT IDENTIFIED IN

THE DEIR
Where as a result of the environmental analysis of the proposed project and the identification of project design features, compliance with existing laws, codes and statutes, and the identification of feasible mitigation measures, the following potentially significant impacts have been determined by the City to be reduced to a level of less than significant, the City has found in accordance with CEQA Section 21081(a)(1) and CEQA Guidelines Section 15091(a)(1) that “Changes or alterations have been required in, or incorporated into, the Proposed Project which mitigate or avoid the significant effects on the environment,” which is referred to herein as “Finding 1.” Where the potential impact can be reduced to less than significant solely through adherence to and implementation of project design features or standard conditions, these measures are considered “incorporated into the project” which mitigate or avoid the potentially significant effect, and in these situations, the City also will make “Finding 1” even though no mitigation measures are required, but will find that the potential impact has been reduced to Less Than Significant through either project design features incorporated into the project or adherence to standard conditions.

Where the City has determined pursuant to CEQA Section 21081(a)(2) and CEQA Guidelines Section 15091(a)(2) that “Those changes or alterations are within the responsibility and jurisdiction of another public agency and have been, or can and should be, adopt ed by that other agency, the City’s finding is referred to herein as “Finding 2.”
11 Where, as a result of the environmental analysis of the proposed project, the City has determined that either (1) even with the identified of project design features, compliance with existing laws, codes and statutes, and/or the identification of feasible mitigation measures, potentially significant impacts cannot be reduced to a level of less than significant, or (2) no feasible mitigation measures or alternatives are available to mitigate the potentially significant impact, the City has found in accordanc e with CEQA Section 21081(a)(3) and CEQA Guidelines Section 15091(a)(3) that “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 work,” referred to herein as “Finding 3.” In making these findings, the City has relied upon the environmental conclusions reached by the experts that prepared the FEIR, including the information, analysis and conclusions in the technical reports prepared and made a part of the FEIR. Although contrary opinions may have been presented in comments submitted on the DEIR and FEIR, the City has weighed those comments against the underlying data, analysis and conclusions in the FEIR, and has reached its conclusions accordingly.

The following potentially significant environmental impacts were analyzed in the DEIR. • Land Use and Planning
• Aesthetics
• Agriculture and Forestry Resources
• Biological Resources
• Tribal and Cultural Resources
• Geology and Soils
• Hydrology and Water Quality
• Hazards and Hazardous Materials
• Population and Housing
• Public Services and Recreation
• Utilities and Service Systems
• Transportation
• Air Quality
• Greenhouse Gas Emissions
• Energy
• Noise
It should be acknowledged that, as the proposed project involves two components (annexation and adoption of the Specific Plan). These two components were analyzed separately under separate headings in majority of the analyses within the DEIR; where impacts are quantifiable and project-specific details are available (e.g., VMT, construction and operational air emissions, etc.), the S pecific Plan component may specifically identify projects/Planning Areas with these project -specific details. However, no site specific development applications have been submitted. Nonetheless, for the purpose of making Findings for this project, the following summaries of each potentially significant environmental impact have been reorganized under a three -level analytical framework: Annexation Analysis, Specific Plan Analysis, and Planning Areas 2, 4, 6 (east), 7, and 8 Analysis. In some instances, the analysis for Planning Areas 2, 4, 6 (east), 7 and 8 is included under the Specific Plan Analysis heading. It should also be noted that due to the nature of cumulative analysis, the summaries for each cumulative impact Findings only have one level of 12 analysis that cover the entire project, including the annexation and the adoption of the Specific Plan (inclusive of proposed industrial development within Planning Areas 2, 4, 6 (east), 7, and 8).

A. LAND USE AND PLANNING
The thresholds of significance for land use and planning impacts are listed in Section 5.1 , Land Use and Planning on pages 5.1-7 and 5.1-8 of the DEIR. Impact analyses were detailed on pages 5.1-8 through 5.1-

46. Potential Impact: The proposed project would not result in a significant impact on land use plans, policies, regulations, or best practices for warehouse projects.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
As discussed in the DEIR, the proposed annexation and NLISP would be consistent with the majority of relevant City of Lancaster General Plan (General Plan), Lancaster Municipal Code (LMC), Southern California Association of Governments (SCAG) 2024 -2050 Regional Transportation Plan/Sustainable Communities Strategy (2024-2050 RTP/SCS), and General William J. Fox Airfield Land Use Compatibility Plan (ALUCP) policies and regulations, as well as the California Attorney General Office’s Bureau of Environmental Justice’s (Bureau’s) Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act (Best Practices for Warehouse Projects). As such, impacts would be less than significant.

Specific Plan Analysis
The annexation analysis provided above is also applicable to the specific plan analysis including Planning Areas 2, 4, 6 (east), 7 and 8.

Potential Impact: The proposed project, in conjunction with cumulative development, would not result in cumulatively considerable impact s on land use plans, policies , regulations, or best practices for warehouse projects.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

All cumulative development projects would be required to undergo separate environmental reviews to determine potential conflicts with applicable land use policies, plans, and regulations. As part of the review process, each cumulative project would be required to demonstrate compliance with the provisions of the applicable land use designations and zoning districts. As the proposed annexation and NLISP would be consistent with the majority of relevant General Plan, Zoning Code, 2024-2050 RTP/SCS, and ALUCP policies and regulations, as well as the Bureau’s Best Practices for Warehouse Projects, the proposed project would not contribute to a cumulatively considerable impact to land use and planning.

Impacts would be less than significant.
13 B. AESTHETICS
The thresholds of significance for aesthetic impacts are listed in Section 5.2, Aesthetics, on page 5.2-4 of the DEIR. Impact analyses were detailed on pages 5.2-5 through 5.2-13.

Potential Impact: The proposed project could result in a significant impact on a scenic vista.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
Public views of the annexation area are afforded along scenic route State Route 14 (SR -14), which transects the annexation area (including the Specific Plan area) in a north -south direction. While future development within the annexation area (including th e Specific Plan area) could have the potential to obscure distant views of the desert for motorists along SR -14, future development would not exceed building heights currently anticipated by buildout of the General Plan. Northern and southern views of the mountains would not substantially change upon compliance with required minimum setbacks from street frontages. With adherence to the City’s zoning regulations pertaining to setbacks and building heights along street frontages, future development within the annexation area (including the Specific Plan area) is not anticipated to substantially impede existing public views along SR-14 to scenic resources (the surrounding mountains and desert landscape). Therefore, view impacts to scenic corridors (i.e., SR -14) would be less than significant.

Specific Plan Analysis
The annexation analysis provided above is also applicable to the specific plan analysis, including Planning Areas 2, 4, 6 (east), 7, and 8.

Potential Impact: The proposed project could degrade the existing visual character and scenic quality of the project site.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

The project site primarily consists of relatively level, vacant, and undeveloped land in a rural, non -urban area. However, following the proposed annexation into the City of Lancaster, the project site would be considered urban per CEQA Guidelines Section 21071, Urbanized Area.

Annexation Analysis
As detailed in the DEIR, the proposed project would result in less than significant impacts pertaining to the degradation of visual character and quality. Planned and future development within the annexation area would be required to comply with the develo pment standards of the LMC requirements, as well as the regulations and design guidelines enforced through the NLISP (for future development in the Specific Plan area). The proposed project would not result in significant with respect to visual character. As such, the proposed project would not significantly contribute to cumulative impacts to the degradation of scenic 14 quality with compliance with the LMC requirements, as well as implementation of the proposed NLISP.

Therefore, impacts would be less than significant.

Specific Plan Analysis
The annexation analysis provided above is also applicable to the specific plan analysis, including Planning Areas 2, 4, 6 (east), 7, and 8.

Potential Impact: The proposed project could result in significant light and glare impacts.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
The proposed project would be required to comply with all applicable LMC light and glare regulations, as well as those supplemented through the NLISP. With compliance with NLISP and LMC regulations governing setbacks and building materials as well as fixture types and orientation, potential light and glare impacts would be less than significant. Therefore, the project would not result in cumulatively considerable light and glare and impacts, and impacts would be less than significant.

Specific Plan Analysis
The annexation analysis provided above is also applicable to the specific plan analysis, including Planning Areas 2, 4, 6 (east), 7, and 8.

Potential Impact: The proposed project, in conjunction with cumulative development projects, could result in significant cumulative aesthetic impacts.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Scenic Vistas
Future cumulative projects could result in adverse impacts to scenic vistas in the City. However, cumulative projects would be required to undergo project-specific environmental review under CEQA to evaluate project-level impacts to scenic vistas on a project-by-project basis. Consistency with the General Plan goals and policies, as well as LMC requirements would reduce such overall cumulative impacts.

Future development projects implemented in accordance with the proposed annexation area’s pre-zone and NLISP are not anticipated to impact scenic vistas and impacts to scenic corridors would be less than significant. As such, the proposed project would not contribute to a cumulatively considerable impact and impacts in this regard would be less than significant.

Visual Character/Quality
Overall, as development occurs within the City, the rural desert landscape would change, consistent with the City’s General Plan goals and policies, as well as LMC regulations governing density, building heights, 15 setbacks, and landscaping requirements. Development would be required to undergo project specific environmental review under CEQA to evaluate project-level impacts as well as site and architectural plan review on a project-by-project basis. As part of the City’s plan review process, the City would review each cumulative project to ensure that development in non -urban areas do not degrade the existing visual character or quality.

The proposed project would result in less than significant impacts pertaining to the degradation of visual character and quality. Planned and future development within the annexation area would be required to comply with the development standards of the LMC , as well as the regulations and design guidelines enforced through the NLISP (for future development in the Specific Plan area). T he proposed project would not result in significant impacts with respect to visual character and would not significantly contribute to cumulative impacts to the degradation of scenic quality . Therefore, impacts would be less than significant.

Light/Glare
Development of cumulative projects could result in increased light and glare in the City during construction and operational activities. However, all cumulative development would be required to undergo separate environmental review on a project -by-project basis for light and glare considerations.

All cumulative projects would be required to comply with the LMC outdoor lighting requirements, which would reduce overall cumulative impacts in this regard.

The proposed project would comply with all applicable LMC light and glare regulations, as well as those supplemented through the NLISP. With compliance with NLISP and LMC regulations governing setbacks and building materials as well as fixture types and orientation, potential light and glare impacts would be less than significant. Therefore, the project would not result in cumulatively considerable light and glare and impacts, and impacts would be less than significant.

C. AGRICULTURE AND FORESTRY RESOURCES
The thresholds of significance for agriculture and forestry resource impacts are listed on pages 5.3-3 and

5.3-4 of the DEIR. Impact analyses were detailed on pages 5.3-4 through 5.3-6.

Potential Impact: The proposed project could potentially conflict with existing zoning for agricultural use or a Williamson Act contract or involve other changes in the existing environment, which, due to their location or nature, could result in the conversion of farmland, to non -agricultural use or conversion of forest land to non-forest use.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
According to the California Department of Conservation California Williamson Act Enrollment Finder, the annexation area does not include any farmland currently under a Williamson Act contract. Additionally, there are no Williamson Act contracts in Los Ange les County. Thus, no impacts would occur related to lands under Williamson Act contracts. Additionally, as detailed in the DEIR, the project site (annexation area and Specific Plan area) includes areas that are currently zoned by the County as A-2-2, R-A, MXD-RU, 16 and M-1 which allow agricultural uses. The project would convert some of these agriculturally zoned areas to non -agricultural zones. Specifically, the project would pre -zone areas within the annexation area currently zoned A-2-2 and R-A to RR-2.5. However, the RR-2.5 zone would continue to permit agricultural use (e.g., light agricultural uses as an accessory use and commercial crop production). Thus, less than significant impacts would occur.

Specific Plan Analysis
The annexation analysis provided above is also applicable to the specific plan analysis, including Planning Areas 2, 4, 6 (east), 7 and 8.

Potential Impact: The proposed project, in conjunction with cumulative development, would not result in cumulatively considerable conflicts with existing zoning for agricultural use or a Williamson Act contract or involve other changes in the existing environment, which, due to their location or nature, could result in the conversion of farmland, to non-agricultural use or conversion of forest land to non-forest use.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Cumulative projects listed in Table 4 -2 could result in a significant impact to agricultural resources by conflicting with existing Williamson Act contracts and through the conversion of land zoned for agricultural use to non -agricultural use. However, given that zoning is site specific, future cumulative projects would be required to undergo separate environmental review to evaluate site- specific impacts regarding the conversion of land under the Williamson Act and/or zoned for agricultural use to nonagricultural use and mitigate such impacts, if any, as needed.

The project site does not include any farmland currently under a Williamson Act contract. Thus, no cumulative impacts would occur related to lands under Williamson Act contracts.

As discussed, the project site (annexation area and Specific Plan area) includes areas that are currently zoned by the County as A -2-2, R-A, MXD-RU, and M -1 which allow agricultural uses. The project would convert some of these agriculturally zoned areas to non-agricultural zones. Specifically, the project would pre-zone areas within the annexation area currently zoned A-2-2 and R-A to RR-2.5 However, the RR-2.5 zone would continue to permit agricultural use (e.g., light agricultural uses as an accessory us e and commercial crop production).

D. BIOLOGICAL RESOURCES
The thresholds of significance for biological resource impacts are listed in Section 5.4, Biological Resources, on page 5.4-21 of the DEIR. Impact analyses were detailed on pages 5.4-22 through 5.4-31.

Potential Impact: The proposed project could potentially 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 Game or U.S. Fish and Wildlife Service.

Finding: The City hereby makes Finding 1.
17 Facts in Support of Findings:

Annexation Analysis
Several non -listed special- status plant and wildlife species are expected to occur or have moderate potential to occur within the annexation area. Species currently listed and protected under the Federal Endangered Species Act (FESA) and/or California Endangered Species Act (CESA) are not expected to occur within the project site; however, burrowing owl (Athene cunicularia), a Candidate for listing under CESA, is likely to occur on -site, while western Joshua tree ( Yucca brevifolia), also a Candidate for State listing, has a moderate potential to occur within the project site. Furthermore, there are several trees within the project site that could be occupied by birds protected under the Migratory Bird Treaty Act (MBTA).

Therefore, future development in accor dance with the proposed land use designations and pre -zones within the project site could result in direct and indirect impacts to special- status species, including nesting birds protected under the MBTA and California Fish and Game Code (CFGC), resulting in significant impacts. Overall, with implementation of Mitigation Measure BIO -1 (rare plant surveys and Incidental Take Permit[s] for western Joshua tree), Mitigation Measure BIO- 2 (pre -construction burrowing owl surveys), and Mitigation Measure BIO -3 (pr e-construction nesting bird surveys), project impacts to special-status species would be less than significant.

Specific Plan Analysis
The annexation analysis provided above is also applicable to the specific plan analysis including Planning Areas 2, 4, 6 (east), 7, and 8.

Potential Impact: The proposed project could have an substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or U.S. Fish and Wildlife Service.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
According to the Biological Resources Assessment, the annexation area (including the Specific Plan area) consists primarily of desert scrub habitats dominated by saltbush/shadscale/allscale (Atriplex spp.) scrub, areas disturbed by anthropogenic activities, and developed lands consisting of paved roadways and structures. No sensitive native vegetation communities were identified within the annexation area during the surveys conducted in 2023 across Planning Areas 2, 4, and 6 through 8, and none were identified during reviews of aerial photography and California Natural Diversity Database (CNDDB) records for the project site. As a result, no special- status vegetation communities are expected to occur within the annexation area. No impact would occur.

Specific Plan Analysis
The annexation analysis provided above is also applicable to the Specific Plan area, including Planning Areas 2, 4, 6 (east), 7, and 8.
18 Potential Impact: The project could have a substantial adverse effect on federally protected wetlands as defined by Clean Water Act (CWA) Section 404 (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
The reconnaissance level field work and literature reviews indicate that one primary drainage feature, Amargosa Creek, is the only notable water conveyance signature within the annexation area. Other unnamed and isolated features do not appear to exhibit a well-defined ordinary high watermark, obvious bed, bank or channel, continuous or recurrent soil saturation, and lack the hydrological or vegetative criteria required for State or federal protection as wetlands or waters. Nonetheless, a formal delineation of waters of the U.S. (WOTUS) and waters of the State (WOTS) must be completed prior to ground disturbance, to determine the final regulatory status of drainage signatures and the Lancaster Water Reclamation Plant.

While these features are anticipated to not fall under jurisdiction of the U.S. Army Corps of Engineers (USACE), filling, dredging, or otherwise altering such features may result in impacts to signatures falling under State agency jurisdiction, and may require a Waste Discharge Requirement from the Regional Water Quality Control Board (RWQCB), pursuant to the California Porter-Cologne Water Quality Control Act, and a Lake or Streambed Alteration Agreement (LSAA) from CDFW, pursuant to Section 1600 et seq. o f the CFGC.

The presence and extent of regulatory agency jurisdiction would be required to be identified by completing a jurisdictional determination, and if potentially regulated jurisdictional features are determined present, a formal field delineation following the most recent agency-approved methods. The formal jurisdictional delineation would be required to determine the extent of agency jurisdiction and potential impacts to regulated features. Furthermore, as required by Mitigation Measure BIO -4, if these signatures are disturbed, permits or discretionary approval may need to be obtained from regulatory agencies: USACE, which regulates discharge of dredged or fill material into WOTUS pursuant to the Section 404 of the CWA and Section 10 of the Rivers and Harbors Act; RWQCB, which regulates discharges to surface waters pursuant to Section 401 of the CWA and Section 13263 of the California Porter- Cologne Water Quality Control Act; and CDFW, which regulates alterations to streambed and associated riparian habitat unde r Section 1600 et seq. of the CFGC. Mitigation Measure BIO -4 would also require compensatory mitigation for impacts to be determined during the formal notification and/or application processes. With implementation of Mitigation Measure BIO-4, impacts to jurisdictional features identified during a formal jurisdictional delineation of WOTS and WOTUS would be less than significant.

Specific Plan Analysis
The annexation analysis provided above is also applicable to the specific plan analysis.

Planning Areas 2, 4, 6 (east), 7, and 8 Analysis
The annexation analysis provided above is also applicable to the Planning Areas 2, 4, 6 (east), 7, and 8 analysis.
19 Potential Impact: The project could interfere substantially with the movement of native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors or impede the use of wildlife nursery sites.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
No recognized wildlife movement corridor or linkage coincide with the annexation area. The annexation area does not provide the necessary conditions to function as a wildlife corridor, nor does the annexation area support riparian dependent species. The annexation area is situated within the Antelope Valley region of the western Mojave Desert and is dominated by upland desert scrub habitat. While undeveloped open desert exists in the broader landscape, multiple barriers significantly reduce the suitability of the annexation area as a wildlife movement corridor, including:
• The presence of Fox Field Airport and commercial development (two miles west); • Major highways and paved roadways such as SR -14, SR-138, Sierra Highway, and local avenues; and
• Existing development, fence lines, and light and noise disturbances from vehicular traffic.

While Amargosa Creek transects the southern portion of the annexation area, this feature is ephemeral and does not contain a riparian corridor or vegetation structure that would facilitate significant wildlife movement. As a result, Amargosa Creek is not expected to function as a key movement corridor, nor does the annexation area provide a critical linkage between larger habitat areas. In summary, the annexation area does not function as a significant wildlife corridor or habitat linkage due to its upland nature, lack of riparian connectivity, and physical barriers such as roads, airports, and development. While some localized species may move through the annexation area, the broader Antelope Valley region contains more suitable open-space linkages, including the nearby Antelope Valley SEA, which provides a far greater role in supporting regional wildlife movement. As a result, the annexation area does not serve as a significant or recognized wildlife movement corridor. Additionally, implementation of Mitigation Measures BIO -1 through BIO-4 would further reduce less than significant impacts to wildlife movement. Overall, impacts to wildlife movement would be less than significant.

Specific Plan Analysis
The annexation analysis provided above for is also applicable to the specific plan analysis.

Planning Areas 2, 4, 6 (east), 7, and 8 Analysis
The annexation analysis provided above is also applicable to the Planning Areas 2, 4, 6 (east), 7, and 8 analysis.

Potential Impact: The proposed project, in conjunction with cumulative development, could result in cumulatively considerable impacts to candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife service.
20 Finding: The City hereby makes Finding 1.

Facts in Support of Findings: Cumulative projects would be required to undergo project -specific environmental review under CEQA and the lead agency’s discretionary review process to determine potential impacts to sensitive special- status species and any required mitigation. Future env ironmental review for related projects may require preparation of a biological resources assessment and focused protocol surveys to evaluate project -specific impacts to special-status species and identify required mitigation.

The proposed annexation and NLISP (including Planning Areas 2, 4, 6 [east], 7, and 8) could impact special- status species. However, with the implementation of Mitigation Measure BIO -1 (rare plant surveys and Incidental Take Permit[s] for western Joshua tree), Mitigation Measure BIO-2 (pre-construction burrowing owl surveys), and Mitigation Measure BIO-3 (pre-construction nesting bird clearance surveys), the project would not result in cumulatively considerable impacts to sensitive special- status species. Cu mulative impacts would be less than significant.

Potential Impact: The project, in conjunction with cumulative projects, would not result in cumulatively considerable impacts to federally protected wetlands as defined by section 404 of the CWA (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Similar to future development within the project site, cumulative projects would be required to undergo project-specific environmental review under CEQA and the lead agency’s discretionary review process to determine potential impacts to State or federally protected wetlands and any required mitigation. Future environmental review for related projects may require preparation of a jurisdictional delineation to evaluate project -specific impacts to State or federally protected wetlands and identify any require d mitigation.

The proposed annexation and NLISP (including Planning Areas 2, 4, 6 [east], 7, and 8) could impact jurisdictional resources. However, the presence and extent of regulatory agency jurisdiction would be required to be identified by completing a jurisdictiona l determination, and if potentially regulated jurisdictional features are determined present, a formal field delineation. As required by Mitigation Measure BIO -4, if these signatures are disturbed, permits or discretionary approval may need to be obtained from regulatory agencies. Mitigation Measure BIO -4 would also require compensatory mitigation for impacts to be determined during the formal notification and/or application processes. Thus, with implementation of Mitigation Measure BIO -4, development associated with the project would not have a cumulatively considerable adverse effect on State or federally protected wetlands. Cumulative impacts would be less than significant.

Potential Impact: The project, in conjunction with cumulative projects, would not result in cumulatively considerable impacts to the movement of native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of wildlife nursery sites.

Finding: The City hereby makes Finding 1.
21 Facts in Support of Findings:

Cumulative projects listed in Table 4-2 are subject to CEQA and would be required to comply with existing requirements related to nesting migratory native birds, including the MBTA. These projects, if located within the Antelope Valley SEA, mapped wildlife corridor, wildlife linkage area, or other Statewide or regional wildlife connectivity overlay, would be required to prepare a biological resources assessment and focused protocol surveys to evaluate project-specific impacts regarding the movement of native resident or migratory fish or wildlife species.

The proposed annexation and NLISP (including Planning Areas 2, 4, 6 [east], 7, and 8) would not result in potential impacts to the movement of native resident or migratory fish or wildlife species. Further, implementation of Mitigation Measure BIO-1 (rare plant surveys and Incidental Take Permit[s] for western Joshua tree), Mitigation Measure BIO -2 (pre-construction burrowing owl surveys), Mitigation Measure BIO-3 (pre-construction nesting bird clearance surveys), and Mitigation Measure BIO -4 (compensatory mitigation for impacts to WOTS and/or WOTUS) would further reduce less than significant project impacts. Thus, the project would not result in cumulatively considerable impacts to the movement of native resident or migratory fish or wildlife species. Cumulative impacts would be less than significant.

E. TRIBAL AND CULTURAL RESOURCES
The thresholds of significance for tribal and cultural resource impacts are listed in Section 5.5, Tribal and Cultural Resources, on page 5.5 -19 through 5.5-20 of the DEIR. Impact analyses were detailed on pages

5.5-20 through 5. 5-32.

Potential Impact: The project could cause significant impacts to historical/and or archaeological resources.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings: The Cultural and Paleontological Resources Assessment, Lancaster Westside Annexation and Specific Plan Project, Los Angeles County, California (Cultural and Paleo Report), prepared by Michael Baker and dated November 2024, identified 59 archaeological sites and six assessor parcels with documented historic-aged buildings located within the project site; a complete list of these resources and sites is included in Table 8, Archeological Resources Within the Project Site , and Tabl e 9, Assessor Parcels With Documented Historic-Aged Structures Within the Project Site, of the Cultural Paleo Report.

Annexation Analysis
DEIR Table 5.5-1, Potential Annexation Area Cultural Resources, lists previously identified archaeological sites and assessor parcels located within the annexation area that have not been evaluated for inclusion in the National Register or California Register. All other previously identified archaeological resources and assessor parcels located within the annexation area were evaluated for inclusion in the National Register or California Register and were recommended ineligible.

Future development projects within the annexation area would be required to undergo project -level environmental review under CEQA on a case-by-case basis and comply with existing applicable State and local laws related to cultural resources. Additionally, any development projects that have the potential to impact the resources listed in DEIR Table 5.5-1 would be required to evaluate those resources for inclusion in the California Register and/or National Register.
22 Based on the annexation area’s sensitivity for historic archaeological resources, a Phase I Cultural Resources Study would be required for each future project that is subject to CEQA review to identify potential unknown resources that may be impacted by pr oject implementation within areas not previously subjected to pedestrian surveys (Mitigation Measure CUL -1). Additionally, prior to ground- disturbing activities, all future development projects that are subject to CEQA review would be required to implement Mitigation Measure CUL -2, which includes preparation of an Archaeological Resources Monitoring and Discovery Plan (ARMDP). Following implementation of Mitigation Measures CUL -1 and CUL-2, and in the event that no archaeological material is uncovered durin g construction, impacts to cultural resources would be less than significant. If archaeological material is uncovered in the course of ground-disturbing activities, work shall be temporarily halted in the vicinity of the find (within a 60 -foot buffer) and the project proponent shall retain a qualified professional archaeologist meeting the Secretary of the Interior’s Professional Qualification Standards for archaeology to evaluate the significance of the find and recommend appropriate treatment for the resource (Mitigation Measure CUL -3). Thus, in the event that archaeological material is uncovered during construction, implementation of Mitigation Measure CUL-3 would ensure impacts to cultural resources remain less than significant.

Specific Plan Analysis
The programmatic analysis provided above for the Annexation Analysis is also applicable to the Specific Plan area. There are previously identified archaeological resources and assessor parcels located within other portions of the Specific Plan area that have not been evaluated for inclusion in the National Register or California Register, and are presented in DEIR Table 5.5 -2, Potential Specific Plan Area Cultural Resources. Any future development projects that have the potential to impact the resources listed in DEIR Table 5.5-2 would be required to evaluate those resources for inclusion in the California Register and/or National Register.

Further, similar to the annexation area, development in Planning Areas 1, 3, and 5 (where previous cultural intensive surveys have not been conducted) would require preparation of a Phase I cultural resources study prepared by a qualified archaeologist and /or architectural historian meeting the Secretary of the Interior’s Professional Qualification Standards for archaeology, architectural history, and/or history (Mitigation Measure CUL -1). Additionally, prior to ground -disturbing activities, all future deve lopment projects within the Specific Plan area would be required to implement Mitigation Measure CUL -2, which includes preparation of an ARMDP. If archaeological material is uncovered in the course of ground - disturbing activities, work shall be temporarily halted in the vicinity of the find (within a 60 -foot buffer) and the project proponent shall retain a qualified professional archaeologist meeting the Secretary of the Interior’s Professional Qualification Standards for archaeology to evaluate the significance of the find and recommend appropriate treatment for the resource (Mitigation Measure CUL-3). In conclusion, following implementation of Mitigation Measures CUL-1 through CUL-5, impacts to cultural resources would be less than significant.

Planning Areas 2, 4, 6 (east), 7, and 8 Analysis
The Cultural and Paleo Report included an intensive analysis of Planning Areas 2, 4, 6 (east), 7, and 8 within the Specific Plan area. Overall, 35 historic sites, 11 prehistoric sites, and 1 multicomponent site were identified within these Planning Areas. Of these, 43 resources were evaluated and recommended not eligible for inclusion in the California Register; refer to Cultural and Paleo Report Table 8. The four remaining resources (AVLC3-P-001, AVLC3-P-005, AVLC3-P-009, and AVLC3-P-010) were analyzed in detail on the DEIR.
23 Ground-disturbing activities in Planning Areas 7 and 8 of the Specific Plan area have the potential to impact resources AVLC3-P-001, AVLC3-P-005, AVLC3-P-009, and AVLC3-P-010, all of which have yet to be confirmed for eligibility in the California Register. Therefore, prior to project ground -disturbing activities specifically within Planning Areas 7 and 8, Mitigation Measure CUL-4 would be implemented, which would require preparation of a Phase II archaeological testing plan in consultation with interested Native American tribes in order to determine whether the resource is eligible for inclusion in the California Register. If it is determined that the resource is eligible for inclusion in the California Register, then a Phase III data recovery plan shall be devised and implemented in consultation with interested Native American tribes (Mitigation Measure CUL -5). Following implementation of Mitigation Measures CUL -4 and CUL-5, impacts to resources AVLC3 -P-001, AVLC3-P-005, AVLC3-P-009, and AVLC3-P- 010 would b e reduced to less than significant levels.

Potential Impact: The project could cause a significant impact to tribal cultural resources.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
Future development within the annexation area would be required to undergo project -specific environmental review under CEQA and the City’s discretionary review process to determine potential impacts to tribal cultural resources, which may include consultation with Native American tribes pursuant to AB 52. Prior to any ground -disturbing activities, future development projects would be required to complete a Phase I Cultural Resources Study, including a pedestrian survey with a Fernandeño Tataviam Band of Mission Indians (FTBMI) Tribal monitor. (Mitigation Measure CUL -1). If subsequent mitigation is required, consultation with the FTBMI would be required per Mitigation Measure CUL -6 before further ground-disturbing activities could proceed.

While it is not anticipated that human remains, including those interred outside of formal cemeteries, would be encountered during construction, prior to any ground -disturbing activities in the annexation area, Mitigation Measure CUL-7 would be required to implement a Treatment and Disposition Plan (TDP) in consultation with the FTBMI regarding the process for in-field treatment of inadvertent discoveries and the disposition of inadvertently discovered non-funerary resources. Additionally, per Mitigation Measure CUL-8, all mitigation measures which involve coordination with or involvement by FTBMI would include the Yuhaaviatam of San Manuel Nation (YSMN) upon finalized discussion between YSMN and the City. As such, Mitigation Measure CUL -8 may include tribal monitoring, review and oversight of Phase II Evaluations, review of individual site plans to finalize tribal requirements, and worker education by Tribal entities prior to the start of construction activities on individual sites. Further, if, during ground-disturbing activities, human remains are found, those remains would require proper treatment, in accordance with applicable laws. Upon adherence to existing laws and implementation of Mitigation Measures CUL-1, CUL- 6, CUL-7, and CUL-8, potential impacts to tribal cultural resources would be less than significant.

Specific Plan Analysis
Prior to any ground-disturbing activities in Planning Areas 1, 3, and 5, future development projects would be required to complete a Phase I Cultural Resources Study, including a pedestrian survey with a FTBMI Tribal monitor (Mitigation Measure CUL -1). If subsequent mitigation is required, consultation with the 24 FTBMI would be required per Mitigation Measure CUL-6 before further ground-disturbing activities could proceed.

Additionally, prior to any ground- disturbing activities in Planning Areas 1, 3, 5, 7, and 8, Mitigation Measure CUL -7 would be required to implement a TDP in consultation with the FTBMI regarding the process for in-field treatment of inadvertent discoveries and the disposition of inadvertently discovered non-funerary resources. Mitigation Measure CUL-8 would require all mitigation measures which involve coordination with or involvement by FTBMI to include the YSMN.

Further, if, during ground -disturbing activities, human remains are found, those remains would require proper treatment, in accordance with applicable laws. Upon adherence to existing laws and implementation of Mitigation Measures CUL -1 and CUL -6 through C UL-8, potential impacts to tribal cultural resources and human remains would be less than significant.

Planning Areas 2, 4, 6 (east), 7, and 8 Analysis
Given the cultural sensitivity of the areas, proposed development within Planning Areas 7 and 8 of the NLISP would be required to complete a Phase II archaeological testing plan in consultation with the FTBMI per Mitigation Measure CUL-4. If subsequent mitigation is required, consultation with the FTBMI would be required per Mitigation Measures CUL -5 and CUL-6 before further ground- disturbing activities could proceed. Further, if, during ground-disturbing activities, human remains are found, those remains would require proper treatment, in accordance with applicable laws. Upon adherence to existing laws and implementation of Mitigation Measures CUL -4 through CUL -6, potential impacts to tribal cultural resources and human remains would be less than significant.

Potential Impact: Project implementation, in conjunction with other cumulative projects, could result in cumulatively considerable impacts to historical and archaeological resources.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Cumulative projects developed in the vicinity of the project site have the potential to result in cumulatively considerable impacts to historical and archaeological resources. However, impacts to cultural resources are generally site-specific. Similar to the proposed project, related cumulative projects would be required to undergo project-specific environmental review under CEQA and the lead agency’s discretionary review process to determine potential impacts based on project-specific ground-disturbing activities.

As summarized above, the project would result in less than significant impacts and thus, would not contribute to a cumulatively considerable impact. Cumulative impacts would be less than significant.

Potential Impact: Project implementation, in conjunction with other cumulative projects, could result in cumulatively considerable impacts to a tribal cultural resource.

Finding: The City hereby makes Finding 1.

25 Facts in Support of Findings:

Similar to the proposed project, all cumulative development projects would require separate environmental review under CEQA, which may include consultation with Native American tribes pursuant to AB 52 and/or SB 18.

Project implementation would be required to comply with applicable mitigation measures to reduce potential adverse impacts to previously undiscovered tribal cultural resources. Thus, the project would not contribute to a cumulatively considerable impact. Cumulative impacts would be less than significant.

F. GEOLOGY AND SOILS
The thresholds of significance for geology and soils impacts are listed in Section 5.6, Geology and Soils, on page 5.6-15 of the DEIR. Impact analyses were detailed on pages 5.6-16 through 5.6-26.

Potential Impact: Project implementation could expose people and structures to substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
The proposed land use designations and pre-zones within the annexation area would accommodate both residential and nonresidential development. All future development proposed in the annexation area as well as proposed developments within the Specific Plan area, including industrial warehouse buildings in Planning Areas 2, 4, 6, 7, and 8, would be required to comply with existing regulatory requirements, including the Earthquake Hazards Reduction Act, Seismic Hazard Mapping Act, the California Building Standards Code (CBSC), LMC Chapter 15.08, Building Code , as well as the seismic design considerations provided in project -specific geotechnical reports, if applicable. Future projects would also require environmental review under CEQA to evaluate project -specific impacts and mitigation measures would be implemented, as needed. Further, development within the Specific Plan area would not include any residences or habitable structures. As such, buildout in accordance with the proposed annexation and NLISP would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground-shaking. Impacts would be less than significant.

Specific Plan Analysis
The annexation analysis provided above is also applicable to the specific plan analysis, including Planning Areas 2, 4, 6 (east), 7, and 8.

Potential Impact: Project implementation could expose people and structures to substantial adverse effects, including the risk of loss, injury, or death involving liquefaction.

Finding: The City hereby makes Finding 1.

26 Facts in Support of Findings:

Annexation Analysis
Liquefaction zones are located within the annexation area, specifically traversing the site in a southwest- northeast direction, and within areas directly north of Avenue D; refer to DEIR Exhibit 5.6-1, Liquefaction Zones. Additionally, groundwater seepage in the center of the annexation area has been measured at 28 feet below ground surface (bgs), and sands and silty sands that comprise the soil on-site could be subject to liquefaction during an earthquake. Future development within the annexation area in accordance with the proposed land uses could occur in a potential liquefaction zone, in areas subject to seepage, and/or in areas with sand and silty sand at shallow depths. Site - and project-specific geotechnical reports may also be required to evaluate geotechnical hazards on-site and determine any required geotechnical design criteria to reduce geological hazards (Mitigation Measure GEO-1). Additionally, future development would be required to comply with the CBSC and LMC requirements related to building safety to reduce potential liquefaction impacts. With the incorporation of Mitigation Measure GEO -1, impacts would be less than significant.

Specific Plan Analysis
Liquefaction zones are located within NLISP Planning Areas 2, 3, and 5 through 8; refer to DEIR Exhibit 5.6-

1. Therefore, proposed and future development within the Specific Plan area may be subject to liquefaction in the event of a major earthquake. Plann ed and future development within a liquefaction zone would conform with the CBSC’s design standards for Site Class F (i.e. sites with soils with high liquefaction potential). Further, all future development in accordance with the NLISP, would be required to comply with the CBSC and LMC requirements related to building safety to reduce potential liquefaction impacts. Future development would also be required to undergo separate environmental review under CEQA to evaluate project-specific impacts and identify any required mitigation measures. Thus, following implementation of Mitigation Measure GEO-1, and compliance with existing regulations, implementation of the NLISP would not expose people or structures to adverse liquefaction hazards, and impacts would be less than significant.

Planning Areas 2, 4, 6 (east), 7, and 8 Analysis
As detailed above, liquefaction zones are located within Planning Areas 2, 6 (east), 7 and 8; refer to DEIR Exhibit 5.6 -1. Specifically, sands and silty sands at depths of approximately 35 to 50 feet bgs within Planning Area 6 (east) may be subject to liquefaction, as well as silty sands at a depth of approximately 20 feet bgs within Planning Areas 7 and 8. Additionally, while not in a mapped liquefaction zone, groundwater seepage in Planning Area 4 has been measured at 28 feet bgs, which is shallower than the applicable liquefaction risk threshold of 30 feet bgs as identified in the DEIR Appendix 11.4, Geotechnical Reports .

Therefore, proposed and future development within the Specific Plan area may be subject to liquefaction in the event of a major earthquake. Planned and future development within Planning Areas 2, 4, 6, 7, and 8 would be subject to Mitigation Measure GEO -2, which would require that geotechnical recommendations in the Geotechnical Reports or an updated/finalized project -specific geotechnica l investigation be incorporated into project plans prior to issuance of a grading permit. Additionally, any development within a liquefaction zone would conform with the CBSC’s design standards for Site Class F (i.e. sites with soils with high liquefaction potential). Further, the proposed industrial warehouse buildings, as well as all future development in accordance with the NLISP, would be required to comply with the CBSC and LMC requirements related to building safety to reduce potential liquefaction im pacts. Future 27 development would also be required to undergo separate environmental review under CEQA to evaluate project-specific impacts and identify any required mitigation measures. Thus, following implementation of Mitigation Measures GEO-1 and GEO-2, and compliance with existing regulations, implementation of the NLISP would not expose people or structures to adverse liquefaction hazards, and impacts would be less than significant.

Potential Impact: Project implementation could result in substantial soil erosion or loss of topsoil.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
Construction of future uses within the annexation area (including the Specific Plan area) could require grading activities with the potential to result in soil erosion or loss of topsoil. LMC Section 8.16.030, Disturbing Surface of Land or Causing Wind Erosion Prohibited, prohibits the disturbance of surface or subsurface land by excavating, grading, leveling cultivating, plowing, discing, removing any existing vegetation or by depositing or spreading a quantity of soil on said land, or by any other act likely to cause or contribute to dust emission or wind erosion of said land during construction activities. LMC Section

8.16.030 also prohibits the aggravation of an existing dust or wind erosion condition without providing sufficient protection. Further, LMC Section 15.64.060, Drainage/Flood Control Improvements Fee , funds mitigation of stormwater runoff impacts caused by the construction and operation of new development.

Further, the City and Air District prohibit mass grading for alternative energy facilities (e.g., solar facilities, etc.), which would help reduce soil erosion impacts.

In compliance with the State Regional Water Quality Control Board (SWRCB) National Pollutant Discharge Elimination System (NPDES) program, development projects involving one or more acres of site disturbance would also be required to prepare and implement a Stormwater Pollution Prevention Plan (SWPPP) and associated Best Management Plans (BMPs) in compliance with the SWRCB’s Construction General Permit during grading and construction.

As shown, future development projects within the annexation area (including the Specific Plan area) would be required to comply with the LMC and the NPDES program requirements. Further, all future development projects would be required to undergo separate environmental review under CEQA to evaluate site-specific impacts and identify any required mitigation measures. Therefore, impacts would be less than significant.

Specific Plan Analysis
The annexation analysis provided above is also applicable to the specific plan analysis including Planning Areas 2, 4, 6 (east), 7, and 8.

Potential Impact: Project implementation could be located on unstable soils or expansive soils and potentially result in geologic hazards or create a substantial direct or indirect risk to life or property.

Finding: The City hereby makes Finding 1.
28 Facts in Support of Findings: The project site is located within a seismically -active area that could result in unstable soil conditions. Refer to DEIR Section 8.0, Effects Found Not To Be Significant, for a discussion concerning the project’s potential impacts in regard to landslide hazards and to DEIR Impact Statement GEO-2 for analysis regarding the project’s potential impacts with regards to liquefaction hazards.

Annexation Analysis
As portions of the annexation area are located within a liquefaction zone, lateral spreading could occur; refer to DEIR Exhibit 5.6 -1. Additionally, the southern portion of the annexation area includes areas of known fissures, which could result in subsidence and compression; refer to DEIR Exhibit 5.6-2, Soil Stability Issues. Regarding expansive soils, the annexation area, like most of the City, has low shrink/swell potential.

Nonetheless, per Mitigation Measures GEO-1 and GEO-2, future applicable development projects would be required to prepare project- and site-specific geotechnical reports which would evaluate site-specific geologic hazards and provide geotechnical recommendations to reduce geologic hazards. Additionally, future developments would be required to comply with the CBSC and LMC requirements related to building safety to reduce potential geologic hazards. Thus, impacts would be less than significant following implementation of Mitigation Measures GEO-1 and GEO-2.

Specific Plan Analysis
In regard to lateral spreading, as shown on DEIR Exhibit 5.6-1, portions of the Specific Plan area are located within a liquefaction zone; as such, lateral spreading could occur. Planning Areas 2, 3, and 5 through 8 are confirmed to be at risk of liquefaction and are at risk for lateral spreading as well. In regard to subsidence and collapse, the southern portion of the Specific Plan area includes areas of known fissures, which could result in subsidence and compression; refer to DEIR Exhibit 5.6-2.

Planned and future development within these Planning Areas would be subject to Mitigation Measure GEO-2, which would require incorporation of all geotechnical recommendations into project plans prior to issuance of grading permits. Additionally, future dev elopment throughout the Specific Plan area may also be required to implement Mitigation Measure GEO -1 to evaluate on-site geologic hazards. Further, proposed structures as well as future improvements throughout the Specific Plan area would comply with the CBSC and LMC requirements related to building safety to ensure geotechnical stability with respect to unstable soils resulting in lateral spreading, subsidence, collapse, and expansive soils. Thus, with the incorporation of Mitigation Measures GEO-1 and GEO-2 and compliance with the CBSC and LMC, impacts would be less than significant.

Planning Areas 2, 4, 6 (east), 7, and 8 Analysis
In regard to lateral spreading, as shown on DEIR Exhibit 5.6-1, portions of the Specific Plan area are located within a liquefaction zone; as such, lateral spreading could occur. Planning Areas 2, 6 (east), 7 and 8 are confirmed to be at risk of liquefaction and are at risk for lateral spreading as well. In regard to subsidence and collapse, the southern portion of the Specific Plan area includes areas of known fissures, which could result in subsidence and compression; refer to DEIR Exhibit 5.6-2. The Geotechnical Reports confirm that soils within Planning Areas 2, 7, and 8 are documented to be experiencing subsidence. However, according to the Geotechnical Reports, soil tested in Planning Areas 2, 4, 6 (east), 7, and 8 resulted in generally low collapse potential. Regarding expansive soils, soils throughout the Specific Plan area range in expansion potential from very low in Planning Areas 2 and 6, low in Planning Area 4, and medium to high in Planning Areas 7 and 8 based on the Geotechnical Reports.
29 As detailed above, planned and future development within Planning Areas 2, 4, 6 (east), 7, and 8 would be subject to Mitigation Measure GEO- 2, which would require incorporation of all geotechnical recommendations into project plans prior to issuance of grading permits. Additionally, future development within Planning Areas 2, 4, 6 (east), 7, and 8 may also be required to implement Mitigation Measure GEO-1 to evaluate on-site geologic hazards. Further, proposed structures within Planning Areas 2, 4, 6 (east) , 7, and 8 would comply with the CBSC and LMC requirements related to building safety to ensure geotechnical stability with respect to unstable soils resulting in lateral spreading, subsidence, collapse, and expansive soils. Thus, with the incorporation of Mitigation Measures GEO-1 and GEO-2 and compliance with the CBSC and LMC, impacts would be less than significant.

Potential Impact: Project implementation could 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.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
Existing uses within the annexation area are not currently connected to the County of Los Angeles Sanitation District (LACSD) regional trunk sewer system or the City’s local sewer network. Rather, wastewater generated by existing uses within the project site are collected by underground, privately - owned septic tank systems. While there are currently only septic systems in the ann exation area, it is possible that the City would extend wastewater services into the annexation area in the future as more development occurs in the northern portion of Lancaster. As such, future development within the annexation area would either connect to existing septic systems on -site, install new septic systems, or connect to the City’s wastewater network. It should be noted that existing uses currently connected to existing septic systems would not be required to connect to the City’s wastewater network. As the annexation area potentially contains areas prone to liquefaction, unstable soils, or expansive soils, all future development projects would be required to undergo separate environmental review under CEQA to evaluate project-specific impacts and identify any required mitigation measures.

Additionally, the use of septic tanks in the City is regulated by LMC Section 16.24.210, Use of septic tanks, which allows the use of on -site septic systems in nonurban residential areas as defined by the General Plan. Only new developments located within 200 feet of existing sanitary sewer infrastructure would be required to connect to the City’s wastewater network. Additionally, the 2022 edition of the California Plumbing Code (2022 CPC) contains plumbing design and construction standards related to septic tanks.

The standards protect against hazards that may arise from the use of plumbing piping and systems by regulating and controlling the design, construction, installation, quality of materials, location, and operation of plumbing piping systems within the State. Specifically, septic tank systems are required to meet design criteria, distance requirements, and capacity standards outlined in Appendix H, Private Sewage Disposal System, of the 2022 CPC. Additionally, new septic tank systems would also be required to meet design criteria and soil absorption capacities that are compatible with existing on-site soils. Upon compliance with existing State and local regulations, impacts would be less than significant.

30 Specific Plan Analysis
Future development within the Specific Plan area would connect to the City’s wastewater network via multiple existing and proposed sanitary sewer lines throughout the Specific Plan area. These lines would connect to the trunk sewer lines including the trun k sewer line located in 20th Street West, along the western boundary of the Specific Plan area; refer to DEIR Exhibit 3-9, Sanitary Sewer Infrastructure Plan.

The existing sanitary sewer main would provide points of connection along 20th Street West at Avenue D, Avenue E, and Avenue F. There is also an option to install an off -site sanitary sewer line (i.e., off-site from the Specific Plan area but within the larger annexation area) to connect to the existing 20th Street West sewer line at Avenue G; refer to DEIR Exhibit 3- 9. Future on-site planned sewer lines would occur within Avenue D, Avenue E, Avenue F, the southern section of 10th Street West between Avenue F and Avenue F-8, and within the common border of Planning Areas 6 and 7. Thus, buildout of the NLISP would not utilize alternative wastewater disposal systems (e.g., septic systems) and no impacts would occur.

Potential Impact: Project implementation could directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
The mapped rock formations within the annexation area consist of alluvium of Holocene to middle Pleistocene age and lacustrine deposits of Pleistocene age. As such, future development in accordance with the proposed land use designations in the annexation area has a high potential to disturb paleontological resources within undisturbed bedrock, with sensitivity increasing with depth.

Potential impacts to paleontological resources are based on soil conditions and project details (e.g., depth of excavation required). Thus, it is speculative to determine potential impacts to paleontological resources at this programmatic level of analysis. It is not anticipated that activities taking place at depths less than three feet, such as clearing and grubbing, or at the current topsoil surface, such as building renovations, would encounter paleontological resources. However, for any future ground disturbing activities (grading, excavation, boring, etc.) at depths greater than three feet and in undisturbed geologic contexts which have the potential to contain significant paleontological resources, implementation of Mitigation Measures GEO-3 through G EO-6 are required to reduce potential impacts. Mitigation Measure GEO -3 would require the retention of a Society of Vertebrate Paleontology (SVP) qualified paleontologist to provide or supervise a paleontological sensitivity training to all personnel plann ed to be involved with earth-moving activities, prior to the beginning of ground-disturbing activities. Mitigation Measure GEO-4 would require monitoring by an SVP qualified paleontologist for grading or excavation in sedimentary rock material, other than top soil, at depths of three feet below present grade or greater. Mitigation Measure GEO-5 outlines the requirements for a data recovery plan if a fossil is discovered. Mitigation Measure GEO-6 includes reporting and avoidance measures for a fossil discove ry, as well as procedures for continuing work on -site. Implementation of Mitigation Measures GEO -3 through GEO -6 would reduce impacts to less than significant levels.

31 Specific Plan Analysis
The mapped rock formations within the Specific Plan area consist of alluvium of Holocene to middle Pleistocene age and lacustrine deposits of Pleistocene age. As such, the project has a high potential to disturb paleontological resources within undisturbed bedrock, with sensitivity increasing with depth. For all development within the NLISP, activities taking place at depths less than three feet, such as clearing and grubbing, or at the current topsoil surface, are not anticipated to encounter paleontologic al resources. For any ground disturbing activities (grading, excavation, boring, etc.) at depths greater than three feet and in undisturbed geologic contexts which have the potential to contain significant paleontological resources, implementation of Mitigation Measures GEO -3 through GEO-6 is required to reduce potential impacts to less than significant levels.

Planning Areas 2, 4, 6 (east), 7, and 8 Analysis
For development of the proposed industrial warehouse buildings within Planning Areas 2, 6 (east), 7, and 8, as well as all other development within the NLISP, activities taking place at depths less than three feet, such as clearing and grubbing, or at the current topsoil surface, are not anticipated to encounter paleontological resources. For any ground disturbing activities (grading, excavation, boring, etc.) at depths greater than three feet and in undisturbed geologic contexts which have the potential to contain significant paleontological resources, implementation of Mitigation Measures GEO -3 through GEO -6 is required to reduce potential impacts to less than significant levels.

Potential Impact: Project implementation, combined with other related cumulative projects, could expose people and structures to potential substantial adverse effects involving geology and soils.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Cumulative projects identified in DEIR Table 4 -1 would be located within proximity to similar soil conditions as the project. However, in the event of an earthquake, the intensity of seismic ground shaking would vary by site based on earthquake magnitude, distance to epicenter, and geology of the area between the epicenter and the cumulative project sites, and thus geologic hazards would vary accordingly.

Similar to future development projects within the annexation and Specific Plan areas, cumulative projects would be required to comply with existing local, State, and Federal regulations regarding geologic hazards.

For example, future developments would be required to comply with the Earthquake Hazards Reduction Act, Seismic Hazard Mapping Act, NPDES program, CBSC, and LMC.

As concluded above, geologic/seismic hazards associated with the proposed project would be less than significant upon implementation of regulatory requirements and Mitigation Measures GEO-1 and GEO-2, which would require site-specific geotechnical investigations and adherence to the recommendations of the geotechnical investigations. Thus, cumulative impacts would be less than significant.

Potential Impact: The proposed project, in conjunction with cumulative development, could directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.

Finding: The City hereby makes Finding 1.

32 Facts in Support of Findings:

Cumulative projects identified in DEIR Table 4 -1 would be located within proximity to similar geologic conditions as the project, and thus have similar potential to encounter paleontological resources.

However, potential paleontological resource impacts associated with the development of each cumulative project would be specific to each site.

As concluded above, paleontological impacts associated with the proposed project would be less than significant upon implementation of regulatory requirements and Mitigation Measures GEO -3 through GEO-6. Further, all future development projects within the annexation area and Specific Plan area would be required to undergo separate project - and site -specific environmental review. Thus, cumulative impacts would be less than significant.

G. HYDROLOGY AND WATER QUALITY
The thresholds of significance for hydrology and water quality impacts are listed in Section 5.7, Hydrology and Water Quality, on pages 5.7-19 and 5.7-20 of the DEIR. Impact analyses were detailed on pages 5.7- 20 through 5.7-33.

Potential Impact: Project implementation could violate water quality standards or waste discharge requirements or otherwise substantially degrade water quality.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
Construction
Future development within the annexation area (including the Specific Plan area) that disturb less than one acre of land would be required to comply with the City’s SWMP, which includes minimum control measures that minimize stormwater runoff during construction and operation. If future developments are anticipated to disturb more than one acre of land, a General Construction Permit under the NPDES program would be required and the future development project would be subject to the stormwater discharge requirements of a General Construction Permit. Compliance with existing regulations would minimize construction-related water quality impacts associated with future development projects within the annexation area (including the Specific Plan area). Impacts would be less than significant.

Operations
Buildout in accordance with the proposed land use designations and pre-zones within the annexation area (including the Specific Plan area) could contribute to water quality degradation in the City as it could increase impervious areas within the annexation area, thus increasing urban runoff. As the proposed land use designations and pre -zones would allow for a variety of uses, substances such as oils, fuels, paints, and solvents may be transported to nearby drainages, watersheds, and groundwater in stormwat er runoff. The significance of these water quality impacts would vary depending upon a variety of conditions, including weather conditions, soil conditions, increased sedimentation of drainage systems within the area, compliance with MS4 and NPDES permit requirements, and proper installation of BMPs. Further, in 33 accordance with LMC Section 8.50.200, Stormwater management and rainwater retention , stormwater management practices or technical requirements for existing and/or new landscaping would be required for new developments to minimize runoff and increase rainwater retention and infiltration. Additionally, applicable future development projects would be required to prepare a Water Quality Management Plan (WQMP) in compliance with the NPDES permit requirements. Future projects would also be required to comply with the City’s Storm Water Management Program (SWMP), which includes additional minimum control measures that reduce stormwater runoff during operation. Overall, future development projects would be required to comply with existing regulations for water quality standards or Report of Waste Discharge (WDR) and would be ensured as part of the City’s plan review process. Impacts would be less than significant.

Specific Plan Analysis
The annexation analysis provided above is also applicable to the specific plan analysis including Planning Areas 2, 4, 6 (east), 7, and 8.

Potential Impact: Project implementation could decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
As the annexation area is primarily vacant, future development projects would increase the amount of impervious areas, which has the potential to interfere with groundwater recharge. It is not anticipated that this change in imperviousness would interfere with natural groundwater recharge since direct rainfall from the Lancaster area makes an inconsequential contribution to overall groundwater recharge of aquifers in the Antelope Valley.

Although impacts to natural groundwater recharge are not anticipated, impacts to groundwater supplies because of future development could occur. The annexation area is in the Antelope Valley Groundwater Basin, which is managed by the Antelope Valley Waterm aster. Prolonged drought conditions in recent years, which resulted in decreased runoff and recharge, and declining water levels in much of the Basin, resulted in an overall decrease in groundwater in storage. However, since 2015, a judgement was administered for the Basin to establish a safe yield for groundwater production and an allocation of that safe yield among Basin producers. Since long-term recharge is expected to be stable, it is anticipated that groundwater pumping, and hence supply, will be reliable even in short-term and multiple year droughts.

Thus, groundwater is considered a very reliable supply for the Antelope Valley Region. Additionally, with the introduction of State Water Project water and increasing urbanization, the water table depressions have either stabilized or increased in the Antelope Valley Region.

Due to the potential increased water demand generated by the proposed land use designations and pre- zones in the annexation area, groundwater demand may increase and total water demand in the City and Antelope Valley may similarly increase. Each future development project would have a specific impact on water demand, depending on the proposed land uses and development intensity. However, as discussed in DEIR Section 5.11, future development would be required to adhere to Title 20 of the California Code 34 of Regulations (CCR) and implement water efficiency design standards. All future developments would be required to obtain a water will serve letter or equivalent prior to issuance of building permits. Therefore, impacts would be less than significant.

Specific Plan Analysis
As the Specific Plan area is primarily vacant, future buildout of the NLISP would increase impervious areas, which has the potential to interfere with groundwater recharge. As stated, it is not anticipated that this change in imperviousness would interfere with natural groundwater recharge since direct rainfall from the Lancaster area makes an inconsequential contribution to overall groundwater recharge of aquifers in the Antelope Valley.

As detailed in DEIR Section 5.11, the estimated water demand associated with buildout of the NLISP would be adequately accommodated by Los Angeles County Waterworks District 40 (LACWD 40) system’s water supply. As a result, buildout of the NLISP would not substantially decrease groundwater supplies or interfere with groundwater recharge such that the project may impede sustainable groundwater management of the basin. Therefore, impacts would be less than significant.

Potential Impact: Project implementation could alter the existing drainage pattern of the area which could result in substantial erosion or siltation, increase the amount or rate of surface run-off, exceed the capacity of stormwater drainage systems or impede or redirect flood flows.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
Erosion/Siltation
Construction for future development within the annexation area would involve earthmoving activities, which have the potential to result in soil erosion or siltation. If the future development disturbs less than one acre of land, the development would be required to comply with the City’s SWMP, which includes minimum control measures that minimize stormwater runoff resulting from erosion or siltation during construction and operation. If the future development disturbs more than one acre of land, a General Construction Permit under the NPDES program would be required and the future development would be subject to the stormwater discharge requirements of a General Construction Permit. LMC Section

8.50.110, Grading design plan¸ also requires that grading of a project site be designed to minimize soil erosion, runoff, and water waste. Furthermore, LMC Section 8.16.030, Disturbing Surface of Land or Causing Wind Erosion Prohibited, prohibits the disturbance of surface or subsurface land by excavating, grading, leveling cultivating, plowing, discing, removing any existing vegetation or by depositing or spreading a quantity of soil on said land, or by any other act likely to cause or contribute to dust emission or wind erosion of said land during construction activities. LMC Section 8.16.030 also prohibits the aggravation of existing dust or wind erosion condition without providing sufficient protection. Compliance with existing regulations would minimize construction - and operation -related erosion and siltation impacts associated with future development projects within the annexation area. Impacts would be less than significant.

35 Flooding
Portions of the annexation area are within flood hazard zones. Specifically, the northern and southern portions of the annexation area are located within areas having a one percent or greater chance of flood occurrence within any given year; refer to DEIR Exhibit 5.7 -1, Flood Zone Map. As such, future development within these areas could be prone to flooding. However, all future development would be required to comply with applicable federal, State, and local regulations related to flood control. These regulations and requirements may include preparation of hydrology and/or drainage studies per LMC Section 16.24.140, Hydrology study; installation of drainage structures such as culverts, storm drains, or other improvements in accordance with LMC Section 16.24.150, Mitigation of storm and nuisance water runoff; implementation of stormwater management practices for proposed landscaping per LMC Section

8.50.200, Stormwater management and rainwater retention ; and payment of drainage/flood control improvement fees per LMC Section 15.64.060, Drainage/flood control improvements fee.

Further, the Master Plan of Drainage requires that drainage facilities not identified in the plan but that may be necessary to convey storm water through a proposed development be the developer’s sole responsibility. Therefore, impacts related to flooding resulting from altered drainage patterns would be less than significant.

Stormwater Drainage System
Future development within the annexation area would be constructed on predominately vacant, undeveloped land, and would generally result in an increase in impervious surfaces and stormwater runoff in the area. As stated, the annexation area does not have any existing storm drain infrastructure. However, the City has plans to construct a regional storm drain (sized for 50 -year storm events) (i.e., regional earthen channel) in the southwestern portion of the annexation area to the west of SR- 14 (i.e., near the northwestern corner of the Avenue F and SR -14 intersection). Additional planned regional storm drains (sized for 50 -year storm events) (i.e., regional earthen channels and reinforced concrete pipes) and proposed outlet/energy dissipators are located off- site within existing City limits along the southern boundary of the annexation area.

Compliance with the City’s SWMP, NPDES General Construction Permit (if applicable), and LMC would ensure future developments in the annexation area adequately mitigate potential impacts related to altering existing drainage patterns and increases in stormwater runoff. Therefore, impacts would be less than significant.

Specific Plan Analysis
Erosion/Siltation
Construction of future development in accordance with the NLISP would involve earthmoving activities, which have the potential to result in soil erosion or siltation. However, if the future development disturbs less than one acre of land, the development would be required to comply with the City’s SWMP. If the future development disturbs more than one acre of land, a General Construction Permit under the NPDES program would be required and the future development would be subject to the stormwater discharge requirements of a General Construction Permit. As described in the NLISP, future development would also require development and implementation of an erosion control plan. LMC Section 8.50.110, also requires that grading of a project site be designed to minimize soil erosion, runoff, and water waste. Furthermore, implementation of the NLISP would be required to comply with LMC Section 15.64.060, and LMC Section 36 8.16.030, as well as the NPDES program requirements. Moreover, LMC Section 15.64.060, funds mitigation of stormwater runoff impacts caused by the construction and operation of new development.

Compliance with existing regulations, would minimize construction - and operation-related erosion and siltation impacts associated with buildout of the NLISP. As such, impacts would be less than significant.

Flooding
Portions of the Specific Plan area are within flood hazard zones. Specifically, the southeastern portion (i.e., portions of Planning Areas 3 and 5 through 8) of the Specific Plan area is located within an area having a one percent or greater chance of floo d occurrence within any given year; refer to DEIR Exhibit 5.7 -1. As such, future development in accordance with the NLISP could be located in areas that are prone to flooding.

To accommodate future development in the Specific Plan area, future improvements include a 2,125 acre- foot water retention pond (i.e., Pond Three) within Planning Area 3; refer to Appendix XXIV of the City of Lancaster Hydrology Study for North Annexation Avenue G to Avenue B & 14 Freeway to 5th Street West, Lancaster, CA 93534 (Hydrology Study), prepared by Duke Engineering, dated February 17, 2025. Pond Three would be designed to mitigate the additional stormwater entering Piute Ponds from the channelization of the stormwater along the Amargosa Creek, and additional impervious surfaces associated with future NLISP buildout. Proposed channels would convey the generated stormwater in a northeasterly direction towards Piute Ponds where stormwater would overflow back into the existing drainage pattern. Where the channel system terminates, the pre-developed storm runoff volume would be maintained to not lessen the amount of natural storm water entering Piute Ponds. Additionally, future development in accordance with the NLISP would require individual detention basins and storm drain systems for each development site. These systems would be designed as part of project-specific site plans during the planning stage of the entitlement process. The required detention systems would be designed to comply with the City’s storm water managemen t requirements in accordance with LMC Section

16.24.150. Each system would be site -specific and designed for individual sites not utilizing the master planned channels and ponds to satisfy the design specifications.

Further, all future development would be required to comply with applicable federal, State, and local regulations related to flood control. These regulations and requirements may include preparation of hydrology and/or drainage studies per LMC Section 16.24.140; implementation of stormwater management practices for proposed landscaping per Municipal Code Section 8.50.200, Stormwater management and rainwater retention; and payment of drainage/flood control improvement fees per LMC Section 15.64.060. Additionally, per the National Flood Improvement Program Floodplain Management Requirements Guide and Title 44 Code of Federal Regulations (CFR) Sections 60.3(c)(7) and (c)(11), all new construction in AO zones must have the structure lowest floor elevated above the highest adjacent grade.

Adequate drainage paths would be required around future development to guide floodwater around and away from the proposed buildings, as applicable. As described in the NLISP, the master storm drain system for the Specific Plan area would follow the standards provided in the City’s Master Plan of Drainage. The Master Plan of Drainage requires that drainage facilities not identified in the plan but that may be necessary to convey storm water through a proposed development be the developer’s sole responsibility.

Additionally, any drainage from a future development project needs to be properly conveyed downstream to a suitable receiving facility; should these facilities not serve the needs of the Master Plan of Drainage, implementation of the facilities would be the developer’s sole responsibility. Therefore, impacts related to flooding resulting from altered drainage patterns would be less than significant. 37 Stormwater Drainage System
As stated, proposed channels, a water retention pond (i.e., Pond Three), and individual site -specific detention basins and storm drain systems would be designed to adequately mitigate additional stormwater associated with future buildout of the NLISP. Compliance with existing local, State, and federal regulations related to stormwater systems would also reduce potential impacts to less than significant levels.

Potential Impact: Project implementation could risk release of pollutants due to project inundation from flood hazard, tsunami, or seiche zones.

Finding: The City hereby makes Finding 1.

Annexation Analysis
Flooding can occur during and immediately after periods of heavy rainfail, or from tsunamis, seiches, or dam failure. Refer to DEIR Impact Statement HWQ-3 for a discussion regarding flood hazards.

Tsunamis are large waves caused by the sudden displacement of water that results from an underwater earthquake, landslide, or volcanic eruption. Tsunamis generally affect low-lying areas along the coastline.

The annexation area is located over 50 miles inland, and not located within a designated Tsunami Hazard Area. Thus, tsunamis are not a potential hazard.

Seiches are oscillating standing waves generated by two waves traveling in opposite directions in an enclosed body of water. They can be caused by wind or earthquake -related ground shaking. The project site is not near any large bodies of water capable of inducing seiches. It is acknowledged that Apollo Community Regional Park, located approximately 1.9 miles to the west of the project site at 4555 Avenue G, contains a large man -made lakes. However, this body of water is not large enough to induce seiches.

Thus, seiches are not a potential hazard. Dam failure is the structural collapse of a dam that releases the water stored in the reservoir behind the dam. A dam failure is usually the result of the age of the structure, inadequate spillway capacity used in construction, or structural damage caused by an earthquake or flood.

Amargosa Creek Dam is located approximately 15 miles southwest of the project site. However, the project site is not located within the inundation area of the dam. Thus, dam failure is no t a potential hazard.

Overall, future development within the project site would result in less than significant impacts with regards to the release of pollutants due to project inundation from flood hazard, tsunami, or seiche zones.

Specific Plan Analysis
The annexation analysis provided above is also applicable to the specific plan analysis including Planning Areas 2, 4, 6 (east), 7, and 8.

Potential Impact: Project implementation could conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.

Finding: The City hereby makes Finding 1.

38 Facts in Support of Findings:

Annexation Analysis
The project site is in the Antelope Valley Groundwater Basin (Basin). As stated, the Basin is categorized as a “very low” priority basin by the California Department of Water Resources. Therefore, no groundwater sustainability plan is established for the Basin. However, the City is located within the South Lahontan Hydrologic Region and is subject to the objectives and limits of the Basin Plan under the jurisdiction of the Lahontan RWQCB. Water quality standards and control measures for surface and ground w aters of the Lahontan Region are contained in the Basin Plan. Refer to DEIR Impact Statement HWQ-1 for a discussion regarding project impacts to water quality.

Specific Plan Analysis
The annexation analysis provided above is also applicable to the specific plan analysis including Planning Areas 2, 4, 6 (east), 7, and 8.

Potential Impact: The proposed project, in conjunction with cumulative development , could create impacts with respect to water quality, groundwater supplies, drainage and flooding.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Water Quality
Cumulative projects could contribute to water quality degradation that results in the violation of water quality standards or WDRs in the Antelope Valley Groundwater Basin. However, all cumulative projects would be required to mitigate site- specific hydrologic impacts on a project-by-project basis pursuant to all applicable federal, State, and local stormwater regulations and requirements, including NPDES permit requirements. Future development projects within the annexation and specific plan areas could contribute to water quality degradation in the project site. In compliance with NPDES permit requirements, future development projects would be required to implement project-specific SWPPPs and WQMPs to minimize off- site discharge of anticipated and potential pollutant runoff during the construction and operations. As a result, future development projects would not result in the violation of water quality standards or WDRs or otherwise substantially degrade water quality. Implementation of the proposed project would not result in a substantial cumulative contribution to water quality impacts and cumulative impacts would be less than significant.

Groundwater
Cumulative impacts to groundwater supplies as a result of future development are anticipated to occur as water demand increases with each development. However, all projects would be required to mitigate project-specific impacts groundwater supplies on a project -by-project basis pursuant to all applicable federal, State, and local regulations and requirements. F uture development projects within the annexation and specific plan areas could result in impacts to groundwater supplies. However, adherence to State and local regulations would minimize impacts associated with the annexation to groundwater supplies. Impacts would be less than significant. Additionally, the estimated water demand associated with buildout of the NLISP would be adequately accommodated by LACWD 40’s water supply. As a result, 39 buildout of the NLISP would not substantially decrease groundwater supplies or interfere with groundwater recharge such that the project may impede sustainable groundwater management of the basin. Implementation of the proposed project would not result in a substantial cumulative to groundwater supplies and cumulative impacts would be less than significant.

Drainage
Cumulative projects could alter local drainage patterns and result in substantial erosion/siltation, flooding, and/or stormwater in excess of planned capacity. However, as stated above, cumulative projects would be required to evaluate site- specific hydrologic impacts on a project -by-project basis pursuant to all applicable federal, State, and local stormwater regulations and requirements. These regulations would require project -specific BMPs, LID features, and/or on -site retention techniques, which would r educe peak flow rate or runoff volumes. If a future development project disturbs more than one acre of land, a General Construction Permit under the NPDES program would be required to prepare a project -specific SWPPP and WQMP with associated BMPs to be implemented.

The proposed annexation and NLISP could alter local drainage patterns and result in substantial erosion/siltation, flooding, and/or stormwater in excess of planned capacity. However, upon compliance with existing regulations, future development within the annexation area would result in less than significant impacts. Additionally, to accommodate future development in the specific plan area, future improvements include channelizing stormwater along the Amargosa Creek and installation of a 2,125 acre-foot water retention pond within Planning Area 3 . Pond Three would be designed to mitigate the additional stormwater entering Piute Ponds from the channelization of the stormwater along the Amargosa Creek, and additional impervious surfaces associated with future development. Additionally, future development in accordance with the NLISP would require development of individual detention basins and storm drain systems within the specific plan area. These systems would be designed as part of project-specific site plans during the planning stage of the entitlement process. Thus, the project would not result in a substantial cumulative contribution to erosion, siltation, or flooding on - or off-site and cumulative impacts would be less than significant.

Flooding
Cumulative projects developed within identified flood zones may result in the release of pollutants due to project inundation from flood hazards. However, all cumulative projects would be required to mitigate site-specific hydrologic impacts on a project-by-project basis pursuant to all applicable federal, State, and local regulations and requirements, including LMC requirements for installation of drainage structures and payment of drainage/flood control improvement fees. Additionally, individual project compliance with NPDES permit requirements regarding the preparation of a SWPPP and/or WQMP to implement site- specific structural and non-structural BMP controls would further minimize the risk of releasing pollutants due to project inundation.

The annexation and specific plan areas are not located in areas which could be subject to tsunamis, seiches, or dam failure. However, the proposed annexation and NLISP could result in the release of pollutants due to project inundation from flood hazards. Future developments within the annexation area would be required to comply with applicable federal, State, and local regulations related to flood control.

Further, to accommodate future development in the NLISP , future improvements include channelizing the stormwater along Amargosa Creek and constructing a 2,125 acre-foot water retention pond (i.e., Pond Three) within Planning Area 3. Additionally, future development in accordance with the NLISP would 40 require development of individual detention basins and storm drain systems for the Specific Plan area.

These systems would be designed as part of project specific site plans during the planning stage of the entitlement process. Thus, the project would not result in a substantial cumulative impact regarding the release of pollutants due to project inundation from flood hazards and cumulative impacts would be less than significant.

Water Quality Management Plans
No groundwater sustainability plan has been established for the Antelope Valley Groundwater Basin.

However, water quality standards and control measures for surface and ground waters of the Lahontan Region are contained in the Basin Plan. Cumulative projects developed within the Antelope Valley Groundwater Basin could contribute to water quality degradation through increasing impervious areas and urban runoff. However, all cumulative projects would be required to mitigate site-specific hydrologic impacts on a project-by-project basis pursuant to all applicable federal, State, and local regulations and requirements, including NPDES permit requirements (i.e., preparation of project -specific SWPPPs, WQMPs, and associated BMP/LID features) and LMC requirements, which would require installation of drainage structures and payment of drainage/flood control fees, as applicable.

The proposed annexation and NLISP could contribute to water quality degradation by potentially increasing impervious areas in the City and thus increasing urban runoff. However, with adherence to State and local regulations, impacts associated with the proposed annexation and NLISP regarding a conflict with the water quality control plan would be less than significant. As a result, future development projects would not result in substantial cumulative contribution related to conflict with a water quality control plan and impacts would be less than significant.

H. HAZARDS AND HAZARDOUS MATERIALS
The thresholds of significance for hazards and hazardous materials impacts are listed in Section 5.8, Hazards and Hazardous Materials, on pages 5.8-11 and 5.8-12 of the DEIR. Impact analyses were detailed on pages 5.8-12 through 5.8-29.

Potential Impact: Project implementation could create a significant hazard to the public or environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
Based on the Preliminary Hazardous Materials Assessment for the Westside Annexation and Specific Plan Project (Appendix 11.6 of the DEIR), the annexation area currently comprises of vacant undeveloped land, rural residential dwellings, mobile home parks, and industrial uses. No properties in the annexation area have been subjected to any corrective action, restoration, or remediation relating to hazardous waste and materials, but have reported the use/handling/storage/transport of hazardous materials. The p roposed annexation would not include any specific development or construction, and any future development would be subject to existing laws and regulations. However, future development within the annexation area could still result in accidental conditions involving existing on-site contamination due to current and 41 past uses within the annexation area. The following analyses consider potential accidental conditions associated with construction activities within the annexation area:

Existing On-Site Structures and Utilities
According to the Preliminary Hazardous Materials Assessment, structures located in the annexation area were likely constructed prior to 1978. These aged structures potentially contain asbestos containing material (ACM) and/or lead -based paint (LBP), and/or organochlorine-containing termiticides (used to treat wooden buildings constructed prior to 1989).

Future development in the annexation area, requiring the demolition of structures, would be conducted according to applicable federal and State laws and regulations. Specifically, any demolition permits issued by the City would require an Antelope Valley Air Quality Management District (AVAQMD) Notification of Demolition/Renovation to be submitted for review. The Notification of Demolition/Renovation is required to indicate no asbestos is located within the structure proposed to be demolished. If ACMs are identified for existing structures in the annexation area, asbestos abatement is required to be completed prior to any activities that would disturb ACMs or create an airborne asbestos hazard. If paint is separated from building materials (chemically or physically), the paint waste is required to be evaluated independently from the building material by a qualified environmental professional in accordance with California Code of Regulations Title 8, Section 1532.1. If LBPs are found, abatement is required to be completed by a qualified Lead Specialist prior to any activities that would create lead dust or fume hazard. Compliance with existing regulations related to ACMs and LBPs would reduce potential impacts to a less than significant level.

Additionally, removal of existing utilities that may contain Polychlorinated biphenyls (PCBs) would be conducted pursuant to the standard practices of each purveyor in a manner consistent with the existing laws and regulations, including those of California Department of Toxic Substances Control (DTSC), California Environmental Protection Agency (CalEPA), and California Division of Occupational Safety and Health (Cal/OSHA). Impacts would be less than significant.

Grading/Site Disturbance Activities
During excavation, potential hazardous substances/materials may be encountered. On -site construction workers and off- site receptors may be exposed to such substances/materials via direct contact and/or indirect exposures during excavation/grading, loading, and transportation. However, such substances/materials would be managed in accordance with a Health and Safety Plan (HASP) and/or a Soil Management Plan (SMP), as required by applicable local, State, and federal laws and regulations that pertain to the us e, storage, transportation and disposal of hazardous materials and waste. Mitigation Measure HAZ -1 establishes procedures to minimize potential risks to the public and environment if unknown wastes or suspect materials believed to involve hazardous waste or materials are encountered during construction of future development projects. Therefore, potential accidental conditions during excavation would be reduced to less than significant levels with implementation of Mitigation Measure HAZ-1.

Septic Systems
The annexation area has past and current uses that may have supported septic systems in the past or currently utilize septic systems. Evidence of these past structures are still visible, and it is unknown if these systems remain on-site. As such, the propo sed project would require the implementation of Mitigation 42 Measure HAZ-2 which would establish procedures for the proper identification and removal of any septic tanks on a project site in compliance with existing local and State regulations. Upon compliance with the recommended Mitigation Measure HAZ-2, impacts would be reduced to less than significant levels.

Specific Plan Analysis
Future development of the NLISP could involve grading and excavation activities, which may reveal unknown hazards and hazardous materials contamination. As stated, future development would be required to comply with existing applicable federal, State, and local laws related to the hazardous materials. Such substances/materials would be managed in accordance with a HASP and/or a SMP, as required by applicable local, State, and federal laws and regulations that pertain to the use, storage, transportation and disposal of hazardous materials and waste. Further, compliance with Mitigation Measures HAZ-1 and HAZ -2 would minimize potential risks related to accidental release of hazardous materials from unknown contamination discovered during construction. Upon comp liance with the existing federal, State, and local procedures, short - and long- term impacts related to the accidental release of hazardous materials would be less than significant.

Planning Areas 2, 4, 6 (east), 7, and 8 Analysis
Future development within several areas of the Specific Plan (Planning Areas 2 and 4) where site-specific hazardous materials investigation has been conducted due to past land uses could result in accidental conditions involving existing on-site contamination due to current and past uses within Planning Area 2 and 4. The following considers potential accidental conditions associated with construction activities within Planning Areas 2 and 4.

Accidental Conditions Within Planning Areas 2 and 4
According to the Preliminary Hazardous Materials Assessment, a field study was conducted at Planning Areas 2 and 4 for the presence of potential lead contamination from prior recreational duck hunting activities. Soil samples collected indicated that Plann ing Areas 2 and 4 do not exceed the lead concentration reporting limits. Less than significant impacts would result.

According to Preliminary Hazardous Materials Assessment, the rural residence in Planning Area 4 abandoned a septic tank and seepage pit in 1990. Additionally, other rural residences within Planning Area 2 have been reported to use septic tanks. These rural residences also contain a total of eight water wells and a 350 -gallon above surface tank that was previously used for the storage of jet ski fuel. The above surface tank has a lack of staining and as such, a prior release is unlikely. The septic tanks and wells are unlikely to represent an environmental concern but would require proper abandonment and removal prior to the development of Planning Areas 2 and 4.

As stated above, the demolition of structures such as rural residences and associated structures would be conducted according to applicable federal and State laws and regulations. Specifically, if ACMs are identified for existing structures within Planning Areas 2 and 4, asbestos abatement is required to be completed prior to any activities that would disturb ACMs or create an airborne asbestos hazard. If LBPs are found, abatement is required to be completed by a qualified Lead Specialist prior to any activities that would create lead dust or fume hazard. Closure of any water wells would be conducted in accordance with the California Department of Water Resources Water Well Standards per Mitigation Measure HAZ-3 to ensure proper destruction of the well to as sure that groundwater supply is protected and preserved for further use and to eliminate potential physical hazard of an abandoned well. 43 While miscellaneous debris piles are not typically associated with hazardous materials, demolition debris within these piles may contain potential LBPs and ACMs. As such, future development within Planning Areas 2 and 4 would be required to implement Mitig ation Measure HAZ- 4, which requires an asbestos and lead based paint survey for miscellaneous debris piles (associated with demolition debris). The survey would be conducted by an Asbestos Hazard Emergency Response Act (AHERA) and Cal/OSHA certified specialist to determine the presence or absence of ACMs or LBPs in debris piles. If ACMs or LBPs are present on-site, removal would be required to be performed by a State-certified contractor in accordance with the AVAQMD Rule 1403 and California Code of Regulat ion Title 8, Section 1532.1. Contractors performing ACM/LBP removal shall provide evidence of abatement activities to the AVAQMD. Upon compliance with Mitigation Measure HAZ-4, impacts would be reduced to less than significant levels.

Potential Impact: Project implementation could create a significant hazard to the public or environment through the routine transport, use, or disposal of hazardous materials.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
No construction or development is proposed as part of the annexation action. As such, the proposed annexation itself would not result in any new transport, use, or disposal of hazardous materials. Existing transport, use, or disposal of hazardous within the annexation area would continue to comply with federal, State, and local regulations, standards, and guidelines related to the transport, use, and disposal of hazardous materials.

Nevertheless, buildout of the annexation area could require hazardous materials for construction and operation of future development. Future development within the annexation area would be subject to compliance with existing federal, State, and local regulations, standards, and guidelines related to the transport, use, and disposal of hazardous materials. As such, impacts regarding the routine transport, use, or disposal of hazardous materials associated with future development in the annexation area would be less than significant.

Specific Plan Analysis
Construction
Development of the NLISP, including Planning Areas 2, 4, 6 (east), 7 and 8, may require the demolition of existing structures. Additionally, construction of the various uses permitted under the NLISP could potentially expose construction workers and the public to temporary hazards related to the transport, use, and maintenance of construction materials (i.e., oil, diesel fuel, transmission fluid, etc.). However, it should be noted that construction activities would cease upon construction completion and the materials used would not be in such quantities or stored in such a manner as to pose a significant safety hazard.

Construction activities would be required to comply with applicable federal, State, and local laws and regulations governing the use, storage , and transportation of hazardous materials/waste. Compliance with applicable laws and regulations would ensure that all potentially hazardous materials utilized during construction are used and handled in an appropriate manner. Impacts concerning the rout ine transport, use, or disposal of hazardous materials during construction would be less than significant. 44 Operation
The proposed land uses within the NLISP are expected to use/store quantities of hazardous materials such as fuel, paints, and other chemicals that would have the potential to be released into the environment if not properly handled and stored. The handling of hazardous materials, such as cleaning solutions, solvents, pesticides for landscaping, painting supplies, and petroleum products would be used/stored/handled in the Specific Plan area. The proper use, storage, and handling of these hazardous materials would be subject to federal, State, and local regulations. Upon compliance with the existing federal, State, and local procedures, long -term impacts related to the transport, use, and disposal of hazardous materials would be less than significant.

Potential Impact: Project implementation could result in a safety hazard or excessive noise for people residing or working in the project area.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

The closest airport to the project site is General William J. Fox Airfield, located at 4725 William J Barnes Avenue, approximately 1.5 miles to the west. The Los Angeles County Airport Land Use Commission adopted the ALUCP on December 1, 2004.

Annexation Analysis
Portions of the annexation area are located within the boundaries of the ALUCP, specifically Compatibility Zones C, D, and E. According to Table 2B of the ALUCP, Compatibility Zone C is a zone of moderate risk, a zone where aircraft turn towards the airport for final approach, a zone where departing aircraft complete transition from takeoff to climb mode, and where approximately 11 percent of off- runway aviation accidents occur. Compatibility Zone D is a zone of low risk and where 13 percent of general avia tion accidents occur; however, due to the large area Compatibility Zone D encompasses, a low likelihood of accidents would occur at a specific location. Compatibility Zone E is a zone of low risk and only two percent of near-airport accidents occur within Compatibility Zone E.

Development within the General William J. Fox Airfield compatibility zones would be required to comply with the guidelines and standards provided in the ALUCP. Table 2A of the ALUCP lists the prohibited uses within each Compatibility Zone, residential dwelling units per acre, maximum usage intensity (maximum permitted of people per acre), and other development conditions. Compliance with the guidelines and standards for the General William J. Fox Airfield compatibility zones would minimize the risk associat ed with an off-airport aircraft accident or emergency landing.

According to Exhibit 2B, Noise Contours for Compatibility Planning, and Exhibit 3F, Compatibility Factor Map, of the ALUCP, the annexation area is not located within the General William J. Fox Airfield noise contours. As discussed in the ALUCP, the maximum Community Noise Equivalent Level (CNEL) considered normally acceptable for new residential land uses in the vicinity of the airport is 55 dBA; however, new residential uses are deemed marginally acceptable within the 55 to 60 decibel (dB) CNEL range. Othe r permitted uses allowed within this CNEL range include, but are not limited to, schools, libraries, offices, commercial, industrial, and agricultural uses. As the annexation area is located outside of the 55 CNEL noise contour of the General William J. Fox Airfield, existing and future developments within the annexation area would not be exposed to excessive noise levels. 45 The annexation action would not result in any direct development. All development within the annexation area would be subject to review. Further, all future development within the annexation area, specifically those within Compatibility Zones C, D, and E, would be required to demonstrate compliance with the ALUCP, as applicable. As such, impacts would be less than significant.

Specific Plan Analysis
As shown in DEIR Exhibit 3-11, portions of the Specific Plan area are located within the boundaries of the ALUCP, specifically Compatibility Zones C, D, and E. However, future and proposed development in accordance with the NLISP would be subject to the gu idelines and standards for each respective compatibility zone, which would minimize the risk associated with a near- airport aircraft accident or emergency landing.

The Specific Plan accommodates approximately 38.5 million sf of various uses permitted under the NLISP.

According to the ALUCP, non-residential development within the compatibility zone must comply with the maximum usage intensity (maximum permitted of peo ple per acre) and noise -sensitivity of the use.

According to Table 2A of the ALUCP, Compatibility Zone C permits a maximum average of 75 individuals per acre at a project site and a clustering of 150 individuals on a single acre. Compatibility Zone D permits a maximum average of 150 individuals per acre at a project site and a clustering of 300 individuals on a single acre. Compatibility Zone E does not have a maximum usage intensity threshold. As such, Planning Areas 1, 4, and 5 would be required to comply with listed maximum usage intensity for Compatibility Zone C for the portions within the zone and comply with the maximum usage intensity for Compatibility Zone D for the other portion within this zone. As shown in DEIR Exhibit 3 -11, portions of Planning Areas 2 (southern half), 3 (northern and central portions), and 6 (northwestern portion) of the NLISP would be required to comply with the listed maximum usage intensity for Compatibility Zone D. For the remaining portions of Planning Areas 2, 3, and 6, no maximum usage intensity requirements apply. Similarly, Planning Areas 7 and 8 do not have a maximum usage intensity requirement.

Developments within the Compatibility Zone C would require an Airspace review by the Los Angeles Airport Land Use Commission (ALUC) and Federal Aviation Administration (FAA) for objects greater than 50 feet. Developments within the Compatibility Zone D and E would require an Airspace review by the ALUC and FAA for objects greater than 100 feet. A Deed Notice would be required for developments within Compatibility Zone C and D. Upon compliance with maximum usage intensity and applicable development conditions (Deed Notice and Airspace Review), impacts would be less than significant.

As the Specific Plan would permit development of various uses, including light and heavy industrial uses, there is the potential for hazardous material storage. According to the ALUCP, Compatibility Zone C only permits the storage of fuel or hazardous subs tances in underground storage tanks and above ground storage of 6,000 gallons or less of non -aviation flammable materials. Any storage of other hazardous materials other than those listed are not permitted unless no other feasible alternative site exists, and the development is designed in a manner that minimize its susceptibility to damage from an aircraft accident.

Compatibility Zone D and E does not have any hazardous material storage requirements. As such, developments within Planning Areas 1, 4, and 5 would be required to comply with the hazardous material storage requirements outlined in the ALUCP. With compliance with such requirements, a less than significant impact would occur.

As shown in Exhibit 2B and Exhibit 3F of the ALUCP, the Specific Plan area is not located within the noise contours of the airport. As the Specific Plan area is located outside the airport’s 55 CNEL noise contours, 46 aircraft from the airport would not result in excessive noise for workers in the proposed and future industrial buildings. Additionally, according to Table 2C of the ALUCP, industrial and warehouse uses are permitted within the 50-55 CNEL range. As such, a less than significant impact would occur.

Potential Impact: Project implementation could create a significant hazard to the public or environment through interference with an adopted emergency response or evacuation plan.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
No construction or development is proposed as part of the annexation action. As such, the proposed annexation would not result in any adverse alterations to vehicular circulation routes or obstruct public access along adjacent roadways. However, future development within the annexation area may impact emergency response or emergency evacuation in the area. As shown on DEIR Exhibit 5.8 -1, various evacuation routes (SR-14, Avenue D, and Sierra Highway) are located within the annexation area. As such, future development within the annexation area would be required to comply with all applicable City codes and policies related to emergency access, including the California Fire Code and LMC Title 15, Buildings and Construction. Additionally, future development would be required to undergo plan check review with the City and LACFD. Thus, the annexation area would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. Impacts would be less than significant.

Specific Plan Analysis
Construction
Construction-related activities associated with the development of industrial buildings consistent with the NLISP would have the potential to impact an adopted emergency response plan or emergency evacuation plan. Construction associated with the developme nt of proposed and future industrial buildings could result in short-term temporary impacts to street traffic along 20th Street West, 10th Street West, Avenue F, Avenue E, and Avenue D. Of these listed roadways, the City identifies Avenue D as an evacuation route; refer to DEIR Exhibit 5.8 -1. In order to ensure emergency access is maintained during the construction activities consistent with the NLISP, project applicants would be required to implement traffic control plans, temporary signing and striping plans, and other construction related traffic measures as conditions of approval, and would be applied to individual project s as deemed necessary by the City Engineer. As such, construction-related activities would result in a less than significant impact.

Operations
Operation of the developments within the Specific Plan area would not result in any adverse alterations to vehicular circulation routes or obstruct public access along adjacent roadways. Additionally, all development within the Specific Plan area would be required to comply with all applicable City codes and policies related to emergency access, including the California Fire Code. Thus, 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. 47 Potential Impact: Project implementation could expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fire.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
As shown in Figure 4 -11, Wildfire Hazards, of the General Plan Safety Element, the annexation area is located within an area identified as a moderate fire hazard severity zone. However, no construction or development is proposed as part of the annexation action. As such, the proposed annexation itself would not introduce new wildland fire risks. Existing structures within the annexation area would continue to comply with federal, State, and local regulations, standards, and guidelines related to wildfires. Further, construction and operation of future development within the annexation area would be subject to compliance with existing federal, State, and local regulations, standards, and guidelines related. Impacts would be less than significant.

Specific Plan Analysis
As shown in Figure 4 -11, Wildfire Hazards, of the General Plan Safety Element, the Specific Plan area is located within an area identified as a moderate fire hazard severity zone. The NLISP would permit a maximum total building area of 38.5 million sf of various permitted uses. As such, future buildout of the Specific Plan area would expose structures and employees to wildfire risks during construction and operation. Nevertheless, similar to the proposed annexation area, implementation of the NLISP would comply with applicable federal, State, and local regulations, standards, and guidelines related to wildfires.

Impacts would be less than significant.

Project Impact: Project implementation, combined with other related projects, could create a significant hazard to the public or environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Cumulative projects could result in the increase in the potential for accidental conditions, particularly during site disturbance and demolition activities; the transport, use or disposal of hazardous materials, conflicts with adopted airport land use plans; interference with evacuation plans; and wildfire. However, with compliance with applicable laws and regulations, including those of DTSC, CalEPA, Cal/OSHA, and HHMD, these impacts would be minimized. Compliance with all applicable Federal and State laws and regulations related to the use, storage, and/or transport of hazardous substances/materials would reduce the likelihood and severity of accidents. Additionally, all projects would be required to comply with the most recently adopted California Fire Code and no projects, including cumulative development projects, would alter roadways in ways that would create public hazards.

With implementation of Mitigation Measures HAZ -1 through HAZ -4, the proposed project would not contribute to a cumulatively considerable impact pertaining to accidental conditions and impacts would be reduced to less than significant levels.
48 I. POPULATION AND HOUSING
The thresholds of significance for population and housing impacts are listed in Section 5.9, Population and Housing, on page 5.9-7 of the DEIR. Impact analyses were detailed on pages 5.9-8 through 5.9-13.

Potential Impact: Project implementation could induce substantial unplanned population growth in an area, either directly or indirectly.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
Based on the Antelope Valley Westside Annexation and Specific Plan Project VMT Analysis (VMT Analysis), prepared by Fehr & Peers, dated March 5, 2025 (refer to DEIR Appendix 11.9, VMT Analysis), buildout of the annexation area (excluding the Specific Plan area) would introduce up to 4,865 residents, 1,837 dwelling units, and 11,690 jobs into the City.

The City’s General Plan was adopted in 2009 and includes General Plan buildout assumptions for a 2030 buildout year. The General Plan buildout assumptions include buildout of the City’s sphere of influence , which includes the annexation area. As such, DEIR Table 5.9-5, Proposed Annexation Buildout Compared to General Plan Buildout, compares the anticipated population, housing, and employment growth associated with the proposed annexation with that of the General Plan buildout. As indicated in DEIR Table 5.9-5, the anticipated population, housing, and employment growth generated by the proposed annexation buildout would be within the General Plan buildout assumptions for the 2030 buildout year.

DEIR Table 5.9 -6, Proposed Annexation Buildout Compared to SCAG Growth Forecasts , compares the annexation’s anticipated population, housing, and employment growth with SCAG population, housing, and employment forecasts for 2050 for the County and City. As indicated in DEIR Table 5.9 -6, the anticipated population, housing, and employme nt growth generated by the proposed annexation buildout would be within the SCAG’s 2050 growth projections for the County. Additionally, the anticipated population and housing growth generated by the proposed annexation buildout would be within the SCAG’s 2050 growth projections for the City; however, anticipated growth in employment within the City would exceed SCAG projections. Nonetheless, as the annexation area is currently located within unincorporated Los Angeles County, and annexation buildout would be within the employment growth projections for the County, employment growth associated with the annexation would result in less than significant impacts.

The jobs/housing ratio is used as a general measure of balance between a community’s employment opportunities and the housing needs of its residents. As of 2024, the City’s jobs/housing ratio is approximately 1.05. According to the General Plan, the City’s jobs/housing ratio is anticipated to decrease to approximately 0.88 by 2030. Based on SCAG growth projections, the City’s jobs/housing ratio is anticipated to decrease to approximately 0.98 by 2050. Based on existing 2024 data, the annexation buildout would increase the City’s jobs/housing ratio from 1.05 to 1.24. As such, the proposed annexation would increase the City’s jobs/housing ratio, while maintaining the healthy 1.0 to 1.5 range identified above. As such, the growth induced by annexation would not be significant enough to indirectly cause unplanned population growth. Overall, the proposed annexation would provide beneficial impacts related to employment in the City and improve the jobs/housing balance, providing the residents with more 49 opportunities to work within the community (rather than commuting to neighboring cities or the Los Angeles basin), and would not be causing significant unplanned population growth.

All future development within the annexation area would be subject to review and would include mitigation, as appropriate, to not induce substantial unplanned population growth. Thus, the proposed annexation would not induce substantial unplanned population growth. Impacts would be less than significant.

Specific Plan Analysis
Buildout of the NLISP would allow up to 38.5 million sf of industrial development, which is anticipated to generate up to 19,358 jobs; refer to DEIR Appendix 11.9. It should be noted that estimating relocation would be speculative given that many personal factors influence personal housing location decisions (i.e., family income levels and the cost and availability of suitable housing in the local area); there is also an expectation that existing residents would be a portion of the workforce. Based on the average person per household ratio of 2.8, NLISP buildout has the potential to introduce up to 54,202 new residents.

The General Plan buildout assumptions include buildout of the City’s SOI, which includes the Specific Plan area. As such, DEIR Table 5.9 -7, Proposed NLISP Buildout Compared to General Plan Buildout , compares the project’s anticipated population and employment growth with the General Plan buildout. As indicated in DEIR Table 5.9-7, the anticipated population growth generated by the proposed NLISP buildout would be within the General Plan buildout ass umptions for 2030, but employment growth would exceed the General Plan assumptions for the 2030 buildout year.

DEIR Table 5.9-8, Proposed NLISP Buildout Compared to SCAG Growth Forecasts , compares the NLISP’s anticipated population and employment growth with SCAG forecasts for 2050. As indicated in DEIR Table

5.9-8, the anticipated population and employment growth generated by the proposed NLISP buildout would exceed the SCAG 2050 growth projections for the City. However, the anticipated population and employment growth generated by the proposed NLISP buildout would be within the SCAG’s 2050 growth projections for the County. Overall, as the Specific Plan area is currently located within unincorporated Los Angeles County, and NLISP buildout would be within the employment growth projections for the County, population and employment growth associated with the NLISP would result in less than significant impacts.

As discussed above, the City’s current jobs/housing ratio is approximately 1.05. By generating approximately 19,358 jobs, the proposed NLISP would increase the City’s jobs/housing ratio to 1.4, which maintains the healthy 1.0 to 1.5 range identified above. According to the General Plan, the City’s jobs/housing ratio is anticipated to decrease to approximately 0.88 by 2030. Based on SCAG growth projections, the City’s jobs/housing ratio is anticipated to decrease to approximately 0.98 by 2050. As such, the General Plan and SCAG projections show an unhealthy decline in the employment opportunities.

Buildout of the proposed NLISP would result in a beneficial impact related to employment in the City and improve the City’s overall jobs/housing balance.

As the Specific Plan area is currently located within the County, anticipated NLISP buildout would be within regional population and employment growth forecasts for the County, NLISP buildout would result in less than significant impacts regarding unplanned population growth. Thus, the proposed NLISP would not induce substantial unplanned population growth. Impacts would be less than significant.

50 Project Buildout Analysis
DEIR Table 5.9-9, Proposed Project Buildout Compared to General Plan Buildout, compares the project’s total buildout potential (annexation buildout plus NLISP buildout) to the General Plan full buildout projections. As indicated in DEIR Table 5.9 -9, total project buildout would remain within General Plan population and housing projections for the City and would exceed General Plan employment projections for the City. While total project buildout would result in an increase in the jobs/housing balance from 1.05 to 1.55, which slightly exceeds the healthy range of 1.0 to 1.5, the General Plan anticipates the City’s jobs/housing ratio to decrease to approximately 0.88 by 2030. As such, the project’s employment generation would result in a beneficial impact related to employment in the City and improve the City’s overall jobs/housing balance. Therefore, project buildout would result in less than significant impacts regarding substantial unplanned population growth.

Potential Impact: Project implementation, combined with other cumulative development projects, could induce substantial unplanned population growth in an area, either directly or indirectly.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Cumulative projects within Lancaster could introduce new residents and businesses and result in cumulative population growth in the City. Therefore, cumulative projects could induce substantial unplanned population growth. Additionally, it should be noted that estimating the number of employees who would relocate to a particular jurisdiction based on job location is speculative given that many personal factors influence personal housing location decisions (i.e., family income levels and the cost and availability of suitable housing in the local area). There is also the potential that future jobs generated by the cumulative projects would be filled by existing residents already living in the City.

As stated, the proposed project would result in less than significant impacts regarding substantial unplanned population growth. Thus, the proposed project would not contribute to a cumulatively considerable impact and impacts would be less than significant.

J. PUBLIC SERVICES AND RECREATION
The thresholds of significance for public services and recreation impacts are listed in Section 5.10, Public Services and Recreation , on page 5. 10-15 of the DEIR. Impact analyses were detailed on pages 5. 10-15 through 5.10-23.

Potential Impact: Project implementation could result in the need for additional fire protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives.

Finding: The City hereby makes Finding 1.

51 Facts in Support of Findings:

Annexation Analysis
Future development within the annexation area would result in the need for additional LACFD fire protection services. However, it should be noted that the project site is currently served by LACFD.

Further, on-site development, associated with the various existing land uses, is currently permitted in accordance with existing on -site zoning designations. Nonetheless, future development within the annexation area would be subject to all applicable laws, ordinances, and regulations in place for fire protection and emergency services. Specifically, future developments would be required to adhere to the general building standards, fire safety standards, and fire safety provisions outlined in Title 24 of the CCR and LMC Chapter 15.32. Per Title 24 of the CCR, future structures would be required to install applicable fire suppression design features (i.e., fire sprinklers, fire hydrants, emergency access), and would require LACFD site plan review and approval. Future developments would also be required to adhere to LMC Chapter 15.76, Fire Protection Fees, which requires payment of a fire protection fee to the City prior to issuance of a building permit. As detailed in LMC Section 15.76.030, Fire protection fees , payment of the fire protection fees would mitigate impacts of new development on the level of fire service capacity in existing LACFD facilities and ensure that the burdens of financing new capital improvements are borne by all of the development projects benefited thereby. Such fire protection fees would be u sed to finance capital improvements as needed due to increased fire protection demand. Therefore, although the proposed pre-zoning within the annexation area would allow increased development and introduce new land uses in the northern portion of the City, the collection of development impact fees would ensure impacts to fire protection services are less than significant.

Specific Plan Analysis
Buildout of the NLISP could result in indirect population growth as future employees and their families may choose to relocate into the City. Based on the City’s average household size of 3.06, buildout of the NLISP could indirectly introduce up to 59,235 additional residents into the City. As such, buildout of the NLISP would result in an increase in population within the City and generate an increase in demand for fire protection and emergency medical services.

Development associated with the NLISP would be subject to all applicable laws, ordinances, and regulations in place for fire protection and emergency services as discussed above. Specifically, future developments would be required to adhere to LMC Chapter 15.76 which requires payment of a fire protection fee. Overall, impacts to fire protection services would be less than significant.

Potential Impact: Project implementation could result in the need for additional police protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
Future development projects within the annexation area would be reviewed by Lancaster Police Department (LPD) and Los Angeles County Sheriff’s Department (LASD) as part of the site plan review 52 process. Future development projects would also be required to pay the City’s development impact fees (DIFs) in order to finance the capital improvements and operational services which would benefit new development. Payment of the DIFs would ensure that the burdens of financing new capital improvements are borne by all of the development projects benefited thereby. Overall, impacts to police protection services would be less than significant.

Specific Plan Analysis
Future development in accordance with the proposed NLISP would result in the increase in demand for LPD and LASD police protection services and facilities. As stated, future development would be designed in compliance with LMC Chapter 15.08, Building Code, adopts by reference the 2022 CBSC. LMC Chapter

15.08 includes emergency access requirements which would minimize site safety hazards and potential operational impacts to police services. Future development projects would also be required to pay the City’s DIFs in order to finance the capital improvements and operational services which would benefit new development. It should be noted that based on the current LASD Delayed Response Policy, response time for emergent calls for service is 10 minutes; response time for routine (non-emergent) calls for service is 60 minutes; and response time for priority calls for service is 20 minutes. 1 Overall, impacts to police
protection services would be less than significant.

Potential Impact: Project implementation could result in the need for additional school facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable performance objectives.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
As discussed, future development within the annexation area would increase residents and employment within Lancaster. Thus, the proposed annexation would increase demand for Westside Union School District (WUSD), Lancaster School District (LSD), and Antelope Valley Union High School District (AVUHSD) school services.

Pursuant to SB 50, school fees imposed through the Education Code are deemed to be full mitigation for new development projects; thus, payment of school impact fees would offset the cost of providing services for students potentially generated by future pr ojects. Thus, compliance with State and local regulations and payment of school impact fees would ensure impacts to WUSD, LSD, and AVUHSD services are proportionally offset. Impacts would be less than significant.

Specific Plan Analysis
Future development projects within the Specific Plan area would be required to pay a standard development impact fee of $0.62 per square foot of commercial/industrial uses to WUSD, $0.62 per square foot of commercial/industrial uses to LSD, and $0.20 per square foot of industrial use to AVUSHD.

School impact fees imposed through the Education Code are deemed to be full mitigation for new

1 Los Angeles County Sheriff’s Department , Field Operations Directive, 90- 012 Station Desk Procedure/Delayed Response Policy , https://pars.lasd.org/Viewer/Manuals/13233/Content/14194#!, accessed August 11, 2025. 53 development projects. Thus, compliance with State and local regulations would ensure that impacts related to school services are proportionally offset. Impacts would be less than significant.

Potential Impact: Project implementation could result in the need for additional parks and recreational facilities and/or the increased use of existing neighborhood and regional parks such that substantial physical deterioration could occur or be accelerated.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
Future residential development within the annexation area would be required to provide dedication of parkland and/or payment of in -lieu fees and payment of impact fees related to open space pursuant to LMC Section 15.64.070, Park acquisition fee , LMC Section 15.64.080, Park development fee, and LMC Chapter 15.72, Park In -Lieu Fees . Payment of such development impact fees would be required and utilized by the City for maintenance and/or renovating existing facilities. Overall, compliance with the payment of required impact fees would ensure project impacts to parks and recreational facilities would be less than significant.

Specific Plan Analysis
Potential impacts on parks and recreational facilities are typically associated with residential developments or projects with a residential component; as the proposed NLISP would not allow for residential uses, it is not anticipated that direct impacts to parks and recreational facilities would result.

Future light and heavy industrial development associated with the NLISP would not directly increase demand for parks and recreational facilities in a manner that would require the construction of new facilities, the construction of which could cause signif icant environmental impacts. Therefore, given the nature of the anticipated light and heavy industrial development associated with the NLISP, impacts to parks and recreational facilities would be less than significant.

Potential Impact: Project implementation could result in the need for additional public library facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable performance objectives.

Findings: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
Future development within the annexation area would introduce new residents and employment within Lancaster that could increase demand for library services. However, no project -specific construction activities or development projects are currently proposed as part of annexation. Future development projects would be required to pay the City’s DIFs in order to finance the capital improvements and operational services which would benefit new development. Payment of the DIFs would ensure that the 54 burdens of financing new capital improvements are borne by all of the development projects benefited thereby. Overall, impacts to library services would be less than significant.

Specific Plan Analysis
Potential impacts on library services are typically associated with residential developments or projects with a residential component; as the proposed NLISP would not allow for residential uses, it is not anticipated that direct impacts to library services would result. However, future employees and their families may relocate into the City from other jurisdictions and thus, have an indirect impact on nearby library facilities. Overall, future light and heavy industrial development associated with the NLISP would not directly increase demand for library facilities in a manner that would require the construction of new facilities, the construction of which could cause significant environmental impacts. Therefore, given the nature of the anticipated light and heavy industrial development associated with the NLISP, impacts would be less than significant.

Potential Impact: The proposed project, in conjunction with cumulative development, could result in cumulatively considerable impacts to fire, police, schools, libraries and recreational facilities/parks.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Fire Protection
Similar to future development within the project site, cumulative projects could increase the demand for additional LACFD resources (e.g., additional staffing, equipment, and expanded/new facilities, etc.).

Cumulative projects would be subject to all applicable laws, ordinances, and regulations in place for fire protection and emergency services, including Title 24 of the CCR regarding fire suppression standards for new development. Additionally, in conformance with LMC Chapter 15.76, cumulative development s would also be required to pay fire protection fees to mitigate impacts on existing LACFD services and resources.

As discussed above, future development in accordance with the proposed project would result in less than significant impacts to LACFD services upon compliance with applicable regulations and payment of fire protection fees. Therefore, the proposed project would not result in cumulatively considerable impacts to fire protection services.

Police Protection
Similar to future development within the project site, cumulative projects could have the potential to result in the need for additional LPD and LASD resources (e.g., additional staffing, equipment, and expanded/new facilities, etc.). However, cumulative projects would be subject to LPD and LASD site plan review and approval.

As discussed above, future development in accordance with the proposed project would result in less than significant impacts to LPD and LASD services upon conformance with all applicable laws, ordinances, and regulations in place for police protection services. Therefore, the proposed project would not result in cumulatively considerable impacts to police protection services. 55 Schools
Cumulative projects within the WUSD, LSD, and AVUHSD school boundaries would introduce new development that could increase demands for WUSD, LSD, and AVUHSD services. However, cumulative projects would be required to pay the statutory school fees to the appropriate school district based on the type and size of development proposed pursuant to SB 50. Payment of school impact fees is considered full mitigation for a project’s impacts associated with the need to provide new or altered school facilities to serve new students generated by future development.

As discussed above, future development in accordance with the proposed project would result in less than significant impacts to school services following conformance with the applicable laws, ordinances, and regulations in place for school services as discussed above. Therefore, the proposed project would not result in cumulatively considerable impacts to school services.

Libraries
Cumulative projects would introduce new development that could increase demands for LA County Library services. However, cumulative projects would be required to adhere to all applicable laws, ordinances, and regulations pertaining to parks and recreational facilities within the City.

Future development in accordance with the proposed project would result in less than significant impacts to library services upon conformance with all applicable laws, ordinances, and regulations in place.

Therefore, the proposed project would not result in cumulatively considerable impacts to library services.

Parks and Recreation
Cumulative projects could introduce new development that increases demands for parks and recreational facilities provided by the City of Lancaster. However, cumulative projects would be required to adhere to all applicable laws, ordinances, and regulations pertaining to parks and recreational facilities within the City, including the dedication of parklands or payment of park in-lieu fees to offset any potential increase in demand for City parks and recreational facilities.

Future development in accordance with the proposed project would result in less than significant impacts to existing City parks and recreational facilities. Therefore, the proposed project would not result in cumulatively considerable impacts to parks and recreational facilities.

K. UTILITIES AND SERVICE SYSTEMS
The thresholds of significance for Utilities and Service Systems are listed in Section 5. 11, Utilities and Service Systems, on page 5. 11-18 of the DEIR. Impact analyses were detailed on pages 5. 11-18 through

5.11-35.

Potential Impact: Project implementation could have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years, and would not require or result in the construction of new water supply facilities or expansion of existi ng facilities, the construction of which could cause significant environmental effects.

Finding: The City hereby makes Finding 1.
56 Facts in Support of Findings:

Water Supply and Distribution
Annexation Analysis
Future developments will be required to demonstrate adequate water supply with a signed Water Availability Form, “Will-Serve” letter, or some other confirmation that existing water supply is sufficient to accommodate the development. All future development will also be required to comply with all applicable State and local regulations and policies related to water supply and infrastructure. Future projects within the annexation area would also be required to annex into the LACWD 40 system if located in proximity to LACWD infrastructure; if too far, future projects could potentially remain on water wells if desired. Thus, the potential water supply and infrastructure impacts is less than significant.

Specific Plan Analysis
Future development within the Specific Plan area would require the construction of new or expanded water utility infrastructure. Buildout of the NLISP (including industrial uses, irrigation use, and Leisure Lakes Mobile Estates) would result in a water demand of approximately 7,921,271.6 gallons per day. As detailed in DEIR Table 5.11 -6, LACWD 40 Normal Year Water Supply and Demand Comparison, through DEIR Table 5.11-8, LACWD 40 Multiple Dry Years Water Supply and Demand Comparison, LACWD 40 would have sufficient water supplies to serve buildout of the NLISP and existing customers during normal, single dry-year, and multiple dry-year scenarios through 2045 by utilizing the process to secure fully reliable new water supplies, outlined in the New Water Supply Acquisition MOU with the Antelope Valley -East Kern Water Agency (AVEK). In a single dry- year scenario, AVEK would meet LACWD 40’s water demand by pumping groundwater from its banked supplies. As individual projects are developed, their specific demands wou ld be assessed, and resources allocated to maintain a balanced and sustainable water supply. It is the responsibility of future project applicants/developers to secure water supplies from LACWD 40 for new developments.

It should be noted that the Specific Plan area is not currently served by existing LACWD 40 facilities and would require annexation into the LACWD 40 service area. As part of the project, all areas south of Avenue D, including the entire Specific Plan area, would be annexed into LACWD 40’s service area. Future development would be required to comply with all applicable State and local regulations and policies related to water supply and infrastructure. Specifically, future development would be required to adhere to Title 20 of the CCR and implement water efficiency design standards. New development within the Specific Plan area would be required to construct underground water service lines on -site to connect to LACWD 40’s existing water conveyance network in the region. Water connections to off -site water lines would be established through coordination between future project applicants, the City, and LACWD 40.

Future developments would be required to demonstrate adequate water supply with either a signed Water Availability Form or “Will-Serve” letter, as applicable. Adherence to State and local regulations would reduce potential water supply and infrastructure impacts to less than significant levels.

Potential Impact: Project implementation could 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.

Finding: The City hereby adopts Finding 1.
57 Facts in Support of Findings:

Annexation Analysis
While there are currently only septic systems in the annexation area, it is possible that the City could extend wastewater services into the annexation area in the future as more development occurs. As such, future development within the annexation area would be required to either connect to existing septic systems on-site, install new septic systems, or connect to the City’s wastewater network. It should be noted that existing uses, currently connected to existing septic systems, would not be required to connect to the City’s wastewater network. The use of septic tanks in the City is regulated by LMC Section 16.24.210, Use of septic tanks, which allows the use of on-site septic systems in nonurban residential areas as defined by the General Plan. Only new developments located within 200 feet of existing wastewater infrastructure would be required to connect to the City’s wastewater network . Additionally, the 2022 CPC contains plumbing design and construction standards related to septic tanks. The standards protect against hazards that may arise from the use of plumbing piping and systems by regulating and controlling the design, construction, installation, quality of materials, location and operation of plumbing piping systems within the State. Specifically, septic tank systems are required to meet design criteria, distance requirements, and capacity standards outlined in Appendix H, Private Sewage Disposal System, of the 2022 CPC.

Additionally, new septic tank systems would also be required to meet design cri teria and soil absorption capacities that are compatible with existing on-site soils.

According to the Notice of Preparation (NOP) comment letter from LACSD, the Lancaster Water Reclamation Plant has the capacity to treat 18 million gallons of wastewater per day and currently has an average recycled flow of 13 million gallons of wastewater per day; refer to DEIR Appendix 11.1, NOP and Comment Letters. Future developments within the annexation area also have the option to connect to the City’s wastewater network, which connects to existing regional trunk sewer pipelines in the project area.

As such, future development within the annexation area would be required to install underground wastewater utility connections and pay sewer connection fees, pursuant to LMC Section 13.08.060, Connection to public sewer – Payment of fees required , and LACSD requirements, to offset impacts associated with increasing wastewater flow into the City’s/LACSD’s wastewater collection and treatment networks. Upon compliance with existing State and local regulations, impacts associated with the proposed annexation would be less than significant.

Specific Plan Analysis
Future development within the Specific Plan area would connect to the City’s wastewater network via an existing sanitary trunk sewer line located in 20th Street West, along the western boundary of the Specific Plan area; refer to DEIR Exhibit 3-9. The existing sanitary sewer main would provide points of connection along 20th Street West at Avenue D, Avenue E, and Avenue F. There is also an option to install an off-site sanitary sewer line (i.e., off-site from the Specific Plan area but within the larger ann exation area) to connect to the existing 20th Street West sewer line at Avenue G; refer to DEIR Exhibit 3-9. Future on-site planned sewer lines would occur within Avenue D, Avenue E, Avenue F, the southern section of 10th Street West between Avenue F and Avenue F-8, and within the common border of Planning Areas 6 and

7. According to an NOP comment letter from LACSD, the NLISP would allow up to 38.5 million sf of industrial development, which is expected to generate approximately 963,275 gallons of wastewater per day; refer to DEIR Appendix 11.1. Wastewater generated withi n the Specific Plan area would be treated at the 58 Lancaster Water Reclamation Plant. The Lancaster Water Reclamation Plant has the capacity to treat 18 million gallons of wastewater per day and currently treats an average recycled flow of 13 million gallons of wastewater per day. As such, the Lancaster Wa ter Reclamation Plant can accommodate and treat wastewater generated by NLISP buildout without exceeding existing capacities.

Future development within the Specific Plan area can connect to the City’s local sewer pipelines, which flow to an existing LACSD regional trunk sewer pipeline located along 20th Street West. As such, future development within the Specific Plan area would be required to pay sewer connection fees pursuant to LMC Section 13.08.060, Connection to public sewer – Payment of fees required, and LACSD requirements, to offset impacts associated with increasing wastewater flow into the City’s/LACSD’s wastewater collection and treatment networks. Further, if industrial waste is disposed into the public sewer system, applicable City permits would be required for each connection discharging industrial waste to the public sewer system as outlined in LMC Section 13.08.680, Permit – Required when. Upon compliance with existing State and local regulations, impacts would be less than significant.

Potential Impact: The project could require the construction of new storm water drainage facilities or the expansion of existing facilities.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Refer to DEIR Section 5.7, Hydrology and Water Quality, for a detailed discussion on the potential for the proposed project to create or contribute stormwater runoff that could exceed the capacity of existing or planned stormwater drainage systems.

Annexation Analysis
Future development within the annexation area would be constructed on predominately vacant, undeveloped land, and would generally result in an increase in impervious surfaces and stormwater runoff in the area. As stated, the annexation area does not have a ny existing City storm drain infrastructure.

However, the City plans a regional storm drain (sized for 50 -year storm events) (i.e., regional earthen channel) in the southwestern portion of the annexation area, west of SR -14 (i.e., near the northwestern corner of the Avenue F and SR -14 intersection). Additional planned regional storm drains (sized for 50 - year storm events) (i.e., regional earthen channels and reinforced concrete pipes) and planned outlet/energy dissipators are located off-site in existing City limits near the southern boundary of the annexation area.

If construction activities associated with future development disturb less than one acre of land, compliance with the City’s SWMP is required to minimize stormwater runoff volumes. If construction activities are anticipated to disturb more than one acre of land, a General Construction Permit under the NPDES program would be required. In compliance with the General Construction Permit, preparation and implementation of a SWPPP, Risk Assessment, and other documentation would be required prior to the commencement of soil disturbing activities. The SWPPP also must include a list of BMPs that would be implemented to reduce and treat stormwater runoff.

Additionally, in compliance with LMC Chapter 16.24, Improvements, Dedications and Reservations, project applicants may be required to submit a hydrology study for applicable developments to verify that proposed streets and existing downstream streets are d esigned to carry a 50 -year storm event, top -of- 59 curb to top -of-curb, and 100-year storm event within the existing right- of-way, among others. As such, upon compliance with existing regulations, future development within the annexation area would result in less than significant impacts.

Specific Plan Analysis
Future development within the Specific Plan area would increase impervious surfaces. Each development within the Specific Plan area would contain its own storm drain and detention system. These systems would be designed during the planning stage of the entitlement process and be specific to the proposed development. The required detention systems would be designed to comply with the City of Lancaster storm water management requirements.

A new channel would be constructed within the Specific Plan area to protect the area from flooding.

Stormwater flow through the channel would be conveyed to the northeast towards Piute Ponds where the flow would overflow back into the existing drainage pat tern. Additionally, future improvements include a 2,125 acre-feet water retention pond within Planning Area 3; refer to DEIR Appendix 11.5. Pond Three would be designed to mitigate the additional stormwater entering Piute Ponds from the channelization of the stormwater along the Amargosa Creek, and additional impervious surfaces associated with future development in the Specific Plan area. Where the proposed channel system terminates, the pre-developed stormwater runoff volume would be maintained to not lessen the amount of natural storm water entering Piute Ponds.

Additionally, future development within the Specific Plan area would require new on -site stormwater infrastructure to adequately collect, treat, and convey project -generated stormwater. The master storm drain system for the Specific Plan area would follow the standards provided in the City’s Master Plan of Drainage; refer to Hydrology Study DEIR Appendix 11.5.

As described above, if construction activities associated with future development within the Specific Plan area disturb less than one acre of land, compliance with the City’s SWMP is required to minimize stormwater runoff volumes. If construction activitie s are anticipated to disturb more than one acre of land, a General Construction Permit under the NPDES program would be required. Additionally, in compliance with LMC Chapter 16.24, project applicants may be required to submit a hydrology study for applicable developments to verify that proposed streets and existing downstream streets are designed to carry a 50 -year storm event, top -of-curb to top- of-curb, and 100 -year storm event within the existing right-of-way, among others. As such, impacts would be less than significant.

Potential Impact: Project implementation could generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impact the attainment of solid waste reduction goals or federal, State, and local management and reduction statutes and regulations related to solid waste.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
Future construction activities would be subject to compliance with relevant federal, State, and local requirements concerning solid waste. Specifically, future development within the annexation area would 60 be required to demonstrate compliance with AB 939, which requires all California cities to “reduce, recycle, and re-use solid waste generated in the state to the maximum extent feasible.” AB 939 requires that at least 50 percent of waste produced is recycled, reduced, or composted. Future development would also be required to demonstrate compliance with the 2022 (and subsequent updates) Green Building Code (CALGreen), which includes design and construction measures that reduce construction -related waste though material conservation measures and other construction-related efficiency measures. Compliance with these programs would ensure short -term construction related solid waste impacts are less than significant.

Operation of future development within the annexation area would generate solid waste that requires disposal at the Lancaster Landfill and Recycling Center and/or Antelope Valley Public Landfill. However, compliance with all applicable federal, State, and local laws, regulations, and standards regarding solid waste disposal, including the mandates of Resource Conservation and Recovery Act (RCRA), AB 939, AB 1826, CALGreen Section 5.408, Construction Waste Reduction, Disposal, and Recycling, LMC Chapter

13.16, Refuse Collection and Disposal (which includes regulations for solid waste management within the City), and LMC Chapter 13.17, Requirements for the Collection and Recycling of Recyclable Materials and Collection and Organics Processing of Organic Material Generated from Commercial Facilities, Multi- Family Dwellings, and Special Events (related to compliance with AB 939, AB 341, and AB 1826 at the local level) would reduce impacts to solid waste disposal. As such, operational impacts would be less than significant.

Specific Plan Analysis
Construction activities associated with future development within the Specific Plan area would generate solid waste. As stated, all construction activities would be subject to conformance with relevant federal, State, and local requirements related to solid waste disposal. Compliance with these programs would ensure construction -related solid waste impacts associated with future development are less than significant.

The NLISP would allow approximately 38.5 million sf of industrial development. Based on a solid waste generation rate of 62.5 pounds per 1,000 sf per day for industrial uses, buildout of the NLISP is expected to generate approximately 2,408,187 pounds of solid waste per day, or approximately 1,205 tons per day.

This represents approximately 23.6 percent of the daily permitted capacity at the Lancaster Landfill and Recycling Center and approximately 21.72 percent of the daily permitted capacity at the Antelope Valley Public Landfill. Thus, solid waste generated by the NLISP buildout would not exceed existing capacities at the Lancaster Landfill and Recycling Center or Antelope Valley Public Landfill.

Additionally, future industrial development in accordance with the NLISP would be required to undergo separate environmental review under CEQA to evaluate project-level impacts to existing landfill capacities for solid waste. Compliance with all applicable federal, State, and local laws, regulations, and standards regarding solid waste disposal, including the mandates of RCRA, AB 939, AB 1826, CALGreen Section 5.408 and LMC Chapter 13.16 (which includes regulations for solid waste management within the City), and LMC Code Chapter 13.17 (related to compliance with AB 939, AB 341, and AB 1826 at the local level) would reduce impacts to solid waste. As such, operational impacts associated with NLISP buildout would not generate solid waste in excess of State or local standards, or in excess of local infrastructure capacity.

Impacts would be less than significant.
61 Potential Impact: The project could result in the relocation or construction of new or expanded dry utility facilities, the construction of which could cause significant environmental effects.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
Future development within the annexation area would occur on predominately vacant, undeveloped land, and would therefore increase use of electricity, natural gas, and telecommunication services within the City. Future developments may be required to constr uct new on- and off-site dry utility connections for electricity, natural gas, and telecommunication services and pay connection and service fees. Construction of new dry utility infrastructure would be subject to compliance with all applicable local, State, and federal laws, ordinances, and regulations. Impacts would be less than significant.

Specific Plan Analysis
Future development within the Specific Plan area would occur on predominately vacant, undeveloped land, and would therefore increase use of electricity, natural gas, and telecommunication services. As shown on DEIR Exhibit 3-10, Dry Utilities Infrastructure Plan, existing dry utility lines are within Avenue D, Avenue E, 10th Street West, and Sierra Highway north of Avenue E. The existing dry utility lines provide points of connection at the intersection of Avenue F and 10th Street West and along Avenue E, and at the common border of Planning Areas 1 and 2. Future planned dry utility improvements would include installing lines within 20th Street West, the southern portions of Sierra Highway (Avenue E to Avenue F - 8), Avenue F, along the common border between P lanning Areas 1 and 2, and within Planning Area 6.

Future planned off-site improvements would include installation of dry utility lines along 20th Street West and Sierra Highway between Avenue F-8 and Avenue H. Additionally, future developments are responsible for the installation of necessary infrastructure within their respective development site within the Specific Plan area, and in the project area, if necessary, to connect to the backbone dry utilities infrastructure illustrated on DEIR Exhibit 3 -10. Construction of new dry utility infrastructure associated with the NLISP buildout would be subject to compliance with all applicable local, State, and federal laws, ordinances, and regulations. Impacts would be less than significant.

Potential Impact: The project, in conjunction with cumulative development, could created increased demand for water, wastewater, storm water, solid waste, and dry utilities services.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Water Supply/Distribution
Cumulative projects could increase demand for water and adversely impact LACWD 40’s existing water supply and facilities. Projects would be required to comply with existing regulations pertaining to water supply and conveyance. For example, related projects would be required to demonstrate adequate water supply with either a signed Water Availability Form or “Will- Serve” letter from the applicable water purveyor. Additionally, payment of standard connection fees would be required to offset project-related 62 impacts to LACWD 40’s water supply and distribution services, which are required to be paid prior to issuance of building permits.

Development within the proposed annexation and Specific Plan areas would increase demand for water supply but would not adversely impact LACWD 40’s existing water supply and facilities. LACWD 40 would continue to have sufficient water supplies to accommodate buildout of the NLISP during normal, single dry-year, and multiple dry -year scenarios through 2045. Future project applicants/developers are responsible for acquiring water supplies from LACWD 40 for new developments. Additionally, adherence to State and local regulations would reduce potential water supply and infrastructure impacts associated with the proposed project to less than significant levels. Thus, the project would not result in cumulatively considerable impacts to water supply and infrastructure. Cumulative impacts would be less than significant.

Wastewater Treatment
Cumulative projects within the City’s wastewater service area could result in increased wastewater generation. However, similar to future development projects within the project site, cumulative projects would be required to comply with federal and local regulations regarding wastewater treatment. As summarized above, future development projects within the annexation Specific Plan areas could increase wastewater generation and require additional wastewater collection and treatment. Buildout in the annexation area could either utilize individual septic tanks or connect to the City’s/LACSD’s wastewater network. Buildout of the Specific Plan area would connect to the City’s/LACSD’s wastewater network and wastewater generated within the Specific Plan area would be adequately accommodated at the Lancaster Water Reclamation Plant. Thus, the project would not result in cumulatively considerable impacts to wastewater treatment facilities. Cumulative impacts would be less than significant.

Stormwater Drainage Facilities
Similar to future development within the project site, cumulative projects would be required to undergo the lead agency’s discretionary review process to determine project -specific impacts to existing storm drainage facilities. Cumulative projects would be required to comply with federal, State, and local regulations and policies. For example, LMC Section 16.24.140, Hydrology study, requires applicable projects to prepare a hydrology study to identify whether existing and/or planned stormwater facilities can adequately accommodate increases in stormwater runoff generated by a project. Additionally, compliance with the City’s SWMP and/or General Construction Permit under the NPDES program would reduce stormwater impacts associated with cumulative projects.

As summarized above, development within the annexation and Specific Plan areas could increase impervious surfaces that require the construction of new storm drainage facilities. Upon compliance with existing regulations, future development within the annexation area would result in less than significant impacts. Proposed channels and Pond Three within the Specific Plan area would accommodate increased stormwater flow from buildout of the Specific Plan area. Future development in the Specific Plan area would also include individual storm drain and detention systems unique to each site plan. Thus, the project would not result in cumulatively considerable impacts to stormwater drainage facilities.

Cumulative impacts would be less than significant.

63 Solid Waste
Cumulative projects would be required to undergo the lead agency’s discretionary review process to determine project- specific impacts related to solid waste generation. Cumulative projects would be required to comply with existing regulations and policies, including AB 939 and AB 341 (related to diverting solid waste from landfills), AB 1826 (related to recycling organic matter), CALGreen Section 5.408, Construction Waste Reduction, Disposal, and Recycling (related to recycling construction and demolition waste), LMC Chapter 13.16, Refuse Collection and Disposal (which includes regulations for solid waste management within the City), and LMC Chapter 13.17, Requirements for the Collection and Recycling of Recyclable Materials and Collection and Organics Processing of Organic Material Generated from Commercial Facilities, Multi-Family Dwellings, and Special Events (related to compliance with AB 939, AB 341, and AB 1826 at the local level).

As summarized above, construction and operational activities associated with development within the proposed annexation and Specific Plan areas could generate solid waste. However, compliance with all applicable federal, State, and local laws, regulations, and standards would reduce potential impacts associated with the proposed annexation to solid waste generation. Additionally, solid waste generated by buildout of the NLISP would be adequately accommodated by the Lancaster Landfill and Recycling Center and Antelope Valley Public Landfill without exceeding existing capacities. Thus, the project would not result in cumulatively considerable impacts.

Dry Utilities
Similar to future development within the project site, cumulative projects may increase demand for electricity, natural gas, and telecommunication services. However, cumulative developments would be required to pay applicable connection and service fees to SCE, SCG, Race Communications, and Spectrum to receive electricity, natural gas, and telecommunication services, respectively.

As summarized above, development within the proposed annexation and Specific Plan areas could increase demand for dry utility services that could cause a significant environmental impact. However, construction of new dry utility infrastructure within the annexation area would be subject to compliance with all applicable local, State, and federal laws, ordinances, and regulations. Additionally, future planned dry utility improvements, as part of NLISP buildout, would include installing lines within 20th Street West, the southern portions of Sierra Highway, Avenue F, along the common border between Planning Areas 1 and 2, and within Planning Area 6. Future planned off-site improvements would include installation of dry utility lines along 20th Street West and Sierra Highway between Avenue F -8 and Avenue H. Thus, the project would not result in cumulatively considerable impacts that increase demand for dry utility services that could cause a significant environmental impact. Cumulative impacts would be less than significant.

L. TRANSPORTATION
The thresholds of significance for transportation impacts are listed in Section 5. 12, Transportation, on pages 5.12-10 and 5.12-11 of the DEIR. Impact analyses were detailed on pages 5.12-12 through 5-12-22.

Potential Impact: Project implementation could conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. .

Finding: The City hereby makes Finding 1.
64 Facts in Support of Findings:

Annexation Analysis
No construction or development is proposed as part of the annexation action; thus, it is speculative to determine potential transportation policy impacts at this programmatic level of analysis. Future developments in accordance with the proposed pre-zones would be required to comply with all applicable City codes and policies related to transit, bicycle, and pedestrian facilities (e.g., General Plan, Master Plan of Trails and Bikeways, Master Plan of Complete Streets, Local Transportation Assessment Guidelines, and LMC Chapter 12.12 and Sections 15.64.040 and 15.64.050, etc.). Thus, impacts associated with the annexation would be less than significant.

Specific Plan Analysis
Roadway Improvements
The Circulation and Access Plan within the proposed NLISP describes the backbone circulation network within the Specific Plan area. As shown on Exhibit 3 -5, Vehicular Circulation and Access Plan, vehicular roadways are planned to be designated as major arterials (Avenue D, Avenue E, Avenue F, 10th Street West, 20th Street West, and Sierra Highway) and secondary arterials (Avenue F-8).

Per the Local Transportation Assessment Guidelines, a Local Transportation Assessment (LTA) was prepared for the project to analyze potential circulation system deficiencies that may result from project implementation. The LTA identified improvements neces sary to provide or maintain site access and acceptable peak hour LOS, including stop control, traffic signals, roadway striping/restriping, turn lanes, and additional queuing space. Final street design, intersection design, intersection spacing, intersecti on right-of-way, and traffic controls would be required to conform to the City’s Roadway Standards as well as LMC Chapter 12.12. Upon implementation of the LTA recommendations, as well as payment of traffic impact and traffic signalizations fees per LMC Se ctions 15.64.040 and 15.64.050, impacts regarding roadway improvements would be less than significant.

Multi-Modal Transportation
The NLISP provides for a network of sidewalks and bicycle lanes within the roadway right-of-way; refer to DEIR Exhibit 3 -6, Non-Vehicular Circulation and Access Plan. As illustrated, meandering sidewalks are planned along all major and secondary arterial roadways. The non-vehicular transportation improvements within the Specific Plan area would ultimately connect to the existing City and County bicycle and trail system. Additionally, bicycle access would be permitted within the major and secondary arterials right-of- way within the Specific Plan area. Bicycle lane delineation for future development within the Specific Plan area would be dependent on the adjacent buildings or uses development review approval. Future development projects within the NLISP would be responsible for constructing sidewalks and bicycle lane facilities in the public right-of-way as part of the project’s roadway frontage improvement requirements.

As described above, the Specific Plan area is not immediately served by transit facilities. However, the City and Antelope Valley Transit Agency (AVTA) may assess the potential demand for transit facilities in the area as NLISP buildout occurs and may establish new or extended routes.

Overall, with adherence to existing regulations and incorporation of associated improvements, the proposed NLISP would not conflict with the circulation system and impacts would be less than significant. 65 Potential Impact: Project implementation could conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b).

Findings: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
As shown in DEIR Table 5.12 -2, Cumulative Year (2040) VMT Summary , the Total VMT and Home-Based Work VMT would exceed the City’s VMT thresholds under the cumulative year (2040) condition, resulting in a potential VMT impact. As development occurs in the annexation area, subsequent project-level VMT analyses would be req uired to determine the amount of VMT that needs to be mitigated. The VMT Mitigation Program allows developers to pay $150 per VMT exceeded to mitigate potentially significant VMT impacts and tier off of the Program EIR. In lieu of payment to the VMT Mitiga tion Program, developers may implement project design features and California Air Pollution Control Officers Association (CAPCOA) strategies to reduce project- specific VMT to at least 15 percent below baseline VMT. As the annexation area is developed, future projects that do not screen out of a VMT analysis and that would result in potentially significant VMT impacts would be required to implement Mitigation Measure TRA -1, which provides the option of payment into the City’s VMT Mitigation Program, or implementation of project design features and CAPCOA strategies to reduce project-specific VMT to at least 15 percent below baseline VMT. As detailed in the DEIR, the VMT Mitigation Program was developed utilizing a list of unfunded, planned infrastructure proj ects identified within many existing planning documents. The identified infrastructure projects which could directly contribute toward reducing Citywide VMT and could be funded by the program include, but are not limited to, new and widened sidewalks, medians, multipurpose paths, crosswalks, pedestrian refuge islands, curb pop -outs, flashing beacons, a variety of traffic calming measures (speed humps), and traffic circles. Therefore, following implementation of Mitigation Measure TRA-1, buildout of the annexation area would result in a less than significant impact regarding VMT.

Specific Plan Analysis
The VMT impacts of future buildout of the remainder of the Specific Plan area (i.e., Planning Areas 1, 3, and 5), were analyzed cumulatively with buildout of the annexation area; as described above in the Annexation Analysis. Development in these planning areas would be subject to Mitigation Measure TRA- 1 as well in order to reduce VMT impacts to less than significant levels.

Planning Areas 2, 4, 6 (east), 7, and 8 Analysis
As shown in DEIR Table 5.12-3, Project VMT and VMT Threshold for Non-Residential Projects in Lancaster, buildout of Planning Areas 2, 4, 6 (east), 7, and 8 of the NLISP would generate 14.6 Home -Based Work VMT per employee. In comparison to the City’s threshold of 15 percent below Baseline VMT of the AVPA, the Project is 7.1 Home- Based Work VMT per employee higher. As such, development of the proposed

11.3 million sf of industrial warehouse use in Planning Areas 2, 4, 6 (east), 7, and 8 would require payment into the City’s VMT Mitigation Program to reduce impacts related to VMT; refer to Mitigation Measure TRA-1.
66 Potential Impact: Project implementation could substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections, etc.) or incompatible uses (e.g., farm equipment, etc.).

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
Future development projects would be required to comply with all applicable City codes and policies regarding geometric design hazards or incompatible uses, including the California Fire Code and LMC Title 15, Buildings and Construction. Any future roadway improvements within the annexation area would also be required to comply with existing City standards related to street improvements. Specifically, LMC Chapter 12.12, requires street improvements (e.g., curbs, gutters, sidewalks, streetlights, paving, etc .) installed along the frontage of any lots or parcels improved with new or expanded structure(s) to conform to the City’s Public Works Department standards and specifications. Additionally, future development projects within the annexation area would be required to undergo plan check review with the City and Los Angeles County Fire Department. Thus, impacts associated with the annexation regarding geometric design hazards or incompatible uses would be less than significant.

Specific Plan Analysis
Vehicular roadways are planned to be designated as major arterials (Avenue D, Avenue E, Avenue F, 10th Street West, 20th Street West, and Sierra Highway) and secondary arterials (Avenue F-8). To provide safe and efficient access, the proposed transportation improvements would include several safety features, including stop control, traffic signals, roadway striping/restriping, turn lanes, and additional queuing space. As such, the project would not create a significant traffic -related safety hazard. The pro ject roadways, ingress and egress, and interior circulation routes would be designed and constructed consistent with Los Angeles County Fire Department requirements.

There are no incompatible land uses proposed as part of the NLISP; any existing incompatible uses on-site or in the vicinity of the project site that would result in a potential significant traffic safety hazard, would be removed prior to project implementation. Therefore, potential impacts associated with design hazards would be less than significant.

Potential Impact: Project implementation could result in inadequate emergency access.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
As shown on Exhibit 5.8-1, Evacuation Routes, of the DEIR Avenue D, SR-14, and Sierra Highway within the annexation area are designated evacuation routes. As such, future construction associated with development within the annexation area may result in partial temporary lane closures along these roadways. Following Site Plan Review, future development projects determined to have a potentially significant impact on emergency access would be required to prepare and implement a Traffic 67 Management Plan (TMP) as a project condition of approval to maintain vehicular traffic flow, bicyclist and pedestrian access, and emergency access during the construction process. The TMP would be required to include potential measures such as construction signage, limitations on timing for lane closures to avoid peak hours, temporary striping plans, and the use of a construction flag person to direct traffic during heavy equipment use, among other measures.

As stated, no construction or development is proposed as part of the annexation action. However, buildout of the annexation area under the proposed pre-zoning could result in new development, which could impact existing emergency access routes in the area. Future development projects in accordance with the proposed land use designations and pre -zones would be required to comply with all applicable City codes and policies related to emergency access, including the California Fire Code and LMC Title 15.

Additionally, future development projects in accordance with the proposed land use designations and pre-zones would require plan check review with the City and Los Angeles County Fire Department. Overall, impacts related to emergency access would be less than significant.

Specific Plan Analysis
The Annexation analysis provided above is also applicable to the Specific Plan Analysis.

Potential Impact: The project, in conjunction with cumulative development, could conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Cumulative projects could conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. Cumulative projects would be required to undergo project -specific environmental review under CEQA and the City’s discretionary review process. Cumulative projects would also be subject to all applicable policies, plans, and programs related to transit, bicycle, and pedestrian facilities (e.g., General Plan, Master Plan of Trails and Bikeways, Lancaster Local Transportation Assessment Guidelines, Master Plan of Complete Streets, Lancaster Transportation Analysis, and LMC Chapter 12.12 and Sections 15.64.040 and 15.64.050, etc.).

As discussed above, project implementation is not anticipated to result in potentially significant impacts to existing regulations and standards pertaining to pedestrian, bike, and transit services/facilities, upon compliance with applicable State and local regulations and payment of street improvement fees.

Therefore, the proposed project would not result in cumulatively considerable impacts to existing regulations and standards pertaining to pedestrian, bike, and transit services/facilities. The project would not conflict with existing transportation programs and plans and would result in less than significant impacts. Thus, the project’s contribution towards cumulative impacts in conjunction with future buildout of the General Plan and development outlined in Table 4-2 are not cumulatively considerable. Impacts in this regard would be less than significant.

Potential Impact: The proposed project, in conjunction with cumulative development, could conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b).

Finding: The City hereby makes Finding 1.
68 Facts in Support of Findings:

As discussed, the Local Transportation Assessment Guidelines provide recommendations for thresholds of significance for various land use projects regarding impact to VMT. Projects, within the City of Lancaster, that exceed the City’s VMT threshold would be required to pay fair share fees per the City’s VMT Mitigation Program or mitigate their VMT impacts through other acceptable means.

As it was determined that both buildout of the annexation area and NLISP (both individually and combined) would exceed the significance threshold for VMT, implementation of the proposed project, would require future developers to pay VMT impact fees or implement project design features and CAPCOA strategies to reduce VMT impacts in accordance with Mitigation Measure TRA -1. Following implementation of Mitigation Measure TRA -1, the project’s contribution towards cumulative impacts in conjunction with development outlined in DEIR Table 4-2 and General Plan buildout are not cumulatively considerable. Impacts would be reduced to less than significant levels.

Potential Impact: The project, in conjunction with cumulative development, could substantially increase hazards due to a geometric design feature or introduce incompatible uses.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Cumulative projects would be required to comply with existing City standards related to street improvements, including LMC Chapter 12.12. As analyzed above, the proposed project would be required to comply with existing City standards related to street improvements. Therefore, the project would not contribute towards cumulatively considerable impacts with regards to increasing hazards due to geometric design features or introducing incompatible uses. Impacts would be less than significant.

Potential Impact: The project, in conjunction with cumulative development, could result in inadequate emergency access.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Cumulative projects would be required to comply with existing codes and standards, including the California Fire Code and LMC Title 15. As analyzed above, future developments within the annexation area and Specific Plan area would be required to prepare and implement a TMP as a project condition of approval at the City’s discretion, as well as comply with existing codes and standards related to emergency access. Therefore, the project would not contribute towards cumulatively considerable impacts with regards to emergency access. Impacts would be reduced to less than significant levels.

M. AIR QUALITY
The thresholds of significance for air quality impacts are listed in Section 5.13, Air Quality, on pages 5.13- 14 and 5.13-15 of the DEIR. Impact analyses were detailed on pages 5.13-15 through 5.13-61.

Potential Impact: Development associated with implementation of the proposed project could result in localized emissions impacts or expose sensitive receptors to substantial pollutant concentrations. 69 Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
Carbon Monoxide Hotspots
The proposed annexation would not cause excessive CO concentration since the resulting traffic impact would be dispersed over multiple locations. This dispersion helps prevent high concentrations of traffic and associated pollutants in any single area. As shown in DEIR Table 5.13-1, Measured Air Quality Levels, the peak CO concentration at the Lancaster – Division Street monitoring station was 1.380 ppm in 2022, the latest year where data was available. Ambient CO levels are low near the annexation area and the addition of mobile trips generated would not increase ambient CO levels above 7.0 ppm. Additionally, the potential traffic volumes from the annexation area would not result in intensive congestion. Furthermore, future development within the annexation area would be subject to project -specific and site -specific discretionary approvals (including separate CEQA review) on a case -by-case basis and these individual projects would be required to analyze CO emissions associated with construction and operations through project-specific CEQA analysis. Therefore, impacts would be less than significant.

Toxic Air Contaminants
As noted above, implementation of the annexation would not result in direct long-term operation of any stationary sources of toxic air contaminants (TACs) as no specific development is proposed. Further, future development within the annexation area would be subject to project -specific and site -specific discretionary approvals (including separate CEQA review) on a case-by-case basis. Any individual projects that would meet the requirements listed in AVAQMD Rule 1401, New Source Review for Toxic Air Contaminants, would be required to analyze TACs emissions associated with operation of stationary sources through project-specific CEQA analysis.

However, construction of future projects within the annexation area may result in temporary increases in emissions of diesel particulate matter (DPM) associated with the use of off-road diesel equipment. Health- related risks associated with diesel- exhaust emissions are primarily associated with long -term exposure and associated risk of contracting cancer. As such, the calculation of cancer risk associated with exposure of to TACs are typically calculated based on a long -term (e.g., 70-year) period of exposure. Construction of future developments in the annexation area would implement Mitigation Measure AQ -1. Mitigation Measure AQ-1 would require future projects within the proposed annexation area to utilize construction equipment vehicles in proper condition and in tune per manufacturer’s specifications to ensure ozone precursor emissions are reduced. The use of diesel-powered construction equipment, however, would be temporary and episodic and would occur over a relatively large area. In addition, as future projects are proposed within the annexation area, the details of each individual project would be evaluated by the City on a case -by-case basis, and these individual projects would be required to analyze localized emissions associated with construction through project -specific CEQA analysis. For these reasons, exposure to construction-generated DPM would not be anticipated to exceed applicable thresholds (i.e., incremental increase in cancer risk of 10 in one million). As such, impacts from toxic air contam inants would be less than significant.

70 Valley Fever
Nearby sensitive receptors as well as workers could be exposed to Valley Fever from fugitive dust generated during construction of future projects within the annexation area. There is the potential that Coccidioides spores are stirred up during excavation, grading, and earth -moving activities, exposing construction workers and nearby sensitive receptors to these spores and thereby, to the potential of contracting Valley Fever. However, all future development within the annexation area would be required to comply with AVAQMD Rules 401 and 403 (Regulatory Requirement AQ -1) and implement Mitigation Measure AQ-26 that would provide personal protective respiratory equipment to construction workers and provide information to all construction personnel and visitors about Valley Fever. Mitigation Measure AQ-26 would also require the preparation of a Valley Fever Dust Management Plan for review and approval by the Los Angeles County Public Health. Measures included in the Valley Fever Dust Management Plan would ensure that construction workers would be trained on preventing the spread of Valley Fever, provided clean eating areas, prohibited from smoking, positioned upwind or crosswind when excavating, etc. As such, the risk of exposure to Valley Fever would be minimized to a less than significant level. Additionally, the implementation of Regulatory Requirement AQ -1 would minimize dust from potential future construction activity and would not expose nearby sensitive receptors to the Valley Fever fungus. Impacts would be less than significant.

Specific Plan Analysis
Carbon Monoxide Hotspots
In 2003, the SCAQMD as part of its Air Quality Management Plan (AQMP) development process, prepared modeling to determine the potential for CO Hotspots at the four busiest intersections in the air basin. As summarized in the 2003 AQMP, even at one of the busiest intersections at that time, only 0.7 ppm of CO is attributable to vehicular traffic and the remaining 7.7 ppm were due to ambient background conditions.

As shown in DEIR Table 5.13 -1, the background 1 -hour and 8 -hour concentrations are well below th e applicable Air Quality Standards (AAQS). The 2003 AQMP’s findings underscore that CO hotspots are highly unlikely due to the reduced background concentrations and the effectiveness of California's air quality management strategies. The substantial reduction in CO levels from the vehicle fleet and the state’s attainment status for CO further diminish the need for detailed microscale hotspot analyses, reinforcing that existing monitoring and regulatory frameworks adequately address potential air quality concerns. As such, the impacts would be less than significant.

Toxic Air Contaminants
According to the AVAQMD California Environmental Quality Act and Federal Conformity Guidelines (CEQA and Federal Conformity Guidelines), the following project types proposed for sites within the specified distance to an existing or planned (zoned) sensitive receptor land use must be evaluated using significance threshold criteria number (4) (expose s sensitive receptors to substantial pollutant concentrations, including those resulting in a cancer risk greater than or equal to 10 in a million and/or a Hazard Index [HI] [non-cancerous] greater than or equal to 1) regarding sensitive receptors and cancer risk:
• Any industrial project within 1,000 feet of sensitive receptor land use; • A distribution center (40 or more trucks per day) within 1,000 feet; • A major transportation project (50,000 or more vehicles per day) within 1,000 feet; 71 • A dry cleaner using perchloroethylene within 500 feet; and • A gasoline dispensing facility within 300 feet.

As previously discussed, due to the programmatic nature (i.e., lack of stationary source locations, constructions schedule, construction equipment, etc.) of future development in Planning Areas 1, 3, and 5, construction - and operation -related impacts canno t be modeled. Nevertheless, the details of each individual project within Planning Areas 1, 3, and 5 would be evaluated by the City on a case-by-case basis, and these individual projects would be required to analyze localized TAC impacts associated with construction through project-specific CEQA analysis. As such, impacts would be less than significant.

Valley Fever
Any nearby sensitive receptors as well as construction workers could be exposed to Valley Fever from fugitive dust generated during development activities within the Specific Plan area. There is the potential that Coccidioides spores are stirred up during any earth-moving activities, exposing construction workers and nearby sensitive receptors to these spores and thereby, to the potential of contracting Valley Fever.

However, all development within the Specific Plan area would be required to comply with AVAQMD Rules 401 and 403 (Regulatory Requirement AQ-1) during construction and implement Mitigation Measure AQ- 26 that would provide personal protective respiratory equipment to construction workers and provide information to all construction personnel and visitors about Valley Fever. Mitigation Measure AQ -26 would also require the preparation of a Valley Fever Dust Management Plan for review and approval by the Los Angeles County Public Health. Measures included in the Valley Fever Dust Management Plan would ensure that construction workers would be trained on preventing the spread of Valley Fever, provided clean eating areas, prohibited from smoking, positioned upwind or crosswind when excavating, etc. With compliance with AVAQMD Rules and implementation of M itigation Measure AQ-26, dust from construction activity of future development associated with the Specific Plan would be limited and would not expose nearby sensitive receptors to the Valley Fever fungus. Impacts would be less than significant.

Planning Areas 2, 4, 6 (east), 7, and 8 Analysis
Carbon Monoxide Hotspots
In 2003, the SCAQMD as part of its AQMP development process, prepared modeling to determine the potential for CO Hotspots at the four busiest intersections in the air basin. As summarized in the 2003 AQMP, even at one of the busiest intersections at that time, only 0.7 ppm of CO is attributable to vehicular traffic and the remaining 7.7 ppm were due to ambient background conditions. As shown in DEIR Table

5.13-1, the background 1-hour and 8-hour concentrations are well below the applicable AAQS. The 2003 AQMP’s findings underscore that CO hotspots are highly unlikely due to the reduced background concentrations and the effectiveness of California's air quality management strategies. The substantial reduction in CO levels from the vehicle fleet and the state’s attainment status for CO further diminish the need for detailed microscale hotspot analyses, reinforcing that existing monitoring and regulatory frameworks adequately address potential air quality concerns. As such, the impacts would be less than significant.

Toxic Air Contaminants
According to the AVAQMD California Environmental Quality Act and Federal Conformity Guidelines (CEQA and Federal Conformity Guidelines), the following project types proposed for sites within the specified 72 distance to an existing or planned (zoned) sensitive receptor land use must be evaluated using significance threshold criteria number (4) (exposes sensitive receptors to substantial pollutant concentrations, including those resulting in a cancer risk greater than or equal to 10 in a million and/or a Hazard Index [HI] [non-cancerous] greater than or equal to 1) regarding sensitive receptors and cancer risk:
• Any industrial project within 1,000 feet of sensitive receptor land use; • A distribution center (40 or more trucks per day) within 1,000 feet; • A major transportation project (50,000 or more vehicles per day) within 1,000 feet; • A dry cleaner using perchloroethylene within 500 feet; and • A gasoline dispensing facility within 300 feet.

The discussion below analyzes the TAC impacts from construction and operation of the proposed industrial uses within Planning Areas 2, 4, 6 (east), 7, and 8 of the Specific Plan.

Construction Impacts
The land use with the greatest potential exposure to construction DPM source emissions of the proposed developments is Receptor R5 which is located approximately 1,019 feet east of the Planning Area 2 at Mitchell’s Avenue E RV Park (conservatively modeled as a residential receptor) located at 721 West Avenue East. R5 is measured from the private outdoor living area (backyard) facing the Planning Area 2.

Without Mitigation Measure AQ -2, the maximum incremental cancer risk attributable to construction DPM source emissions of the proposed developments is estimated at 0.99 in one million at the maximally exposed individual receptor (MEIR), which is less than the AVAQMD significance threshold of 10 in one million. At this same location, non -cancer risks were esti mated to be less than 0.01, which would not exceed the applicable threshold of 1.0.

With implementation of Mitigation Measure AQ -2, the land use with the greatest potential exposure to construction DPM source emissions of the proposed developments is at Receptor R5 (MEIR). Mitigation Measure AQ-2 requires the diesel-fueled off-road equipment to comply with EPA/CARB Tier 4 standards and be well-maintained. At the MEIR, with mitigation the maximum incremental cancer risk is estimated at 0.48 in one million, which is less than the AVAQMD significance threshold of 10 in one million. At this same location, non -cancer risks were estimated to be less than 0.01, which would not exceed the applicable threshold of 1.0. As such, proposed development within Planning Areas 2, 4, 6 (east), 7, and 8 would not cause a significant human health or cancer risk to adjacent land uses as a result of project construction activity. Although it is not the nearest receptor to Planning Areas 2, 4, 6 (east), 7, and 8, Receptor R5 would experience the highest concentrations of TACs as a result of the proposed developments construction activity due to meteorological conditions (wind speed and direction) in the vicinity of Planning Areas 2, 4, 6 (east), 7, and 8. As such, all other residential receptors in the vicinity of Planning Areas 2, 4, 6 (east), 7, and 8 would be exposed to less emissions and therefore less risk than MEIR identified herein. As such, impacts would be less than significant.

Operational Impacts
Residential Exposure Scenario: The residential land use with the greatest potential exposure to DPM source emissions of the proposed developments is Receptor R5, which is located approximately 1,019 feet 73 east of the Planning Area 2 at Mitchell’s Avenue East RV Park located at 721 West Avenue E. This location was conservatively modeled as a potential residential receptor. R5 is placed in the private outdoor living areas (backyard) facing the Planning Area 2. At the MEIR (Receptor R5), the maximum incremental cancer risk attributable to DPM source emissions of the proposed developments is estimated at 2.42 in one million, which is less than the AVAQMD significance threshold of 10 in one million. At this same location, non-cancer risks were estimated to be less than 0.01, which would not exceed the applicable significance threshold of 1.0. Although it is not the nearest receptor to Planning Areas 2, 4, 6 (east), 7, and 8, Receptor R5 would experience the highes t concentrations of TACs as a result of operational activity due to meteorological conditions (wind speed and direction) in the vicinity of Planning Areas 2, 4, 6 (east), 7, and

8. As such, all other residential receptors in the vicinity of Planning Areas 2, 4, 6 (east), 7, and 8 would be exposed to less emissions and therefore less risk than MEIR identified herein. As such, impacts would be less than significant.

Worker Exposure Scenario: The worker receptor land use with the greatest potential exposure to DPM source emissions of the proposed developments is Receptor R7, which represents the adjacent potential worker receptor approximately 116 feet southeast of Planning Area 2. At the maximally exposed individual worker (MEIW; Receptor R7), the maximum incremental cancer risk impact is 0.59 in one million which is less than the AVAQMD threshold of 10 in one million. Maximum non -cancer risks at this same location were estimated to be less than 0.01, which would not exceed the applicable significance threshold of 1.0.

As such, the proposed developments within Planning Areas 2, 4, 6 (east), 7, and 8 would not cause a significant human health or cancer risk to adjacent land uses as a result of the proposed developments operational activity. Because all other modeled worker receptors are located at a greater distance than the MEIW analyzed herein, and DPM dissipates with distance from the source, all other worker receptors in the vicinity of the proposed developments would be exposed to less emissions and therefore less risk than the MEIW identified herein. As such, the proposed developments would not cause a significant human health or cancer risk to adjacent workers. Therefore, impacts would be less than significant.

School Child Exposure Scenario: Proximity to sources of toxics is critical to determining the impact. In traffic-related studies, the additional non -cancer health risk attributable to proximity was seen within 1,000 feet and was strongest within 300 feet. A one -quarter mile radius, or 1,320 feet, is commonly utilized for identifying sensitive receptors, such as schools, that may be impacted by a proposed project.

This radius is more robust than the 1,000 -foot radius, and therefore provides a more health pro tective scenario for evaluation than the 1,000 -foot impact radius identified above. There are no schools within

0.25-mile of the site of proposed developments. The nearest school is the Mariposa Computer Science Magnet School, which is located approximatel y 9,300 feet south of the site of proposed developments.

Because there is no reasonable potential that TAC emissions would cause significant health impacts at distances of more than 0.25-mile from the air pollution source, there would be no significant impacts that would occur to any schools in the vicinity of Planning Areas 2, 4, 6 (east), 7, and 8.

Construction and Operational Impacts
The land use with the greatest potential exposure to construction and operational DPM source emissions of the proposed developments within Planning Areas 2, 4, 6 (east), 7, and 8 is Receptor R5. At the MEIR (Receptor R5), without Mitigation Measure AQ -2, the maximum incremental cancer risk attributable to construction and operational DPM source emissions of the proposed developments is estimated at 1.95 in one million, which is less than the AVAQMD threshold of 10 in one million. At this same location, non- cancer risks were estimated to be less than 0.01, which would not exceed the applicable threshold of 1.0. 74 With implementation of Mitigation Measure AQ -2, the land use with the greatest potential exposure to construction and operational DPM source emissions of the proposed developments is Receptor R5. At the MEIR (Receptor R5), with mitigation the maximum incre mental cancer risk is estimated at 1.44 in one million, which is less than the AVAQMD significance threshold of 10 in one million. At this same location, non-cancer risks were estimated to be less than 0.01, which would not exceed the applicable threshold of

1.0. As such, the proposed developments within Planning Areas 2, 4, 6 (east), 7, and 8 would not cause a significant human health or cancer risk to adjacent land uses as a result of construction and operational activity. It should be noted that the comb ined construction and operational risk is lower than the operational risk alone as this scenario evaluates the risk for a child that is born at the start of construction, exposed to construction-related emissions for the 5.72-year duration of construction activities, and is then exposed to the proposed developments operational emissions for an additional 24.28 years for a total exposure duration of 30 years. Because risk estimates for construction are relatively low, and exposure that occurs during the earl ier years of life is more heavily weighted, the combined construction and operational risk is lower than the calculated 30 -year operational only risk. All other receptors during construction and operational activity would experience less risk than what is identified for this location.

As such, impacts would be less than significant. DEIR Table 5.13 -12, Summary of Construction, Operational, and Combined Cancer Risk presents the estimated construction, operational, and combined risk for all receptors.

Potential Impact: Project implementation could create objectionable odors affecting a substantial number of people.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
Construction activities associated with future developments may generate detectable odors from heavy- duty equipment exhaust and architectural coatings. However, construction -related odors would be analyzed on a case -by-case basis. In addition, future devel opment within the annexation area would be 75 required to comply with the California Code of Regulations, Title 13, Sections 2449(d)(3) and 2485, which minimizes the idling time of construction equipment either by shutting it off when not in use or by reducing the time of idling to no more than five minutes. This would further reduce the detectable odors from heavy-duty equipment exhaust. Development within the annexation area would also be required to comply with the AVAQMD Regulation XI, Rule 1120 – Asphalt Pavement Heaters, which would minimize odor impacts from ROG emissions during asphalt paving activities. Thus, odors associated with construction activities within the annexation area would be less than significant.

Potential operational odors could be generated from trucks idling exhaust within the annexation area.

These odors would be similar to existing industrial uses throughout the City and would be confined to the immediate vicinity of the new buildings. Industrial uses with potential odor are also typically required to comply with the regulations to minimize the adverse odor impacts. The other potential source of odors would be new waste receptacles located near adjacent properties. The receptacles would be stor ed in areas and in containers, as required by City (Municipal Code Chapter 13.17) and Los Angeles County Health Department regulations, and be emptied on a regular or weekly basis, before potentially substantial odors have developed. The phasing and exact details of each project would be evaluated by the City on a case- by-case basis and each project would be required to analyze potential operational odor impacts. As such, buildout of the annexation area would have a less than significant operational odor impact.

Specific Plan Analysis
Future development within the Specific Plan does not permit or require land uses that would use substantive sources of objectionable odors. Potential temporary and intermittent odors may result from construction equipment exhaust and application of asphalt and architectural coatings. Temporary and intermittent construction-source emissions are controlled through existing requirements and industry BMPs addressing proper storage of and application construction materials. Further, the future development within the Specific Plan would be required to minimize VOC emissions during architectural coating as required by Mitigation Measure AQ -7. Potential operational airborne odors could be created by light/heavy industrial uses within the Specific Plan, such as trucks idling exhaust. However, these odors would be similar to existing industrial uses throughout the City and would be confined to the immediate vicinity of the new buildings. Industrial uses within the Specific Plan area would be required to comply with Mit igation Measures AQ -12, AQ -15, and AQ -16, which reduce exhaust emissions and mitigate substantial adverse odor impacts from trucks idling. Over the life of future development within the Specific Plan, odors may result from storage of municipal solid waste pending its transport to area landfills.

Refuse generated by future development within the Specific Plan would be stored in covered containers and removed at regular intervals in compliance with the City of Lancaster’s solid waste regulations. The development associated with the Specific Plan would also be required to comply with AVAQMD Rule 402.

Based on the preceding, the potential for future development within the Specific Plan to create objectionable odors affecting a substantial number of people is considered less-than-significant. As such, a less than significant impact would occur.

Planning Areas 2, 4, 6 (east), 7, and 8 Analysis
The analysis provided above for the Specific Plan Analysis is also applicable to the Planning Areas 2, 4, 6 (east), 7, and 8 Analysis.

Potential Impact: Project implementation, in conjunction with the related projects, could result in cumulatively considerable odor impacts.
76 Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Odors resulting from the construction activities associated with implementation of the projects that would occur within the City are not likely to affect a substantial number of people, since construction activities occur in a limited area and do not usually emit odors that are considered offensive. Furthermore, individual development projects within the annexation area would occur in incrementally over time and each future project would be evaluated by the City on a case-by-case basis. The individual developments would be required to analyze odors and mitigate any potential odor impacts. Thus, implementation of the proposed annexation would not cumulatively result in significant or highly objectionable odor.

Odors resulting from the construction activities associated with implementation of other cumulative projects in the area are not likely to affect a substantial number of people, since construction activities occur in a limited area and do not usually emit odors that are considered offensive. According to the AVAQMD CEQA and Federal Conformity Guidelines, land uses associated with odor complaints typically include agricultural uses, wastewater treatment plants, food processing plants, chemical plants, composting, refineries, landfills, dairies, and fiberglass molding. As discussed under Impact Statement AQ- 5, future development within Specific Plan does not include any uses identified by the AVAQMD as being associated with odors. Further, future development within Specific Plan would be required to minimize the VOC emissions during architectural coating as required by Mitigation Measure AQ -7. As such, the Specific Plan’s incremental contribution to impacts would be less than cumulatively considerable, and a less than significant impact would occur.

N. ENERGY
The thresholds of significance for energy impacts are listed in Section 5. 15, Energy, on page s 5.15-8 through 5.15-13 of the DEIR. Impact analyses were detailed on pages 5.15-14 through 5.15-26.

Potential Impact: Project implementation could expose people and structures to substantial adverse effects, including the risk of loss, injury, or death involving liquefaction.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
The proposed annexation would likely spur both small - and large -scale development within the City; however, no specific development is being proposed at this time. As such, construction details of future projects are unknown at this stage of the planning process. Nevertheless, upon annexation into the City, all future developments within the annexation area would utilize electricity provided by Lancaster Choice Energy (LCE).

Construction-Related Energy
Implementation of the proposed annexation would not directly result in construction activities associated with future projects as no specific development is proposed and construction details of future potential projects are unknown at this time. Notwithstanding, some incidental energy conservation would occur 77 during construction through compliance with State requirements that equipment not in use for more than five minutes be turned off. Construction equipment would also be required to comply with the latest U.S.

EPA and CARB engine emissions standards. These emission standards require highly efficient combustion systems that maximize fuel efficiency and reduce unnecessary fuel consumption. In addition, because the cost of fuel and transportation is a significant aspect of construction budgets, contractors have a strong financial incentive to avoid wasteful, inefficient, and unnecessary consumption of energy during construction.

Substantial reductions in energy inputs for construction materials can be achieved by selecting building materials composed of recycled materials that require substantially less energy to produce than nonrecycled materials. The integration of resource -efficient construction materials can help reduce environmental impacts associated with the extraction, transport, processing, fabrication, installation, reuse, recycling, and disposal of these construction materials. It is noted that construction fuel use is temporary and would cease upon completion of construction activities. There are no unusual characteristics associated with future development within the annexation area that would necessitate the use of construction equipment, materials, or methods that wou ld be less energy efficient than at comparable construction sites in the region or State. Therefore, fuel energy and construction materials consumed during construction would not represent a significant demand on energy resources.

Operational Energy
Future projects within the annexation area would result in operational energy demand. Future projects would be required to comply with the most current version of the Title 24 Building Energy Efficiency Standards, which provide minimum efficiency standards related to various building features, including appliances, water and space heating and cooling equipment, building insulation and roofing, and lighting.

The Title 24 Building Energy Efficiency Standards are updated every three years and become more stringent between each update; therefore, implementation of the proposed annexation would not result in excessive long-term operational energy consumption or result in unique or more intensive peak or base period electricity demand. Furthermore, the electricity provider is subject to California’s Renewables Portfolio Standard (RPS). The RPS requires investor- owned utilities, electric service providers, and community choice aggregators to increase procurement from eligible renewable energy resources to 100 percent of total procurement by 2045. Renewable energy is generally defined as energy that comes from resources which hare naturally replenished within a human timescale such as sunlight, wind, tides, waves, and geothermal heat. The increase in reliance of such energy resources further ensures that future development within the proposed annexation would not result in the waste of finite energy resources.

The key drivers of transportation -related fuel consumption are job locations/commuting distance and many personal choices on when and where to drive for various purposes. As discussed above, future development within the annexation area would be reviewed b y the City on a case -by-case basis.

Operational energy consumption associated with future projects would be analyzed prior to development and VMT -reducing improvements encouraging residents, workers, and visitors of the City to use alternative transportati on methods, including walking, biking, and transit would be implemented as appropriate. Therefore, implementation of the VMT -reducing improvements would contribute towards reducing transportation-related fuel consumption from future developments within the annexation area.

Overall, fuel consumption associated with the proposed annexation would not be considered inefficient, wasteful, or unnecessary in comparison to other industrial uses in the region; refer to DEIR Table 5.15-7, Annexation Area Energy Consumption. Additionally, it should be noted that developments within the Specific Plan would incorporate Mitigation Measure AQ-19 which would require future developments to 78 provide structural capacity to accommodate roof- top solar panels capable of producing enough renewable energy to meet 50 percent of facility operational electricity demands. Therefore, implementation of the proposed annexation would not cause wasteful, inefficient, and unnecessary consumption of energy during project operation, or preempt future energy development or future energy conservation. A less than significant impact would occur.

Overall, the proposed annexation would not result in direct increases in building energy consumption and therefore would not cause changes to the City’s or County’s electricity or natural gas consumption. As such, impacts would be less than significant in regard to annexation area’s energy consumptions during construction and operation.

Specific Plan Analysis
The proposed project would also adopt the Specific Plan, which would allow up to approximately 38.5 million sf of industrial development. The Specific Plan allows for two land use types within eight planning areas: Light Industrial (LI) and Heavy Industrial (HI). This analysis focuses on three sources of energy that are relevant to the proposed project: electricity, natural gas, and transportation fuel for vehicle trips and off-road equipment associated with construction and operations of the Specific Plan area. Due to the programmatic nature of Planning Areas 1, 3, and 5, specific construction -related information is not available and therefore construction-related energy usage is not projected. As shown in DEIR Table 5.15- 8, Specific Plan Energy Consumption, the construction and operation of the Specific Plan at buildout would not result in the inefficient, wasteful, or unnecessary consumption of energy. The proposed uses within the Specific Plan area would therefore not cause or result in the need for additional energy producing or transmission facilities.

Operational Energy
Transportation Energy Demands
DEIR Table 5.15- 9, Specific Plan Transportation Energy Demands , displays the energy demands from transportation within the Specific Plan area.

Planning Areas 1, 3, and 5 would generate approximately 198,098,208 annual VMT which would represent a fuel demand of approximately 11,863,836 gallons in 2040. Total fuel demand within the Specific Plan area would be approximately 17,046,533 gallons in 2040.

Stationary Source Equipment
Fuel consumption estimates from stationary sources are presented in DEIR Table 5.15 -10, Stationary Source Equipment Fuel Consumption. Although it is not known at this time whether emergency engines would be included in Planning Areas 1, 3, and 5, it was conservatively assumed that these Planning Areas would include 14 emergency generators and 20 emergency fire pumps. Stationary source equipment 79 would consume approximately 34,272 gallons of diesel per year. Stationary source equipment for the entire Specific Plan area would consume approximately 49,683 gallons of diesel per year.

On-Site Cargo Handling Equipment Fuel Demands
As previously stated, it is common for industrial buildings to require the operation of exterior cargo handling equipment in the building’s truck court areas. As a conservative analysis, Planning Areas 1, 3, and 5 would operate a combined total of 74 units of exterior cargo handling equipment. DEIR Table 5.15- 11, On-Site Cargo Handling Equipment Fuel Consumption Estimates displays the Specific Plan’s projected fuel consumption from on-site cargo handling equipment.

On-site equipment use of fuel would not be atypical for the type of development proposed because there are no aspects of the Specific Plan’s proposed operations that are unusual or energy -intensive, and on- site equipment would conform to the applicable CARB emissions standards, acting to promote equipment fuel efficiencies. As such, impacts would be less than significant.

Facility Energy Demands
DEIR Table 5.15 -12, Specific Plan Annual Operational Energy Demands , displays the Specific Plan’s projected operational energy demands from facility electricity and natural gas demands. Planning Areas 1, 3, and 5 would be projected to have an electricity demand of 235,772 MWh per year. Electricity would be supplied by LCE. Additionally, it should be noted that developments within the Specific Plan would incorporate Mitigation Measure AQ -19 which would require future developments to provide structural capacity to accommodate roof-top solar panels capable of producing enough renewable energy to meet 50 percent of facility operational electricity demands.

Since specific information about developments within Planning Areas 1, 3, and 5 is unknown at this stage of the planning process, it was conservatively assumed that the land uses within these areas would utilize natural gas. Planning Areas 1, 3, and 5 are projected to result in a natural gas demand of approximately 460,747,010 kBTU per year. Similar, the entire Specific Plan area are projected to result in a natural gas demand of approximately 460,747,010 kBTU per year as Planning Areas 2, 4, 6 (east), 7, and 8 would not cume natural gas.

The Specific Plan would propose conventional industrial uses reflecting contemporary energy efficient/energy conserving designs and operational programs. The future development within the Specific Plan does not propose uses that are inherently energy intensive and the energy demands in total would be comparable to other residential, industrial and commercial uses of similar scale and configuration. As such, impacts would be less than significant.

Overall, future development within the Specific Plan would comply with Mitigation Measures AQ -3, AQ- 4, AQ-6, AQ-8 through AQ-11, AQ-13 through AQ-15, AQ-18 through AQ-21, and AQ-23 through AQ-25 to reduce energy consumptions. However, none of the mitigation measures are quantifiable at the planning stage, and therefore mitigated energy consumptions were not presented. As supported by the preceding analyses, construction and operations of future development within the Specific Plan would not result in the in efficient, wasteful, or unnecessary consumption of energy. Implementation of the Specific Plan would therefore not cause or result in the need for additional energy producing or transmission facilities.

Development in accordance with the Specific Plan woul d not engage in wasteful or inefficient uses of energy and aims to achieve energy conservations goals within the State of California. As such, impacts would be less than significant.
80 Planning Areas 2, 4, 6 (east), 7, and 8 Analysis
Construction-Related Energy
The estimated power cost of on -site electricity usage during the construction of the proposed industrial uses is assumed to be approximately $2,057,281.55. Additionally, based on the assumed power cost, it is estimated that the total electricity usage duri ng construction is calculated to be approximately 12,858 MWh.

Construction equipment used by the proposed industrial uses would result in consumption of approximately 797,937 gallons of diesel fuel; refer to DEIR Table 5.15 -4, Construction Equipment Fuel Consumption Estimates . Construction equipment use of fuel would not be atypical for the type of construction proposed because there are no aspects of the proposed industrial uses’ construction process that are unusual or energy -intensive, and the proposed industrial uses’ cons truction equipment would conform to the applicable CARB emissions standards, acting to promote equipment fuel efficiencies.

CCR Title 13, Title 13, Motor Vehicles, Section 2449(d)(3) Idling, limits idling times of construction vehicles to no more than five minutes, thereby precluding unnecessary and wasteful consumption of fuel due to unproductive idling of construction equipme nt. Best Available Control Measures (BACMs) inform construction equipment operators of this requirement.

Construction worker trips for construction of the industrial uses would result in the estimated fuel consumption of 3,836,297 gallons; refer to DEIR Table 5.15 -5, Construction Worker Fuel Consumption Estimates. Additionally, fuel consumption from construction vendor trips and hauling trips (Heavy-Heavy Duty Trucks [HHDTs]) would total approximately 2,481,028 gallons of fuel; refer to Table 5.15 -6, Construction Vendor/Hauling Consumption Estimates. Diesel fuel would be supplied by City and regional commercial vendors. Indirectly, construction energy efficiencies and energy conservation would be achieved using bulk purchases, transport, and use of construction materials. The 2023 IEPR released by the CEC has shown that fuel efficiencies are getting better within on and off-road vehicle engines due to more stringent government requirements. As supported by the preceding discussions, the proposed industrial uses’ construction energy consumption would not be considered inefficient, wasteful, or otherwise unnecessary. As such, impacts would be less than significant.

Operational Energy
Transportation Energy Demands
DEIR Table 5.15- 9, Specific Plan Transportation Energy Demands , displays the energy demands from transportation within the Specific Plan area.

Approximately 71,284,107 annual VMT would be generated by the operation of the proposed development within Planning Areas 2, 4, 6 (east), 7, and 8 and would result in a fuel demand of 5,182,697 gallons in 2040; refer to DEIR Table 5.15-9.

Fuel would be provided by current and future commercial vendors. Trip generation and VMT generated by the proposed industrial uses within the Specific Plan are consistent with other industrial uses of similar scale and configuration. As such, the proposed industrial uses’ operations would not result in excessive and wasteful vehicle trips and VMT, nor excess and wasteful vehicle energy consumption compared to other industrial uses.
81 Stationary Source Equipment
Fuel consumption estimates from stationary sources are presented in DEIR Table 5.15 -10, Stationary Source Equipment Fuel Consumption. Planning Areas 2, 4, 6 (east), 7, and 8 fuel consumption was conservatively assumed to include installation of up to 11 300 horsepower diesel-powered fire pumps and seven 700 horsepower diesel -powered emergency generators. Stationary source equipment used in Planning Areas 2, 4, 6 (east), 7, and 8 would consume approximately 15,411 gallons of diesel per year.

On-Site Cargo Handling Equipment Fuel Demands
As previously stated, it is common for industrial buildings to require the operation of exterior cargo handling equipment in the building’s truck court areas. All on- site operational equipment in Planning Areas 2, 4, 6 (east), 7, and 8 would be zero -emission. DEIR Table 5.15 -11, On-Site Cargo Handling Equipment Fuel Consumption Estimates displays the Specific Plan’s projected fuel consumption from on- site cargo handling equipment.

Facility Energy Demands
DEIR Table 5.15 -12, Specific Plan Annual Operational Energy Demands , displays the Specific Plan’s projected operational energy demands from facility electricity and natural gas demands. The facility operational energy demands for the buildout of Planning Areas 2, 4, 6 (east), 7, and 8 in 2040 are estimated to be 81,050 MW h per year of electricity. Additionally, it should be noted that developments within the Specific Plan would incorporate Mitigation Measure AQ -19 which would require future developments to provide structural capacity to accommodate roof-top solar panels capable of producing enough renewable energy to meet 50 percent of facility operational electricity demands.

As previously discussed, Planning Areas 2, 4, 6 (east), 7, and 8 would not consume natural gas, and as such use of natural gas is not considered in the analysis for these Planning Areas.

Development in accordance with the Specific Plan woul d not engage in wasteful or inefficient uses of 82 energy and aims to achieve energy conservations goals within the State of California. As such, impacts would be less than significant.

Potential Impact: The project could conflict with or obstruct a state or local plan for renewable energy or energy efficiency.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
The General Plan contains energy resources and efficiency objectives and policies that would help implement renewable energy and energy efficiency measures and would subsequently reduce energy consumption within the City. As the proposed annexation would n ot affect the City’s building energy consumption, the Title 24 standards, CALGreen Code, and RPS do not apply to the proposed annexation.

While no development is currently proposed within the annexation area, future developments would be required to comply with the energy requirements/codes listed above. Therefore, the proposed annexation would result in less than significant impacts associated with renewable energy or energy efficiency plans.

Specific Plan Analysis
As shown in the DEIR, the Specific Plan would not conflict with any of the State or local plans, including and not limited to, Intermodal Surface Transportation Efficiency Act (ISTEA), Transportation Equity Act (TEA-21), Integrated Energy Policy Report (IEPR), State of California Energy Plan, Title 24, CALGreen, Renewable Portfolio Standard (RPS), SB 350, CEQA Appendix F, and the City’s General Plan. Further, future development within the Specific Plan area would comply with Mitigation Measures AQ-3, AQ-4, AQ-6, AQ- 8 through AQ -11, AQ -13 through AQ -15, AQ -18 through AQ -21, and AQ -23 through AQ -25 to reduce energy consumptions. As such, the Specific Plan would result in less than significant impacts.

Planning Areas 2, 4, 6 (east), 7, and 8 Analysis
The analysis provided above for the Specific Plan Analysis is also applicable to the Planning Areas 2, 4, 6 (east), 7, and 8 Analysis.

Potential Impact: Implementation of the project and other cumulative projects could result in wasteful, inefficient, or unnecessary consumption of energy resources. Implementation of the project and other cumulative projects could conflict with or obstruct a state or local plan for renewable energy or energy efficiency.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

The geographic context for cumulative energy consumption impacts for electricity and natural gas is Countywide and relative to LCE and SoCal Gas’s service areas. While the geographic context for the transportation-related energy use is more difficult to define, it is meaningful to consider the project in the context of Countywide consumption. Future growth within the County is anticipated to increase the 83 demand for electricity, natural gas, and transportation energy, as well as the need for energy infrastructure. As discussed above, the proposed annexation would not result in direct energy consumption and energy demand of future projects within the annexation would be evaluated on a project-by-project basis. Additionally, all future projects within the annexation and other cumulative projects developed in accordance with the General Plan would be subject to all applicable energy standards, as well as the ob jectives and policies of the General Plan. Cumulative development projects also would be required to implement any required mitigation measures on a project -by-project basis, as applicable. Thus, the proposed annexation and related projects would comply wi th energy conservation plans and efficiency standards required to ensure that energy is used efficiently. As such, implementation of the annexation and other cumulative projects would not result in wasteful, inefficient, or unnecessary consumption of energy resources. Impact would be less than significant.

As discussed above, future development within the Specific Plan would result in direct energy consumption and energy demand during construction and operation. Future development within the Planning Areas 2, 4, 6 (east), 7, and 8 would not consume natural gas on-site. However, it is assumed the remaining Planning Areas within the Specific Plan would utilize natural gas. Future growth within the County is anticipated to increase the demand for electricity, natural gas, and transportation energy, as well as the need for energy infrastructure. As discussed above, the proposed Specific Plan would not result in wasteful inefficient, or unnecessary energy consumption and energy demand. Additionally, all cumulative projects listed in DEIR Table 4 -2 would be subject to applicable local, regional, State, and federal energy standards. Cumulative development projects also would be required to implement any required mitigation measures on a project -by-project basis, as applicable, pursuant to CEQA provisions.

Thus, future development within the Specific Plan and related projects would comply with energy conservation plans and efficiency standards required to ensure that energy is used efficiently. Further, future development within the Specific Plan would comply with Mitigation Measures AQ -3, AQ-4, AQ-6, AQ-8 through AQ-11, AQ-13 through AQ-15, AQ-18 through AQ-21, and AQ-23 through AQ-25 to reduce energy consumption. Implementation of the Specific Plan and other cumulative projects would not result in wasteful, inefficient , or unnecessary consumption of energy resources. Impact would be less than significant.

O. NOISE
The thresholds of significance for noise impacts are listed in Section 5.16, Noise, on pages 5.16-12 through

5.16-16 of the DEIR. Impact analyses were detailed on pages 5.16-16 through 5.16-42.

Potential Impact: Project implementation could generate 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.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

The following analysis is a discussion of whether the project would result in a substantial temporary (construction-related) 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; refer to Section 6(C), Noise, below for a discussion of whether the project would result in a substantial permanent (operational) increase in ambient noise levels in excess of established standards. 84 Annexation Analysis
Due to the programmatic nature of the annexation area buildout and lack of specific construction-related information (i.e., construction schedule, number of hauling/vendor/worker trips, type of construction equipment, etc.), construction-related noise impacts cannot be accurately determined at this stage of the planning process. It is acknowledged that construction activities are temporary and would cease upon construction competition. Additionally, pursuant to LMC Section 8.24.040, Loud, unnecessary and unusual noises prohibited - Construction and building, construction of future new development located within 500 feet of an occupied dwelling, apartment, hotel, mobile home or other place of residence would be limited to the hours of 7:00 a.m. to 8:00 p.m. Monday through Saturday and would be prohibited on Sundays and holidays.

Nevertheless, all future development within the annexation area would be required to undergo separate review to evaluate project-specific construction-related noise impacts to nearby sensitive receptors and identify any required mitigation. As such, impacts would be less than significant.

Specific Plan Analysis
Construction of future industrial development in accordance with the Specific Plan could temporarily increase the ambient noise environment in the vicinity of each individual project. Construction noise levels are dependent upon the specific locations, site plans, and construction details of each new future development; given the programmatic nature of the Specific Plan, construction-related noise impacts that may occur from future new development within the Specific Plan area are speculative and cannot be accurately determined at this stage of the planning process. As discussed above, pursuant to LMC Section

8.24.040, construction of future new development located within 500 feet of an occupied dwelling, apartment, hotel, mobile home or other place of residence would be limited to the hours of 7:00 a.m. to 8:00 p.m. Monday through Saturday and would be prohibited on Sundays and holidays. Impacts would be less than significant.

Planning Areas 2, 4, 6 (East), 7, and 8 Analysis
DEIR Table 5.16-7, Ambient Construction Noise Level Increase, presents the temporary ambient noise level increases due to construction activities. As indicated in DEIR Table 5.16 -7, construction of the industrial developments in Planning Areas 2, 4, 6 (east), 7, and 8 would result in an ambient noise level increase ranging from 0.0 to 4.1 dBA L eq during the daytime hours at the nearest receptor locations. The construction noise analysis shows that the nearest receptor locations would not exceed Caltrans 15 dBA L
eq noise level increase threshold of 15 dBA. As such, construction noise impacts associated with construction equipment operations would be less than significant.

DEIR Table 5.16 -8, Nighttime Concrete Pour Noise Levels , displays the noise levels associated with nighttime concrete pour activities. As shown in DEIR Table 5.16 -8, noise levels associated with the nighttime concrete pour activities are estimated to range from 21.4 to 40.2 dBA L eq. Thus, anticipated nighttime concrete pour activities would not exceed the construction noise level threshold of 65 dBA at all the nearest noise sensitive receptor locations. Overall, construction noise impacts associated with nighttime concrete pouring would be less than significant.

Cumulative Construction Noise Analysis
85 Construction activities associated with development within the annexation area and Specific Plan and cumulative projects may overlap, resulting in construction noise in the project vicinity. However, construction noise impacts primarily affect the areas im mediately adjacent to the construction site. It should be noted that approximately eight cumulative projects are located within the annexation area. As discussed, construction -related analysis regarding future development in Planning Areas 1, 3, and 5 cannot be analyzed due to its programmatic nature. The closest cumulative projects to Planning Areas 2, 4, 6, 7, and 8 are Cumulative Projects 16, 20, 24, and 27; refer to DEIR Exhibit 4 -1. However, the construction impacts for Cumulative Projects 16 and 27 are evaluated above as they are in Planning Areas 2, 4, 6, 7, and 8. Due to the distance, Cumulative Projects 20 and 24, in addition with the construction of the remainder of the Specific Plan, may result in construction noise overlap.

The proposed annexation would not directly result in any specific development. Future cumulative projects would undergo environmental review under CEQA to evaluate project-specific construction noise impacts. Future construction activities associated with cumulative development projects would also be required to comply with the Municipal Code and incorporate mitigation measures on a project-by-project basis, as applicable, to reduce construction noise pursuant to CEQA provisions. As the proposed development within Planning Areas 2, 4, 6 (east), 7, and 8 would not exceed applicable construction noise thresholds, cumulative construction noise impacts would be less than significant.

Potential Impact: Project implementation could generate excessive groundborne vibration or groundborne noise levels.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

Annexation Analysis
As previously discussed, the annexation would not directly result in any specific development and any future development and their corresponding construction vibrations cannot be accurately determined at this stage of the planning process. Construction of future development within the annexation area would cause construction vibrations. Additionally, the annexation area would permit uses that would potentially require construction equipment capable of generating substantial vibration impacts (i.e., pile driving).

Nevertheless, due to the programmatic nature of the annexation area, potential construction activities and its distance from sensitive receptors cannot be determined during this stage of the planning process.

All future new development projects would be required to undergo separate environmental review under CEQA to evaluate project -specific construction vibration impacts to nearby sensitive receptors and identify any required mitigation. It should be noted that construction activities are temporary and would cease upon construction completion.

Additionally, the project proposes to pre-zone the annexation area consistent with the proposed land use designations. The RR-2.5, MU-E, P, and MHP zones would not comprise of any uses that would result in significant operational vibration impacts. The LI and SP zones would allow for industrial uses within the annexation area which can result in an increase of truck movements along roadways. However, according to the Federal Transit Administration (FTA), it is unusual for vibration from sources, such as bus es and trucks, to be perceptible, even in locations close to major roads. As such, impacts would be less than significant.

Specific Plan Analysis
86 Construction of future industrial development associated with the proposed Specific Plan could result in temporary construction-related vibration impacts in the vicinity of each individual project. Construction vibration impacts are dependent upon the spec ific locations, site plans, and construction details of each new future development. Given the programmatic nature of the proposed Specific Plan, construction - related vibration impacts that may occur from future new development in the Specific Plan area ar e speculative and cannot be accurately determined at this stage of the planning process. It should be noted that all future new development projects capable of generating substantial construction vibration impacts would be required to undergo separate envi ronmental review under CEQA to evaluate project -specific construction vibration impacts to nearby sensitive receptors and identify any required mitigation.

Similarly, given the programmatic nature of the Specific Plan (except for Planning Areas 2, 4, 6 (east), 7, and 8), operation-related vibration impacts that may occur from future new development in the Specific Plan area is speculative and cannot be accurately determined at this stage of the planning process.

Nevertheless, any buildings shall be designed to locate noise -generating equipment and activity in a manner which would have a minimal impact on abutting residentially zoned property as applicable. Light and heavy industrial uses within the Specific Plan would require proper site planning, building design, and landscaping to minimize impacts. As such, operational impacts would be less than significant.

Planning Areas 2, 4, 6 (east), 7, and 8 Analysis
Construction
DEIR Table 5.16 -21, Vibration Source Levels for Construction Equipment , displays the ground vibration levels associated with various types of construction equipment at 25 feet. Utilizing the vibration source levels provided in DEIR Table 5.16 -21 and the construction vibration assessment methodology from the Caltrans Transportation and Construction Vibration Guidance Manual, DEIR Table 5.16 -22, Construction Equipment Vibration Levels, displays the expected construction equipment vibration levels at the nearest receptor locations. Sensitive receptors range from 145 feet to 8,077 feet from future construction activities in Planning Ares 2, 4, 6, 7, and 8 of the Specific Plan area. As shown in DEIR Table 5.16 -22, sensitive receptors would experience construction vibration levels ranging from 0.000 to 0.015 PPV in/sec.

As such, vibration levels at the nearby sensitive receptors would not exceed the vibration threshold of 0.3 PPV in/sec for residential uses as established by the Caltrans Transportation and Construction Vibration Guidance Manual.

Additionally, it should be noted that vibration levels reported at the sensitive receptor locations are unlikely to be sustained during the entire construction period but would occur rather only during the times that heavy construction equipment is operating near the boundaries of Planning Ares 2, 4, 6, 7, and 8 of the Specific Plan. As such, impacts associated with construction vibration would be less than significant.

Operations
The proposed industrial uses would not include uses that generate groundborne vibration that could be felt by the nearest sensitive receptors. However, heavy duty trucks associated with project operations would occasionally travel through the surrounding roadways. According to the FTA, it is unusual for vibration from sources, such as buses and trucks, to be perceptible, even in locations close to major roads.

As such, it can be reasonably inferred that project operations would not create perceptible vibrat ion impacts to the nearest sensitive receptors. Overall, vibration impacts related to human annoyance and building damage during project operations would be less than significant. 87 Cumulative Construction Vibration Impacts
Future buildout of the annexation area and Specific Plan area could generate groundborne vibration during construction activities. Construction activities associated with the proposed project and cumulative projects may overlap. Despite the potential for o verlap, groundborne vibration generated from the construction of the proposed development in Planning Areas 2, 4, 6 (east), 7, and 8 of the Specific Plan would not exceed the Caltrans significance threshold of 0.3 PPV in/sec. Approximately eight cumulative projects are located within the annexation area. The closest cumulative projects to Planning Areas 2, 4, 6 (east), 7, and 8 are Cumulative Projects 16, 20, 24, and 27; refer to DEIR Exhibit 4-1. However, the vibration impacts for Cumulative Projects 16 and 27 are evaluated above as they are located in Planning Areas 2, 4, 6 (east), 7, and 8. Due to the distance, Cumulative Projects 20 and 24 may result in overlapping vibration impacts. As discussed above, due to the programmatic nature of the annexation ar ea and Planning Area 1, 3, and 5, construction -related vibration impacts cannot be quantified. Nevertheless, all future new development projects would be required to undergo separate environmental review under CEQA to evaluate project-specific construction-related vibration impacts to nearby sensitive receptors and identify any required mitigation. Nevertheless, the proposed land uses in annexation area and Specific Plan would not include any activities capable of generating substantial operational vibratio n impacts. However, because the proposed development within Planning Areas 2, 4, 6 (east), 7, and 8 would not exceed appliable Caltrans vibration thresholds, cumulative vibration impacts would be less than significant.

Potential Impact: Project implementation could expose people residing or working in the project area to excessive noise levels due to airport operations.

Finding: The City hereby makes Finding 1.

Facts in Support of Findings:

According to Exhibit 2B and Exhibit 3F of the ALUCP, the annexation area, including the Specific Plan area, is not located within the General William J. Fox Airfield 65 dB noise contours. However, employees and visitors to the future developments within th e annexation and specific plan areas would be subject to occasional aircraft noise from takeoff and landings. However, noise associated with these events would occur scattered throughout the day and are a fairly route event in the Antelope Valley. As such, the airport would not expose potential residents, visitors, and/or workers at the project site to excessive noise levels.

A less than significant impact would occur.

6. FINDINGS ON POTENTIALLY SIGNIFICANT IMPACTS OF THE PROPOSED PROJECT IDENTIFIED IN

THE DEIR THAT REMAIN SIGNIFICANT AND UNAVOIDABLE
As detailed above, where, as a result of the environmental analysis of the proposed project, the City has determined that either (1) even with the identified of project design features, compliance with existing laws, codes and statutes, and/or the identifi cation of feasible mitigation measures, potentially significant impacts cannot be reduced to a level of less than significant, or (2) no feasible mitigation measures or alternatives are available to mitigate the potentially significant impact, the City has found in accordance with CEQA Section 21081(a)(3) and CEQA Guidelines Section 15091(a)(3) that “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 work,” referred to herein as “Finding 3.” 88 In making these findings, the City has relied upon the environmental conclusions reached by the experts that prepared the FEIR, including the information, analysis and conclusions in the technical reports prepared and made a part of the FEIR. Although contrary opinions may have been presented in comments submitted on the DEIR and FEIR, the City has weighed those comments against the underlying data, analysis and conclusions in the FEIR, and has reached its conclusions accordingly.

The following environmental impacts were analyzed in the DEIR and were determined to remain significant and unavoidable despite implementation of existing regulations and mitigation measures. • Air Quality
o Regional construction emissions
o Regional operational emissions
o Air Quality Management Plan (AQMP) consistency
o Cumulative air quality impacts
• Greenhouse Gas (GHG) Emissions
o GHG emissions
o Cumulative GHG emissions
• Noise
o Project level off-site mobile traffic noise
o Cumulative off-site mobile traffic noise
It should be acknowledged that, as the proposed project involves two components (annexation and adoption of the proposed Specific Plan), these two components were analyzed separately under separate headings in majority of the analyses within the DEIR; where impacts are quantifiable and project- specific details are available (e.g., VMT, construction and operational air emissions, etc.), the Specific Plan component may specifically identify projects/Planning Areas with these project -specific details.

Nonetheless, for the purpose of making Findings for this project, the following summaries of each significant and unavoidable impacts have been reorganized under a three -level analytical framework:

Annexation Analysis, Specific Plan Analysis, and Planning Areas 2, 4, 6 (east), 7, and 8 Analysis. It should also be noted that due to the nature of cumulative analysis, the summaries for each cumulative impact Findings only have one level of analysis that cover the entire project, including the annexation and the adoption of the Specific Plan (inclusive of proposed industrial development within Planning Areas 2, 4, 6 (east), 7, and 8).

A. AIR QUALITY
The thresholds of significance for air quality impacts are listed are listed in Section 5.13, Air Quality, on pages 5.13-14 and 5.13-15 of the DEIR. Impact analyses were detailed on pages 5.13-15 through 5.13-61.

Potential Impact: Short-term construction activities associated with the proposed project could result in a cumulatively considerable net increase of criteria pollutants for which the project region is non - attainment under an applicable federal or state ambient air quality standard.

Finding: The City hereby makes Finding 3.

89 Facts in Support of Findings:

Annexation Analysis
Future construction -related activities associated with development within the annexation area would result in emissions of criteria air pollutants and precursors from site preparation (e.g., demolition, excavation, grading, and clearing); exhaust from off-road equipment, material delivery trucks, and worker commute vehicles; vehicle travel on roads; and other miscellaneous activities (e.g., building construction, asphalt paving, application of architectural coatings, and trenching for utility installation).

Because there are no specific development proposals, construction -related emissions that may occur at any one time are speculative and cannot be accurately determined as the type of construction, the date when construction will commence, and the duration of the construction are all unknown. Assuming relatively robust economic conditions over the next 25 years, construction activities would occur throughout the project area, but the rate of development cannot be predicted. Future development projects would be required to comply with all applicable AVAQMD rules and regulations as well as other control measures to reduce construction emissions, including Regulatory Requirement AQ -1 and Mitigation Measures AQ -1 through AQ -7, as applicable. Upon compliance with e xisting AVAQMD regulations as outlined in Regulatory Requirement AQ-1 as well as Mitigation Measures AQ-1 through AQ- 7, as applicable, construction impacts related to implementation of the proposed annexation would be less than significant.

Specific Plan Analysis
Due to the programmatic nature of future development in Planning Areas 1, 3, and 5, exact construction emissions generated by future development is unknown because the type of construction, the date when construction will commence, and the duration of the construction are all unknown. Future development projects would be required to comply with all applicable AVAQMD rules and regulations (Regulatory Requirement AQ- 1) as well as other control measures to reduce construction emissions, including Mitigation Measures AQ-2 through AQ-7.

Additionally new development projects capable of generating substantial construction-related emissions would be required to undergo separate environmental review under CEQA to evaluate project -specific impacts on a project-by-project basis, as the extent of impacts become known through the design process.

Despite compliance with existing AVAQMD regulations as outlined in Regulatory Requirement AQ -1 as well as Mitigation Measures AQ-2 through AQ-7, construction impacts related to implementation of the proposed Specific Plan would be significant and unavoidab le for two reasons. First, the effectiveness of the mitigation is unknown because the type of construction, the date when construction will commence, and the duration of the construction are all unknown. Second, as explained below, the construction emissions from Planning Areas 2, 4, 6 (east), 7, and 8 would exceed the AVAQMD established threshold for PM
10 after mitigation; refer to DEIR Table 5.13-8, Emissions Summary of Construction – With Mitigation (Planning Areas 2, 4, 6 [East], 7, and 8) . There are no additional feasible mitigation measures to reduce PM10 emissions to below the AVAQMD threshold. As such, impacts would be considered significant and unavoidable.

90 Planning Areas 2, 4, 6 (east), 7, and 8 Analysis
The project proposes to develop up to 11.3 million sf of industrial uses and associated site improvements within Planning Areas 2, 4, 6 (east), 7, and 8 of the Specific Plan. However, no site specific development applications have been submitted. Emissions for each year have been quantified based upon the phase duration and equipment types. DEIR Table 5.13 -7, Emissions Summary of Construction – Without Mitigation (Planning Areas 2, 4, 6 [East], 7, and 8, presents anticipated daily short -term construction emissions associated with construction of the industrial uses within Planning Areas 2, 4, 6 (east), 7, and 8.

Without mitigation, emissions resulting from construction activities would exceed the criteria pollutant thresholds established by the AVAQMD for emissions of volatile organic compounds (VOCs), nitrogen oxides (NO
X), and particulate matter 10 microns in diameter or less (PM 10). Therefore, mitigation measures are proposed to reduce these emissions. Regulatory Requirement AQ -1 as well as Mitigation Measures AQ-2 through AQ-7 would reduce construction-source emissions associated with the proposed developments within the Specific Plan to the extent feasible. However, with implementation of mitigation, construction emissions would still exceed the AVAQMD’s regional thresholds for PM10; refer to DEIR Table 5.13-8, Emissions Summary of Construction – With Mitigation (Planning Areas 2, 4, 6 [East], 7, and 8).

With implementation of the proposed mitigation measures, construction emissions would still exceed the AVAQMD established threshold for PM10. There are no additional feasible mitigation measures to reduce PM10emissions to below the AVAQMD threshold. As such, impacts would be considered significant and unavoidable.

Potential Impact: Implementation of the proposed project could result in increased impacts pertaining to operational air emissions.

Finding: The City hereby makes Finding 3.

Facts in Support of Findings:

Annexation Analysis
Future buildout of the annexation area would generate emissions from mobile source, area source, energy source, on-site cargo handling equipment emissions, stationary sources, and transportation refrigeration units (TRUs); refer to DEIR Table 5.13 -9, Summary of Annexation Area Peak Operational Emissions – Without Mitigation (2040).

Future development in accordance with the proposed land use designations and pre -zones within the annexation area would be required to comply with the air quality standards of the AVAQMD. Additionally, future development within the annexation will be subject to Mitigation Measures AQ -8 through AQ-25, as applicable. Furthermore, future development within the annexation area would be analyzed at a project-level and be reviewed by the City to ensure that development occurs in a manner consistent with the General Plan, LMC, and that additional environmental review is conducted under CEQA, as needed.

Future project-specific environmental review under CEQA would be conducted pursuant to City guidelines and in compliance with existing AVAQMD regulations. However, as the emissions would exceed the AVAQMD thresholds, and the effectiveness of Mitigation Measures AQ-8 through AQ-25 are unknown at this time because the types of users and the date at which further projects will become operational are unknown, impacts related to buildout of the annexation area would be significant and unavoidable. 91 Specific Plan Analysis
Future development projects would be required to comply with all applicable AVAQMD rules and regulations as well as other control measures to reduce operational emissions; refer to Mitigation Measures AQ-8 through AQ-25.

Planning Areas 1, 3, and 5 and remaining annexation area have a buildout year of 2040. DEIR Table 5.13- 11, Summary of Peak Operational Emissions – Without Mitigation (2040) (Planning Areas 1, 3, and 5), details long-term operational emissions associated with buildout of Planning Areas 1, 3, and 5 in 2040 generated by mobile sources, area sources, energy sources, stationary sources and TRUs. As shown in DEIR Table 5.13- 11, operational emissions without mi tigation would exceed the operational thresholds established by the AVAQMD.

As shown in DEIR Tables 5.13 -10, Summary of Peak Operational Emissions – Without Mitigation (2031), and 5.13-11, the estimated long-term emissions generated at buildout year of the Specific Plan area would exceed the AVAQMD’s regional operational significance thresholds and would cumulatively contribute to the nonattainment designations in the Mojave D esert Air Basin (MDAB). Mitigation Measures AQ -8 through AQ-25 would reduce the operational -source emissions associated with buildout of the Specific Plan to the extent feasible. However, none of the mitigation measures are quantifiable at the planning stage because the types of users and the date the projects will become operational are unknown. On this basis, it is concluded that project operational-source VOC, NO X, CO, PM10, and PM2.5 emissions cannot be
definitively reduced below applicable AVAQMD thresholds and therefore, impacts are considered significant and unavoidable.

Planning Areas 2, 4, 6 (East), 7 and 8
DEIR Table 5.13-10, Summary of Peak Operational Emissions – Without Mitigation (2031) (Planning Areas 2, 4, 6 [East], 7 and 8), provides long-term operational emissions associated with buildout of Planning Areas 2, 4, 6 (east), 7, and 8 in 2031 generated by mobile sources, area sources, energy sources, stationary sources, and TRUs. As shown in DEIR Table 5.13 -10, operational emiss ions without mitigation would exceed the operational thresholds established by the AVAQMD. As shown in Table 5.13-10, the estimated long-term emissions generated at buildout year of the Specific Plan area resulting from industrial uses within Planning Areas 2, 4, 6 (East), 7 and 8 would exceed the AVAQMD’s regional operational significance thresholds and would cumulatively contribute to the nonattainment designations in the MDAB. Mitigation Measures AQ-8 through AQ-25 would reduce the operational-source emissions associated with buildout of the Specific Plan to the extent feasible. However, none of the mitigation measures are quantifiable at the planning stage. On this basis, it is concluded that project operational-source VOC, NO X, CO, PM10, and
PM2.5 emissions cannot be definitively reduced below applicable AVAQMD thresholds and therefore, impacts are considered significant and unavoidable.

Potential Impact: Implementation of the proposed project could conflict with or obstruct implementation of the applicable air quality plan.

Finding: The City hereby makes Finding 3.

92 Facts in Support of Findings:

Annexation Analysis
All future development within the annexation area would be required to undergo review on a case -by- case basis. As such, future development projects would be required to analyze project-specific impacts to the City’s existing population and housing and consistency with the City’s growth forecasts. Furthermore, future development projects would be required to comply with all applicable AVAQMD rules and regulations as well as other control measures to reduce construction emissions; refer to Mitigation Measure AQ-1 through AQ-7, as applicable. Furthermore, implementation of Mitigation Measure AQ -26 within the annexation area would reduce the impacts of Valley Fever.

The City of Lancaster is proposing a General Plan Amendment to reflect annexation of the annexation area and application of the proposed land use designations, including non -urban residential, mixed use, industrial, public uses, multiple family residential, and specific plan. Because a General Plan Amendment is proposed, the project would therefore not conform to local land use plans. As such, a significant and unavoidable impact would occur.

Specific Plan Analysis
Compliance With Applicable District Rules And Regulations The development associated with the Specific Plan would be required to comply with all AVAQMD rules and regulations to improve air quality as prescribed in Regulatory Requirement AQ-1. It should be noted that developments within the Specific Plan area would implement Mitigation Measure AQ -8 which requires a more stringent limit of VOC contents than AVAQMD Rule 1113, which is required under Regulatory Requirement AQ -1. Implementation of Mitigation Measure AQ- 8 would reduce a development’s VOC emissions during architectural coating applications.

With buildout of the Specific Plan and annexation area in 2040, the project would exceed the numerical thresholds of significance for emissions of VOC, NO
X, CO, PM10, and PM 2.5 during both the summer and
winter seasons. As such, the Specific Plan implementation would have the potential to delay the timely attainment of air quality standards or AVAQMD Federal 70 ppb Ozone Attainment Plan (Western Mojave Desert Nonattainment Area) (AVAQMD 70 ppb Plan) emission reductions goals. A significant and unavoidable impact would occur.

Consistency With Land Use Plans And Growth Forecasts
As detailed above, future development within Specific Plan would not conform to existing land use plans as stated previously, and a General Plan Amendment would be required. Future development in accordance with the Specific Plan would be required to compl y with all applicable AVAQMD Rules and Regulations but would exceed the applicable regional thresholds. The development within Specific Plan would implement the air quality mitigation measures identified to reduce emissions during construction and operatio n; refer to Mitigation Measures AQ -1 through AQ -26, acting to generally reduce the construction-source and operational -source air pollutant emissions. Additionally, incorporation of contemporary energy-efficient technologies and operational programs, and compliance with AVAQMD emissions reductions and control requirements act to reduce air pollutant emissions generally. In conclusion, the determination of the Specific Plan’s consistency with the AVAQMD 70 ppb Plan is primarily concerned with the long -term i nfluence of a project on MDAB air quality. The Specific Plan 93 implementation would result in long-term impacts on the region’s ability to meet State and federal air quality standards. In conclusion, Specific Plan implementation would have the potential to conflict with the goals and policies of the AVAQMD 70 ppb Plan, and a significant and unavoidable impact would occur.

Planning Areas 2, 4, 6 (east), 7, and 8 Analysis
As analyzed, construction emissions associated with development of Planning Areas 2, 4, 6 (east), 7, and 8 would exceed the applicable AVAQMD regional thresholds for PM

10. Additionally, for operational-source
emissions, buildout of Planning Areas 2, 4, 6 (east), 7, and 8 in 2031 would exceed the numerical thresholds of significance established by the AVAQMD for emissions of VOCs, NO X, carbon monoxide (CO),
PM10, and particulate matter 2.5 microns in diameter or less (PM 2.5) during the summer season and for emissions of VOCs, NOX, PM10, and PM2.5 during the winter season. With buildout of the Specific Plan and annexation area in 2040, the project would exceed the numerical thresholds of significance for emissions of VOC, NO
X, CO, PM10, and PM2.5 during both the summer and winter seasons. As such, Planning Areas 2, 4, 6 (east), 7, and 8 implementation would have the potential to delay the timely attainment of air quality standards or AVAQMD Federal 70 ppb Ozone Attainment Plan (Western Mojave Desert Nonattainment Area) (AVAQMD 70 ppb Plan) emission r eductions goals. A significant and unavoidable impact would occur.

Potential Impact: Short-term construction activities associated with the proposed project and other related cumulative projects, could result in increased air pollutant emission impacts or expose sensitive receptors to increased pollutant concentrations.

Finding: The City hereby makes Finding 3.

Facts in Support of Findings:

Per AVAQMD rules and mandates and Regulatory Requirement AQ -1, as well as the CEQA requirement that significant impacts be mitigated to the extent feasible, these same requirements (i.e., Rule 403 compliance, the implementation of all feasible mitigation measures, and compliance with adopted AQMP emissions control measures) would also be imposed on the construction of future development within the proposed annexation and the City of Lancaster. Based on the discretion of the lead agency, construction-related emissions associated with future development projects within the City and surrounding area would be required to conduct project -specific CEQA analysis and comply with the applicable AVAQMD rules and regulations, as well as Mitigation Measures AQ -1 through AQ-7, as applicable. Therefore, implementation of the proposed annexation would not result in cumulatively considerable impacts regarding construction air quality emissions.

The AVAQMD neither recommends quantified analyses of cumulative construction emissions, nor does it provide separate methodologies or thresholds of significance to be used to assess cumulative construction 94 impacts. The AVAQMD significance thresholds for construction are intended to meet the objectives of the applicable plan (i.e., AQAVQMD 70 ppb Plan) to ensure the NAAQS and CAAQS are not exceeded. As the City has no control over the timing or sequencing of cumulative projects in the Specific Plan vicinity, any quantitative analysis to ascertain the daily construction emissions that assumes multiple, concurrent construction would be speculative. Future cumulative projects would also be required to analyze construction emission impacts on a project-level under CEQA and implement mitigation as needed. Future development projects would be required to comply with all applicable AVAQMD rules and regulations (Regulatory Requirement AQ-1) as well as other control measures to reduce construction emissions. With implementation of Mitigation Measures AQ -2 through AQ -7, construction-source emissions would still exceed AVAQMD significance thresholds. As such, per AVAQMD protocols, construction-source emissions would be considered cumulatively significant and unavoidable.

Potential Impact: Implementation of the proposed project and other related cumulative projects could result in increased impacts pertaining to operational air emissions.

Finding: The City hereby makes Finding 3.

Facts in Support of Findings:

As discussed above, there are no current development proposals for property outside the Specific Plan Planning Areas 2, 4, 6 (east), 7, and 8. Additionally, future development within the annexation area will be subject to Regulatory Requirement AQ-1 and Mitigation Measures AQ-8 through AQ-25, as applicable.

Future development within the annexation area would also be analyzed at a detailed level and be reviewed by the City to ensure that development occurs in a logical manner consistent with the project, General Plan, Municipal Code, and that additional environmental review is conducted under CEQA, as needed. Future project-specific environmental review under CEQA would be conducted pursuant to City guidelines. Nevertheless, it is assumed that the future development of the annexation area will result in significant and unavoidable impacts as the scope of the impact and the effectiveness of the mitigation measures cannot be determined until project specific development is proposed. Furthermore, emission reduction technology, strategies, and plans are constantly being developed. As a result, the proposed annexation would have the potential to contribute to a cumulatively considerable net increase of any nonattainment criteria pollutant. As such, the impacts would significant and avoidable.

The AVAQMD has set forth both a methodological framework as well as significance thresholds for the assessment of a project’s cumulative operational air quality impacts. The AVAQMD’s approach for assessing cumulative impacts is based on the AVAQMD 70 ppb Plan forecasts of attainment of NAAQS in accordance with the requirements of the federal and State CAAs. This forecast also considers SCAG’s forecasted future regional growth. As such, the analysis of cumulative impacts focuses on determining whether the project is consistent with the growth assumptions upon which the AVAQMD 70 ppb Plan is based. If the project is consistent with the growth assumptions, then the future development would not impede the attainment of NAAQS, and a significant cumulative air quality impact would not occur. Future development projects would be required to comply with all applicable AVAQMD rules and regulations (Regulatory Requirement AQ-1) as well as other control measures to reduce emissions. Per substantiated discussion above, operational-source VOC, NOX, CO, PM10, and PM2.5 emissions impacts associated with buildout of the Specific Plan would be significant and unavoidable. As such, per AVAQMD protocols, operational-source VOC, NOX, CO, PM10, and PM2.5 emissions impacts would al so be cumulatively significant even with implementation of Mitigation Measures AQ-8 through AQ-25. 95 Potential Impact: Implementation of the proposed project and related projects could result in cumulatively considerable inconsistencies with the applicable air quality plan.

Finding: The City hereby makes Finding 3.

Facts in Support of Findings:

As noted above, the AVAQMD considers any project with a significant project -level air quality impact to also have a significant cumulative air quality impact. As discussed above, a General Plan Amendment is proposed as the project would not conform to loca l land uses plans. Even all future development within the project area would be required to comply with applicable General Plan policies and development standards implemented by the proposed project. Future project -specific environmental review under CEQA would be conducted pursuant to City guidelines and Mitigation Measures AQ -1, and AQ-26 would be required. Impacts were determined to be significant and unavoidable with regard to consistency with regional air quality plans. Therefore, the proposed annexation area would have a cumulatively considerable impact. Cumulative impacts would be significant and unavoidable.

Future related projects would be required to analyze project-level consistency with applicable air quality plans, including the AVAQMD 70 ppb Plan. The construction emissions, even with implementation of Mitigation Measures AQ -1 through AQ -7 and AQ -26 woul d exceed the AVAQMD’s thresholds.

Furthermore, operational emissions of the Specific Plan, even with implementation of Mitigation Measures AQ-8 through AQ-25, would exceed the AVAQMD’s operational thresholds. As the Specific Plan would amend the General Plan land use designation of the annexation area and result in VOC, NOX, CO, PM10, and PM2.5 emissions exceedances, which would cause significant and unavoidable impacts, the Specific Plan is determined to be inconsistent with the AVAQMD 70 ppb Plan. The Spe cific Plan would have the potential to result in NAAQS and CAAQS violations and thus, cumulative impacts would be significant and unavoidable.

B. GREENHOUSE GAS EMISSIONS
The thresholds of significance for greenhouse gas emissions are listed in Section 5.14, Greenhouse Gas Emissions, on pages 5.14-11 through 5.14-17 of the DEIR. Impact analyses were detailed on pages 5.14- 17 through 5.14-26.

Potential Impact: Greenhouse gas emissions generated by the project could have a significant impact on global climate change. Implementation of the proposed project could conflict with an applicable greenhouse gas reduction plan, policy, or regulation.

Finding: The City hereby makes Finding 3.
96 Facts in Support of Findings:

Annexation Analysis
Generation of Greenhouse Gas Emissions
Emissions Associated With Annexation Area
The proposed annexation would likely spur both small - and large-scale redevelopment within the City.

Direct project-related GHG emissions include emissions from construction activities, area sources, mobile sources, stationary sources, and on-site equipment sources, while indirect sources include emissions from electricity and natural gas consumption, water demand, and solid waste generation. However, the annexation does not propose demolition or development activities. Therefore, construction GHG emissions are not quantified as part of this programmatic analysis. Implementation of the proposed annexation would not directly generate operational emissions as no specific development is being proposed, but nonetheless, operational GHG emissions are discussed below. Operational GHG emissions associated with buildout of the annexation area is quantified below in DEIR Table 5.14-1, Annexation Area GHG Emissions Summary - Without Mitigation (2040). The proposed annexation would annex approximately 7,153 acres curren tly in unincorporated Los Angeles County into the City’s jurisdiction.

Potential buildout of the annexation area (excluding the Specific Plan area) would result in up to 15,594,480 sf of nonresidential development and 1,837 dwelling units; refer to DEIR Table 3-1, Annexation Area Buildout Potential.

The annual GHG emissions associated with the operation of the proposed project at buildout of the annexation area (excluding the Specific Plan area) is estimated to be approximately 192,022.78 MTCO 2e
per year, as summarized in DEIR Table 5.14-1.

Consistency with Applicable GHG Plans, Policies, or Regulations Pursuant to 15604.4 of the CEQA Guidelines, a lead agency may rely on a qualitative analysis or performance-based standards to determine the significance of impacts from GHG emissions. As such, the project’s consistency with the California Air Resources Bo ard’s (CARB) 2022 Scoping Plan for Achieving Carbon Neutrality (2022 Scoping Plan) is discussed below. It should be noted that the project’s significance is tied to consistency with the 2022 Scoping Plan which is authorized under CEQA Guidelines 15064.4 as discussed above. Consistency with the 2022 Scoping Plan also satisfies consistency with AB 32 since the 2022 Scoping Plan is based on the overall targets established by AB 32 and SB 32. Consistency with the 2008 and 2017 Scoping Plan is not necessary since both of these plans have been superseded by the 2022 Scoping Plan. For reasons outlined herein, the proposed project has the potential to result in a significant impact since the project has the potential to conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs. As detailed below, impacts were determined to be significant and unavoidable.

Consistency with the 2022 Scoping Plan
The 2022 Scoping Plan includes three priority areas to reduce GHG emissions that would apply to all land use development projects. More specifically, the three priority areas include: (1) transportation electrification, (2) VMT reduction, and (3) Building Decarbonization. The potential for the Project to conflict with these three priority areas is summarized below in DEIR Table 5.14-5, Consistency with 2022 Scoping Plan Key Residential and Mixed-Use Project Attributes That Reduce GHGs. It should be noted that the 2022 Scoping Plan priority areas are identified only for residential and mixed-use land use types, and 97 are not considered for other land use types, including industrial uses. However, DEIR Table 5.14-5 applies the general principles of the project area.

Since the Annexation Area have the potential to conflict with the transportation electrification and building decarbonization priority areas outlined in the 2022 Scoping Plan, the Annexation Area have the potential to impede the State’s progress towards carbon neutrality by 2045 under the 2022 Scoping Plan.

For reasons outlined herein, the Annexation Area would result in a potentially significant impact with respect to consistency with the 2022 Scoping Plan.

Consistency with the City of Lancaster Climate Action Plan Energy-saving and sustainable design Mitigation Measures AQ -8 through AQ-11, AQ-13 through AQ-15, AQ-17 through AQ -21, and AQ -23 through AQ -25, features, and operational programs would be incorporated into facilities developed pursuant to the requirements of the City of Lancaster Climate Action Plan. These measures would assist in further reducing the GHG emissions of future development within the annexation area and in the City’s goals towards minimizing GHG emissions.

Specific Plan Analysis
Generation of Greenhouse Gas Emissions
Emissions Associated With Specific Plan Area
According to the AVAQMD CEQA and Federal Conformity Guidelines, the annual emissions threshold for GHG emissions is 100,000 tons of CO
2 equivalent per year (tons CO 2e per year), which is equivalent to 90,719 metric tons of CO2 equivalent per year (MTCO2e per year).

As shown in DEIR Table 5.14-3, Planning Areas 1, 3, and 5 GHG Emissions Summary - Without Mitigation (2040), construction and operation of Planning Area 1, 3, and 5 would generate a total of approximately 199,480.47 MTCO2e per year. The annual GHG emissions associated with the operation of the proposed project at buildout of the proposed industrial uses within the Specific Plan (inclusive of Planning Areas 1, 3, and 5 and Planning Areas 2, 4, 6 [east], 7, and 8) is estimated to be approximately 280,759.04 MTCO 2e
per year, as summarized in DEIR Table 5.14-4, Specific Plan GHG Emissions Summary – Without Mitigation.

Thus, the Specific Plan would exceed the AVAQMD significance threshold of 90,719 MTCO2e per year.

Future development within the annexation area would occur incrementally over time, based largely on economic considerations, market demand, and other planning considerations. Future development within the annexation area would be analyzed at a detailed level and be reviewed by the City on a case-by-case basis to ensure that development occurs in a logical manner consistent with the General Plan, Municipal Code, and that additional review is conducted, as needed.

During construction, future development within the Specific Plan would be required to comply with Mitigation Measures AQ -3, AQ -4, and AQ -6 to reduce construction GHG emissions. During operation, proposed development within the Specific Plan would be requir ed to comply with Mitigation Measures AQ-8 through AQ-11, AQ-13 through AQ-15, AQ-17 through AQ-21, and AQ-23 through AQ-25 to reduce operational GHG emissions. None of the mitigation measures are quantifiable at this planning stage. There is currently no proposed development within the Specific Plan outside of Planning Areas 2, 4, 6, (east), 7, and 8, which is discussed below. As such, the type of construction, the duration of the construction, and when the construction will commence is unknown. Likewise, the use, intensity of the operation, and the commencement of the operation is unknown for any future development. Thus, it is not possible to 98 quantify the effectiveness of this mitigation at this stage. However, as previously discussed, the AVAQMD’s significance threshold of 90,179 MTCO 2e per year is only included for informative purposes.

Instead, the project’s significance would be tied to the consistency with applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases, which is authorized under CEQA Guidelines Section 15064.4.

Consistency with Applicable GHG Plans, Policies, or Regulations Pursuant to 15604.4 of the CEQA Guidelines, a lead agency may rely on a qualitative analysis or performance-based standards to determine the significance of impacts from GHG emissions. As such, the project’s consistency with the California Air Resources Board’s (CARB) 2022 Scoping Plan for Achieving Carbon Neutrality (2022 Scoping Plan) is discussed below. It should be noted that the project’s significance is tied to consistency with the 2022 Scoping Plan which is authorized under CEQA Guidelines 15064.4 as discussed above. Consistency with the 2022 Scoping Plan also satisfies consistency with AB 32 since the 2022 Scoping Plan is based on the overall targets established by AB 32 and SB 32. Consistency with the 2008 and 2017 Scoping Plan is not necessary since both of these plans have been superseded by the 2022 Scoping Plan. For reasons outlined herein, the proposed project has the potential to result in a significant impact since the project has the potential to conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs. As detailed below, impacts were determined to be significant and unavoidable.

Consistency with the 2022 Scoping Plan
The 2022 Scoping Plan includes three priority areas to reduce GHG emissions that would apply to all land use development projects. More specifically, the three priority areas include: (1) transportation electrification, (2) VMT reduction, and (3) Building Decarbonization. The potential for the Project to conflict with these three priority areas is summarized below in DEIR Table 5.14-5, Consistency with 2022 Scoping Plan Key Residential and Mixed-Use Project Attributes That Reduce GHGs. It should be noted that the 2022 Scoping Plan priority areas are identified only for residential and mixed-use land use types, and are not considered for other land use types, including industrial uses. However, DEIR Table 5.14-5 applies the general principles of the project area.

Since the Specific Plan (including Planning Areas 2, 4, 6 [east], 7, and 8) have the potential to conflict with the transportation electrification and building decarbonization priority areas outlined in the 2022 Scoping Plan, the Annexation Area and Specif ic Plan (including Planning Areas 2, 4, 6 [east], 7, and 8) have the potential to impede the State’s progress towards carbon neutrality by 2045 under the 2022 Scoping Plan.

For reasons outlined herein, the Specific Plan (including Planning Areas 2, 4, 6 [east], 7, and 8) would result in a potentially significant impact with respect to consistency with the 2022 Scoping Plan.

Consistency with the City of Lancaster Climate Action Plan Energy-saving and sustainable design Mitigation Measures AQ -8 through AQ-11, AQ-13 through AQ-15, AQ-17 through AQ -21, and AQ -23 through AQ -25, features, and operational programs would be incorporated into facilities developed pursuant to the requirements of the City of Lancaster Climate Action Plan (City of Lancaster CAP). These measures would assist in further reducing the GHG emissions of future development within the Specific Plan (including Planning Areas 2, 4, 6 [east], 7, and 8) and in the City’s goals towards minimizing GHG emissions.

99 Planning Areas 2, 4, 6 (east), 7, and 8 Analysis
Emissions Associated With Planning Areas 2, 4, 6 (east), 7, and 8 As shown in Table 5.14 -2, Planning Areas 2, 4, 6 (East), 7, and 8 GHG Emissions Summary - Without Mitigation (2031), construction and operation of proposed industrial uses within Planning Areas 2, 4, 6 (east), 7, and 8 of the Specific Plan area would generate a total of approximately 81,278.57 MTCO 2e per year. The annual GHG emissions associated with the operation of the proposed project at buildout of the proposed industrial uses within the Specific Plan is estimated to be approximately 280,759.04 MTCO 2e per year, as summarized in DEIR Table 5.14 -4. Thus, the Specific Plan would exceed the AVAQMD significance threshold of 90,719 MTCO2e per year.

However, as previously discussed, the AVAQMD’s significance threshold of 90,179 MTCO 2e per year is
only included for informative purposes. Instead, the project’s significance would be tied to the consistency with applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases, which is authorized under CEQA Guidelines Section 15064.4.

the 2022 Scoping Plan priority areas are identified only for residential and mixed-use land use types, and are not considered for other land use types, including industrial uses. However, DEIR Table 5.14-5 applies the general principles of the project area.

Since Planning Areas 2, 4, 6 [east], 7, and 8 have the potential to conflict with the transportation electrification and building decarbonization priority areas outlined in the 2022 Scoping Plan, the Planning Areas 2, 4, 6 [east], 7, and 8 have the potential to impede the State’s progress towards carbon neutrality by 2045 under the 2022 Scoping Plan. For reasons outlined herein, the Planning Areas 2, 4, 6 [east], 7, and 8 would result in a potentially significant impact with respect to consistency with the 2022 Scoping Plan.

Consistency with the City of Lancaster Climate Action Plan Energy-saving and sustainable design Mitigation Measures AQ -8 through AQ-11, AQ-13 through AQ-15, AQ-17 through AQ -21, and AQ -23 through AQ -25, features, and operational programs would be incorporated into facilities developed pursuant to the requirements of the City of Lancaster Climate Action Plan. These measures would assist in further reducing the GHG emissions of future development within Planning Areas 2, 4, 6 [east], 7, and 8 and in the City’s goals towards minimizing GHG emissions.

C. NOISE
The thresholds of significance for noise impacts are listed in Section 5.16, Noise, on page 5.16-12 through

5.16-16 of the DEIR. Impact analyses were detailed on pages 5.16-16 through 5.16-42.

Potential Impact: Future noise levels associated with implementation of the proposed project could result in a substantial permanent increase in ambient noise levels in the project vicinity and expose persons to or generate noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies.

Finding: The City hereby makes Finding 3.

Facts in Support of Findings:

Annexation Analysis
Implementation of the proposed annexation would not directly generate stationary operational noise levels as no specific development is proposed. All future development within the annexation area would be subject to project -specific and site-specific discretionary approvals (including separate CEQA review) on a case-by-case basis to ensure that stationary operational noise would not result in a significant noise impact. All developments and land use would be required to comply with the City’s noise standard s.

Overall, impacts would be less than significant.

Specific Plan Analysis
The proposed Specific Plan area would permit light and heavy industrial warehouse uses. Future developments within the Specific Plan area could result in increased traffic and thus, increased traffic noise levels on -site and on adjacent roadways. According to DEIR Table 5.16 -4, Significance Criteria Summary, a significant impact would occur if the following criteria are met:

101

i. If the existing ambient noise levels is less than 60 dBA CNEL, a significant impact would occur if a project would increase the ambient noise levels by 5 dBA CNEL or more. ii. If the existing ambient noise levels is between 60 to 65 dBA CNEL, a significant impact would occur if a project would increase the ambient noise levels by 3 dBA CNEL or more. iii. If the existing ambient noise levels is greater than 65 dBA CNEL, a significant impact would occur if a project would increase the ambient noise levels by 1.5 dBA CNEL or more.

Due to the programmatic nature of the Specific Plan, exact traffic volumes generated by future development is unknown. All future new development projects capable of generating substantial mobile noise would be required to undergo separate environmental re view under CEQA to evaluate project- specific impacts on a project-by-project basis, as the extent of impacts become known through the design process. Further, these future new development projects would be required to implement any required mitigation meas ures on a project -by-project basis, as applicable, pursuant to CEQA provisions.

Nonetheless, as detailed under the “Planning Areas 2, 4, 6 (east), 7, and 8 Analysis” below, off-site traffic noise impacts associated with the proposed development on Planning Areas 2, 4, 6 (east), 7, and 8 of the Specific Plan area would be significant and unavoidable.

Stationary noise would occur as a result of future new development associated with industrial warehouses in accordance with the Specific Plan. Stationary noise sources anticipated include mechanical equipment, loading areas, parking areas, heating, and ventilation units, etc. Given the programmatic level of the proposed Specific Plan, stationary noise impacts that may occur from future new development are speculative and cannot be accurately determined at this stage of the planning process. Further, all future new development projects would be required to undergo separate environmental review under CEQA to evaluate project-specific stationary noise impacts to nearby sensitive receptors and identify any required mitigation. Additionally, future new development associated with buildout of the Specific Plan would be required to adhere to the development standards pertaining to noise. Additionally, the stationary operational noise levels from the proposed industrial uses in Planning Areas 2, 4, 6 (east), 7, and 8 were combined with the existing ambient noise levels. As detailed under the “Planning Areas 2, 4, 6 (east), 7, and 8 Analysis” below, noise sources associated with operation of the proposed development on Planning Areas 2, 4, 6 (east), 7, and 8 of the Spe cific Plan area would not result in a significant increase in the ambient noise levels.

Overall, significant and unavoidable operation noise (mobile noise) would occur pertaining to future new development within the Specific Plan Area.

Planning Areas 2, 4, 6 (east), 7, and 8 Analysis
Within Planning Areas 2, 4, 6 (east), 7, and 8, 11.3 million sf of industrial warehouse uses and associated site improvements are proposed to be constructed. The following analysis assumes the implementation of several design features such as positioning the orientation of loading dock areas away from sensitive receptors and increasing building setback by placing large parking lot areas between the loading docks and the residential areas (i.e., Leisure Lakes Mobile Estates). Specifically, Planning Area 2 wo uld position loading docks in a north-south orientation which would ensure sensitive receptors to the west (i.e., Leisure Lakes Mobile Estates) does not have a clear line of sight from activities within the warehouse. The lack of a clear line of sight would attenuate noise. Additionally, the increase in building setback would increase 102

the overall distance from warehouse uses and sensitive receptors and as such, would attenuate noise due to distance.

Mobile Noise
As discussed, implementation of the proposed development would result in traffic noise increases on 14 study area roadway segments under the existing condition, which would exceed the incremental noise level thresholds shown in DEIR Table 5.16-4. To mitigate noise from off-site traffic, the implementation of noise barriers and rubberized asphalt were considered. Specifically, the implementation of rubberized asphalt was considered on 14 roadway segments that would result in potentially significant off-site traffic noise; refer to DEIR Tables 5.16-13, Existing With Proposed Development Traffic Noise Level Increase, and

5.16-16, Background (2031) With Proposed Development Traffic Noise Level Increase. Implementation of rubberized asphalt can provide noise attenuation of approximately 4 dBA from roadway noise. However, it should be noted that the proposed development’s off-site traffic would be primarily comprised of heavy trucks. Noise from heavy trucks would not be reduced from rubberized asphalt as the noise sources from heavy trucks (truck engine and exhaust stack) would be located approximately 11.5 feet above the ground.

As such, implementation of rubberized asphalt would only reduce tire/pavement noise associated with automobiles and would not adequately reduce project-generated off-site noise levels below significance thresholds. Nevertheless, rubberized asphalt is the City standard for all roadways and any new roadway construction within the annexation area will be required to utilize rubberized asphalt. Thus, implementation of rubberized asphalt is not a feasible mitigation measure.

The implementation of off-site noise barriers to reduce traffic noise was also considered. Noise barriers would provide a 5 dBA noise reduction by blocking the line of site from the noise source and the receptor.

However, as previously discussed, heavy tru cks noise sources (truck engine and exhaust stacks) are located approximately 11.5 feet above the ground. While the construction of 12-foot-high noise barriers could conceivably reduce the absolute exterior noise levels, it will not change the fact that th e source traffic noise levels will increase due to the added traffic volumes. In addition, any noise barriers would block views and result in aesthetic and visual impacts affecting passersby that would offset any noise attenuation benefits that may result from such walls. Lastly, many of the needed off -site walls are on property owned or controlled by others. As such, the implementation of noise barriers tall enough (11.5 feet) and long enough to reduce impacts along roadways would be infeasible. Additional ly, project applicants cannot construct off-site walls or other features at properties owned by other individuals and businesses and sound walls along City roadways would conflict with the General Plan. As such, construction of noise barriers is infeasible and would not be viable as a proposed mitigation measure. Off- site traffic noise impacts associated with the proposed development on Planning Areas 2, 4, 6 (east), 7, and 8 of the Specific Plan area would be significant and unavoidable.

Stationary Sources and Operational Noise
DEIR Table 5.16- 18, Proposed Development Stationary Operational Noise Levels , displays the development’s combined noise levels from all sources during the daytime (7:00 a.m. to 10:00 p.m.) and nighttime (10:00 p.m. to 7:00 a.m.). As shown in DEIR Table 5.16- 18, operational noise levels at nearby receptors would range from 37.3 to 55.4 dBA CNEL.

To demonstrate compliance with local noise regulations, the stationary operational noise levels are evaluated against exterior noise level thresholds based on the City’s exterior noise level standards at the nearest noise -sensitive receptor locations. As s hown in DEIR Table 5.16 -19, Operational Noise Level 103

Compliance, operational noise levels associated with the proposed industrial uses would not exceed applicable exterior noise standards.

Additionally, the stationary operational noise levels from the proposed industrial uses in Planning Areas 2, 4, 6 (east), 7, and 8 were combined with the existing ambient noise levels. As shown in DEIR Table 5.16- 20, Proposed Development Operational Noise Level Increase , noise sources associated with operation of the proposed development would not result in a significant increase in the ambient noise levels.

As such, stationary noise sources and operational noise associated with the proposed industrial uses in Planning Areas 2, 4, 6 (east), 7, and 8 would not exceed the applicable exterior noise standards. Impacts would be less than significant.

Potential Impact: The proposed project, in conjunction with related projects, could result in cumulatively significant operational noise impacts.

Finding: The City hereby makes Finding 3.

Facts in Support of Findings:

Mobile Noise
Cumulative projects would be required to undergo environmental review on a project-by-project basis to evaluate operational mobile noise impacts and implement any required mitigation measures, as applicable, pursuant to CEQA provisions. As discussed above, the buildout of the annexation area would introduce up to 163,472. Of which, the proposed industrial uses in Planning Areas 2, 4, 6 (east), 7, and 8 would generate 21,182 two-way trips per day, which includes 4,940 truck trips. The proposed annexation would not propose any specific development; however, buildout of the annexation area based on the proposed land use designations would result in approximately 163,472 trips. The proposed development in Planning Areas 2, 4, 6 (east), 7, and 8 of the Specific Plan would exceed applicable noise significance thresholds along surrounding roadways; refer to DEIR Tables 5.16 -13 and 5.19- 16. Due to the programmatic nature of Planning Areas 1, 3, and 5, exact trip generation from permitted uses and their corresponding trip distribution along local roadways are unknown during this planning process.

Nevertheless, all future new development projects would be required to undergo separate environmental review under CEQA to evaluate project -specific mobile noise impacts to ne arby sensitive receptors and identify any required mitigation.

As the proposed development would exceed applicable noise thresholds for off -site mobile noise, cumulative impacts would similarly be significant and unavoidable. As previously discussed, there are no feasible mitigation measures to reduce off-site traffic noise associated with the proposed developments in Planning Areas 2, 4, 6 (east), 7, and 8 of the Specific Plan. As such, the project’s cumulative mobile noise impacts would be significant and unavoidable.

Stationary Noise
Although cumulative projects have been identified within the project vicinity, noise generated by stationary sources on a given site cannot be quantified due to the speculative nature of each development. Each cumulative project would require separate discretionary approval and CEQA assessment, which would address potential noise impacts and identify necessary attenuation measures, where appropriate. Additionally, as noise dissipates as it travels away from its source, noise impacts from 104

stationary sources would be limited to each of the respective sites and their vicinities. The closest cumulative projects to Planning Areas 2, 4, 6, 7, and 8 are Cumulative Projects 16, 20, 24, and 27; refer to DEIR Exhibit 4 -1. However, the construction i mpacts for Cumulative Projects 16 and 27 are evaluated above as they are located in Planning Areas 2, 4, 6, 7, and 8. The next closest cumulative projects to the Specific Plan area are Cumulative Projects 20 and 24. However, as noted above, the proposed development in Planning areas 2, 4, 6, 7, and 8 would not result in significant stationary noise impacts that would significantly affect surrounding sensitive receptors. It should be noted that the evaluation above was unable to quantify stationary noise impacts from annexation area and Planning Areas 1, 3, and 5 due to its programmatic nature (i.e., lack of information regarding site plans, location of stationary sources, and density of stationary sources, etc.). Nevertheless, the proposed project would not result in cumulatively considerable stationary noise impacts. Impacts would be less than significant.

7. FINDINGS ON PROJECT ALTERNATIVES CONSIDERED IN THE DRAFT EIR The CEQA Guidelines indicate that an EIR must “[d]escribe a range of reasonable alternatives to the project, or to the location of the project, which could 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.” (CEQA Guidelines Section 15126.6(a).) Accordingly, the alternatives selected for review in the Draft EIR focus on alternatives that could eliminate or reduce significant environmental impacts to a level of insignificance, consistent with the project’s objectives (i.e., the alternatives could impede to some degree the attainment of project objectives, but still would enable the project to obtain its basic objectives.) Four alternatives to the proposed project were considered in the Draft EIR, as follows:
• Alternative 1: No Project/County General Plan Alternative; • Alternative 2: Reduced Intensity Alternative;
• Alternative 3: No Specific Plan Alternative; and
• Alternative 4: Modified Mixed-Use Alternative.

Each of these alternatives was considered in terms of their ability to reduce significant impacts of the proposed project, their feasibility, and the ability to achieve the project’s objectives. The project’s objectives are as follows:

1. Encourage development of various land use types in northern Lancaster, including residential, mixed-use, industrial, and public uses.

2. Accommodate employment -generating land uses in Lancaster that provide jobs to local residents and contribute towards the City’s economic development.

3. Implement City of Lancaster General Plan policies and objectives relevant to the project and proposed industrial development.

4. Expand economic development and facilitate job creation in the City by establishing a new industrial development area.
105

5. Attract new businesses to the City and thereby provide a more equal jobs-housing balance in the Antelope Valley that reduce the need for members of the local workforce to commute outside the area for employment.

6. Provide for uses that generate tax revenue for the City, including, but not limited to, increased property tax, in order to support the City’s ongoing municipal operations.

7. Accommodate new development in a phased, orderly manner that is coordinated with the provision of necessary infrastructure and public improvements.

8. Maximize development of Class A speculative warehouse industrial buildings in the project area that meet contemporary industry standards for operational design criteria, can accommodate a wide variety of users, and are economically competitive, to assist the City in competing economically on a domestic and international scale through the efficient and cost- effective movement of goods.

9. Guide future light and heavy industrial development in northern Lancaster in a manner that is visually cohesive, environmentally sustainable, and compatible with existing and planned uses in the surrounding area.

10. Ensure adequate public services and utility services are provided to accommodate future growth in northern Lancaster.

A. ALTERNATIVES CONSIDERED AND SUBSEQUENTLY DISMISSED
An EIR must briefly describe the rationale for selection and rejection of alternatives. The Lead Agency may make an initial determination as to which alternatives are potentially feasible and therefore, merit in-depth consideration, and which are clearly infeasible. Alternatives that are remote or speculative, or the effects of which cannot be reasonably predicted, need not be considered (CEQA Guidelines Section 15126.6(f)(3)). This section identifies alternatives considered by the Lead Agency, but rejected as infeasible, and provides a brief explanation of the reasons for their exclusion. As noted above, alternatives may be eliminated from detailed consideration in the EIR if they fail to meet most of the project objectives, are infeasible, or do not avoid any significant environmental effects (CEQA Guidelines Section 15126.6(c)).

1. Alternative Site
CEQA requires a discussion of alternatives to the project or its location that are capable of avoiding or substantially lessening any significant effects of the project. The key question and first step in the analysis is evaluating whether any of the significant effects of the project would be avoided or substantially lessened by developing the project in another location. Only locations that would avoid or substantially lessen any of the significant effects of the project need be considered for inclusion in the EIR (CEQA Guidelines Section 15126[5][B][1]). In general, any industrial development allowed by the North Lancaster Industrial Specific Plan (Specific Plan) would have similar impacts related to air quality and GHG emissions. Further, potential impac ts related to energy, population and housing, public services, and utilities and service systems would generally be similar regardless of where it is developed within Lancaster and its Sphere of Influence (SOI). Without a site-specific analysis, impacts on aesthetics, cultural resources, geology and soils, hazards and hazardous materials, hydrology/water quality, land use and planning, noise, and transportation cannot be adequately evaluated. 106

Although there are other large areas of undeveloped land within the City and the City’s SOI, they are not as suitable for the proposed project. For example, there is approximately 430 acres of vacant land located in the center of the City (south of Avenue K and west of Sierra Highway). However, it is too small for the proposed large scale industrial development planned under the North Lancaster Industrial Specific Plan (NLISP). Additionally, this site is surrounded by existing uses including residential, pa rk, and commercial uses. The proximity to these uses makes it unsuitable for large industrial developments as envisioned by the proposed project. The far east and west sides of Lancaster also have vast areas of vacant land. However, there are higher concentrations of residences in these areas and they are located too far away from major transportation routes, such as SR -14 and Sierra Highway. Further, the west side of Lancaster is predominantly developed with large scale solar facilities.

The northern portion of the City’s SOI was selected as an appropriate location for future industrial development given that a large portion of it consists of vacant, underutilized land. Additionally, there is growing interest in industrial development in Lancaster and the general Antelope Valley area. In general, industrial uses can result in adverse land use compatibility, air quality, transportation, and noise issues for nearby sensitive receptors/communities. Therefore, the location of the proposed project in the unincorporated and underutilized northern portion of Lancaster would allow development of future industrial uses while minimizing and/or eliminating these potential environmental issues. Further, future industrial development in northern Lancaster would meet the City’s desires to expand and develop this area while taking advantage of the site’s proximity to major transportation corridors including SR-14, SR- 138, and Sierra Highway. The location is also in close proximity to other industrially zone d properties in the City and the William J Fox Airfield.

Overall, the project site was selected as the most appropriate location within the City’s SOI for future industrial development due to its predominantly vacant and undeveloped lands and its proximity to major transportation corridors. Development of the project at an alternative location is not anticipated to avoid or substantially lessen the project’s significant and unavoidable impacts while achieving the majority of the project objectives. Thus, an alternative site alternative has been eliminated from fu rther consideration.

2. City General Plan Alternative
The City General Plan Alternative assumes the proposed annexation would occur but no specific plan would be adopted. Under the City General Plan Alternative, development in the annexation area would occur in accordance with existing City land use designations (Non- Urban Residential [NU], Heavy Industrial [HI], Specific Plan [SP], and Multi-Residential [MR -1]) for the project site. The City does not currently identify any zoning for the project site given that the site is outside of the City’s jurisdiction.

However, the annexation under this alternative would pre -zone the site with zoning districts that are consistent with the land use designations. Specifically, the site would be pre -zoned Rural Residential 2.5 (RR-2.5), Heavy Industry (HI), Specific Plan (SP), and Mobile Home Park (MHP). Anticipated City discretionary approvals for this alternative include a General Plan Amendment and Zone Change. The annexation would also be subject to the Los Angeles County Local Agency Formation Commission (LAFCO) annexation process.

This alternative would not adopt the North Lancaster Industrial Specific Plan, anticipated to guide development of up to 38.5 million sf of light and heavy industrial uses. Rather, the proposed annexation and associated General Plan Amendment and pre -zoning under this alternative would continue to allow for predominantly rural residential development in the project area as the mere annexation of 107

unincorporated County areas would not allow for any specific land use development to occur within the project site.

Development in accordance with existing City land use designations would not achieve most of the project objectives. Specifically, the project site would mostly remain as is (mostly rural residential and vacant land uses) and would not encourage development of various land use types in northern Lancaster, accommodate employment- generating land uses, expand economic development and facilitate job creation in the City by establishing a new industrial development area, provide a more equal jobs-housing balance in the Antelope Valley and reduce vehicle miles traveled, generate tax revenue, accommodate new development in a phased, orderly manner, assist the City in competing economically through the efficient and cost-effective movement of goods, guide future lig ht and heavy industrial development in northern Lancaster in a manner that is visually cohesive, environmentally sustainable, and compatible manner, nor ensure adequate public services and utility services are provided to accommodate future growth in northern Lancaster.

Furthermore, there is growing interest in industrial development in Lancaster and the general Antelope Valley area. This alternative would allow for future industrial development but would not provide specific guidance to future light and heavy industrial developments beyond the requirements contained in the Lancaster Municipal Code (LMC) for projects in the Light and Heavy Industrial zones.

Additionally, development of industrial uses without a specific plan is not anticipated to avoid or substantially lessen the project’s significant and unavoidable impacts while achieving the majority of the project objectives if future industrial development were to occur in the general area. In order to better encourage and accommodate future industrial development in Lancaster, a specific plan would be more adequate; thus, this alternative was considered but rejected from additional analysis.

3. Additional Mixed-Use Alternative
The Additional Mixed-Use Alternative would annex the project site into the City’s jurisdiction and adopt the North Lancaster Industrial Specific Plan, similar to the proposed project. However, this alternative would redesignate and pre -zone the northwest quadrant of the annexation area west of SR -

14. Specifically, this approximately 941 -acre area would deviate from the proposed NU land use designation and RR -2.5 pre -zoning (identified as Land Use 2 on Draft EIR Exhibit 3 -3) and instead, be designated MU and pre-zoned MU-E.

Other proposed land use designations and pre -zones within the project site would remain unchanged from the proposed project. Buildout of the Specific Plan would similarly result in 38.5 million sf of industrial development, of which up to 11.3 million sf would be developed in Planning Areas 2, 4, 6, 7, and 8. Similar to the proposed project, the Additional Mixed -Use Alternative would require the following City discretionary approvals: Annexation, General Plan Amendment, Pre -Zoning, and Specific Plan. This alternative would also be subject to the LAFCO annexation process.

This alternative would replace some of the rural residential uses with additional mixed use development, expanding economic opportunities in northern Lancaster by expanding the mixed use areas within the annexation area.

Development in accordance with the Additional Mixed -Use Alternative would achieve all of the project objectives. For example, additional mixed use development in the project site would encourage development of various land use types in northern Lancaster, accommodate employment-generating land uses, implement City of Lancaster General Plan policies and objectives, expand economic development 108

and facilitate job creation in the City by establishing a new industrial development area, provide a more equal jobs -housing balance in the Antelope Valley and reduce vehicle miles traveled, generate tax revenue, accommodate new development in a phased, orderly manner, assist the City in competing economically through the efficient and cost -effective movement of goods, guide future light and heavy industrial development in northern Lancaster in a manner that is visually cohesive, environmentally sustainable, and compatible manner, and ensure adequate public services and utility services are provided to accommodate future growth in northern Lancaster.

However, this alternative assumes 941 acres of additional mixed-use areas (beyond the 408 acres already proposed by the project) would be economically feasible and reasonable to occur. Additionally, the substantial increase in mixed-use development in the annexation area would exacerbate the proposed project’s anticipated significant and unavoidable impacts related to air quality, GHG emissions, and/or noise. Based on the alternative’s inability to avoid significant environmental impacts, this alternative was considered but rejected from additional analysis.

B. ALTERNATIVES ANALYZED IN THE DRAFT EIR
The following four alternatives were selected for further analysis in the Draft EIR:
• Alternative 1: No Project/County General Plan Alternative; • Alternative 2: Reduced Intensity Alternative;
• Alternative 3: No Specific Plan Alternative; and
• Alternative 4: Modified Mixed Use Alternative.

ALTERNATIVE 1: NO PROJECT/COUNTY GENERAL PLAN ALTERNATIVE In accordance with the CEQA Guidelines , “the no project analysis shall discuss the existing conditions …, as well as what would be reasonably 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.”
2 The CEQA Guidelines continue to state that “in certain instances, the no project alternative means ‘no build’ wherein the existing environmental setting is maintained.” 3 The No Project/County General Plan Alternative includes a discussion and analysis of the existing baseline conditions at the time the NOP was published on September 3, 2024. The No Project scenario is described and analyzed to enable the decision- makers to compare the impacts of approving the proposed project with the impacts of not approving the proposed project.

Under the No Project/County General Plan Alternative, the proposed annexation would not occur and the Specific Plan would not be adopted. The site’s current County land use designations (Rural Land 10 [RL10], Rural Land 20 [RL20], Rural Land 2 (RL2), Public and Semi-Public [P], Residential 5 [H5], Mixed- Use – Rural [MU- R], and Light Industrial [IL]) and zoning (Heavy Agricultural [A -2-2], Residential Agricultural [R -A], Light Manufacturing [M -1], and Rural Mixed Use Development [MXD -RU]) would remain in place. Thus, future development on -site would consist primarily of agricultural, residential agricultural, manufacturing, and rural mixed-use development consistent with the area’s existing County

2 CEQA Guidelines Section 15126.6(e)(2).
3 CEQA Guidelines Section 15126.6(e)(3)(B).
109

zoning. Major existing uses, including the Lancaster Water Reclamation Plant and mobile home parks would remain, similar to the proposed project.

Generally, the site’s current County land use designations and zoning would accommodate development intensities of similar nature as the proposed land use designations and pre -zones. For example, the areas in the northern portion of the site are currently designated RL10, RL20 and zoned A - 2-2 by the County. The project proposes to designate and pre-zone those areas NU and RR-2.5.

It is acknowledged that the southern portion of the project site, including the Specific Plan area, is predominantly designated IL and zoned M -1 by the County with a maximum floor area ratio (FAR) of

1.0. The proposed Specific Plan proposes a 0.5 FAR throu ghout the Specific Plan area and thus, this alternative would accommodate more industrial development intensity than the proposed project.

Further, a small area located in the western portion of the site (currently designated RL2 and zoned A -2-2) would develop mostly rural residential and/or heavy agricultural uses, resulting in less intense development intensities compared to the proposed pr oject, which proposes a MU designation and MU-E pre-zone for said areas.

In summary, this alternative would develop the project site in accordance with the site’s current County land use designations (RL10, RL20, RL2, P, H5, MU-R, and IL) and zoning (A-2-2, R-A, M-1, and MXD- RU). Buildout assumptions for this alternative assume the following:
• 3,426 acres of light manufacturing (approximately 10 million sf of industrial park and 10 million sf of general warehousing uses)
• 3,324 acres of heavy agricultural (20 single-family homes and 30,000 sf of wholesale nursery use)
• 247 acres of residential agricultural (25 single-family homes); and • 164 acres of mixed -use development (80 single family homes and 30,000 sf of commercial uses).

Based on these buildout assumptions, this alternative would result in approximately 55,500 total daily trips.

As detailed in Draft EIR Table 7 -1, No Project/County General Plan Alternative and Project Objectives, the No Project/County General Plan Alternative would not achieve any of the project’s basic objectives.

The No Project/County General Plan Alternative would eliminate the significant and unavoidable impact of the proposed project associated with air quality, GHG emissions, and noise. Compared to the proposed project, this alternative would be environmentally superior to the proposed project with regards to land use and planning, aesthetics/light and glare, hydrology and water quality, hazards and hazardous materials, public services and recreation, utilities and service systems, transportation, air quality, GHG emissions, energy, and noise; refer to Draft EIR Table 7 -5, Comparison of Alternatives. This alternative would result in similar environmental impacts to agriculture and forestry resources, biological resources, tribal and cultural resources, geology and soils, and population and housing; refer to Draft EIR Table 7-5.
110

Finding: While Alternative 1 would have less environmental impacts than the proposed project, it would not achieve any of the project’s objectives. The City therefore finds that Alternative 1 is not preferable to the proposed project.

ALTERNATIVE 2: REDUCED INTENSITY ALTERNATIVE
Similar to the proposed project, the Reduced Intensity Alternative would annex the approximately 7,153-acre project site into the City’s jurisdiction and adopt the North Lancaster Industrial Specific Plan to guide industrial development on approximately 1,860 acres in the central portion of the annexation area.

However, this alternative would reduce development intensity within the Specific Plan area by 30 percent; thus, reducing maximum buildout from approximately 38.5 million sf to approximately 27 millio n sf (26,971,700 sf). Allowed FAR would be proportionally reduced to be consistent with the 30 percent reduction in development intensity. No other changes to the proposed Specific Plan would occur.

Development intensity in the remainder of the annexation area would similarly be reduced by 30 percent.

The proposed land use designations and pre-zones for the remainder of the annexation area would be the same as the proposed project; refer to Exhibit 3-3. Similar to the proposed project, the Reduced Intensity Alternative would require the following City discretionary approvals: Annexation, General Plan Amendment, Pre- Zoning, and Specific Plan. This alternative would also be subject to the LAFCO annexation process. This alternative was selected for further anal ysis to determine whether reducing development intensity would result in a substantial reduction or elimination of the project’s significant and unavoidable air quality, GHG, and/or noise impacts.

As detailed in Draft EIR Table 7 -2, Reduced Intensity Alternative and Project Objectives , the Reduced Intensity Alternative would achieve most of the project’s objectives although to a lesser degree than the proposed project.

The Reduced Intensity Alternative would reduce the significant and unavoidable impact of the proposed project associated with air quality, GHG emissions, and noise , but the impacts would still remain significant and unavoidable. The Reduced Intensity Alternative would be environmentally superior to the proposed project with regards to aesthetics/light and glare, population and housing, public services and recreation, utilities and services systems, transportation, air quality, GHG emissions, energy, and no ise; refer to Draft EIR Table 7-5. This alternative would result in similar environmental impacts to land use and planning, agriculture and forestry resources, biological resources, tribal and cultural tribal resources, geology and soils, hydrology and water quality, and hazards and hazardous materials; refer to Draft EIR Table 7-5.

Finding: While Alternative 2 reduces the air quality, GHG emissions, and noise impacts of the proposed project, the impacts remain significant and unavoidable. Additionally, this alternative would achieve project objectives to a lesser degree than the proposed project. As such, the City finds this alternative to be less preferable than the proposed project.

ALTERNATIVE 3: NO SPECIFIC PLAN ALTERNATIVE
The No Specific Plan Alternative assumes the proposed annexation would occur, but no specific plan would be adopted. Similar to the proposed project, the construction of approximately 11.3 million sf of industrial warehouse buildings and associated site im provements in the central portion of the annexation area (within what would be Planning Areas 2, 4, 6, 7, and 8 of the Specific Plan) would still occur. To accommodate the proposed industrial uses, those areas would be designated and pre-zoned LI, which has a maximum FAR of 0.5.
111

The remainder of the annexation area would be developed in accordance with the proposed land use designations of NU, MU, LI, P, and MR1, and pre -zoned RR-2.5, MU-E, LI, P, and MHP, similar to the proposed project. Anticipated City discretionary approvals for this alternative include Annexation, General Plan Amendment, and Pre -Zoning. The annexation would also be subject to the LAFCO annexation process.

As detailed in Draft EIR Table 7 -3, No Specific Plan Alternative and Project Objectives , the No Specific Plan Alternative would achieve most of the project’s objectives although some to a lesser degree.

The No Specific Plan Alternative would not increase or reduce the significant and unavoidable impact of the proposed project associated with air quality, GHG emissions, and noise. The No Specific Plan Alternative would result in similar environmental impac ts to land use and planning, agriculture and forestry resources, biological resources, tribal and cultural resources, geology and soils, hydrology and water quality, hazards and hazardous materials, population and housing, public services and recreation, utilities and service systems, transportation, air quality, greenhouse gas emissions, energy, and noise; refer to Draft EIR Table 7 -5. The No Specific Plan Alternative would be environmentally inferior to the proposed project with regards to aesthetics/light and glare.

Finding: The No Specific Plan Alternative would not increase or reduce the significant and unavoidable impacts of the proposed project. While Alternative 3 would result in similar impacts in many topical areas as with the proposed project, this alternative would result in increased impacts in regard to aesthetics/light and glare. Further, this alternative would achieve the project objectives to a lesser degree than the proposed project. As such, the City finds this alternative to be less preferable than the proposed project.

ALTERNATIVE 4: MODIFIED MIXED-USE ALTERNATIVE
The Modified Mixed -Use Alternative assumes the proposed annexation would occur and the Specific Plan would be adopted. Similar to the proposed project, the Specific Plan would allow for 38.5 million sf of industrial uses and associated site improvements in the central portion of the annexation area. However, the mixed -use area proposed on the north and south side of Avenue D, west of SR -14 would be modified and reduced in size from approximately 408 acres to 325 acres. Specifically, under this alternative, the approximately 83-acre area north of Avenue D would be designated NU and pre-zoned as RR-2.5, and the approximately 325-acre area south of Avenue D would be designated MU and pre-zoned MU-C (Mixed Use – Commercial); refer to Draft EIR Exhibit 7 -1, Modified Mixed-Use Alternative. While this modification is still a mixed -use zoning which allows residential uses, the focus would be more on commercial type uses, including offices, and would prohibit light industrial uses.

The remainder of the annexation area would be developed in accordance with the proposed land use designations and pre-zones, similar to the proposed project. Anticipated City discretionary approvals for this alternative include Annexation, General Plan Amendment and Pre-Zoning. The annexation would also be subject to the LAFCO annexation process.

As detailed in Draft EIR Table 7 -4, Modified Mixed Use Development Alternative and Project Objectives, the Modified Mixed Use Development Alternative would achieve most of the project’s objectives although to a lesser degree.

The Modified Mixed-Use Alternative would reduce the significant and unavoidable impacts of the proposed project associated with air quality, GHG emissions, and noise, but the impacts would still remain 112

significant and unavoidable. The Modified Mixed -Use Alternative would be environmentally superior to the proposed project with regards to aesthetics/light and glare, transportation, air quality, GHG emissions, energy, and noise; refer to Draft EIR Table 7 -5. This alternative would result in similar environmental impacts to land use and planning, agriculture and forestry resources, biological resources, tribal and cultural tribal resources, geology and soils, hydrology and water quality, hazards and hazardous materials, population and housing, public services and recreation, and utilities and service systems; refer to Draft EIR Table 7-5.

Finding: While Alternative 4 reduces the air quality, GHG emissions, and noise impacts of the proposed project, such impacts would remain significant and unavoidable. Additionally, this alternative would achieve the project objectives to a lesser degree than the proposed project. As such, the City finds this alternative to be less preferable than the proposed project.

7. STATEMENT OF OVERRIDING CONSIDERATIONS
The City Council hereby declared that pursuant to CEQA Guidelines Section 15093, the Planning Commission has balanced the benefits of the proposed project against any significant and unavoidable environmental impacts in determining whether to approve the p roposed project. If the benefits of the proposed project outweigh the unavoidable adverse environmental impacts, those impacts are considered “acceptable”.

The City Council hereby declares that the EIR has identified and discussed significant effects that may occur as a result of the project. With the implementation of the mitigation measures discussed in the Draft EIR and FEIR, these impacts can be mitigated to a level of less than significant except for the significant and unavoidable impacts discussed herein. The City Council identified the following significant and unavoidable impacts despite implementation of existing regulations and mitigation measures:
• Air Quality
 Regional construction emissions
 Regional operational emissions
 AQMP consistency
 Cumulative air quality impacts
• GHG Emissions
 GHG emissions
 Cumulative GHG emissions
• Noise
 Project level off-site mobile traffic noise
 Cumulative off-site mobile traffic noise

The City Council hereby declares that it has made a reasonable and good faith effort to eliminate or substantially mitigate the potential impacts resulting from the project.

The City Council hereby declares that to the extent any mitigation measures recommended to the City are not to be incorporated, such mitigation measures are infeasible because they would impose restrictions on the project that would prohibit the realizatio n of specific economic, social, and other benefits that this City Council finds outweigh the unmitigated impacts. 113

The City Council further finds that except for the project, all other alternatives set forth in the FEIR are infeasible because they would prohibit the realization of the project objectives and/or specific economic, social, or other benefits that this City Council finds outweigh any environmental benefits of the alternatives.

The City Council hereby declares that, having reduced the adverse significant environmental effects of the project, to the extent feasible by adopting the proposed mitigation measures, having considered the entire administrative record on the project and having weighed the benefits of the project against its unavoidable significant impact after mitigation, the City Council has determined that the social, economic and environmental benefits of the project outweigh the potential unavoidable significant environmental impacts and render those potential significant impacts acceptable based on the following considerations:

A. The proposed project would encourage development of various land use types in northern Lancaster, including residential, mixed-use, industrial, and public uses.

B. Buildout of the project would result in up to 1,837 additional dwelling units within the City and contribute towards meeting the City’s housing goals.

C. The project would generate substantial new job opportunities for the local workforce within Lancaster, creating a more equal jobs-housing balance in the Antelope Valley.

D. New residences and businesses encouraged by the project would contribute towards the City’s economic development while reducing the need for residents to commute outside the area for employment.

E. The proposed project would provide for uses that generate tax revenue for the City, such as increased property tax, to support the City’s ongoing municipal operations.

F. The proposed project would accommodate industrial development in response to growing interest in industrial development in Lancaster and the greater Antelope Valley. With the adoption of the Specific Plan, future industrial developments would be developed in a phased, orderly manner and would meet contemporary industry standards for operational design criteria, accommodate a wide variety of users, and be economically competitive.

As the CEQA Lead Agency for the proposed action, the City of Lancaster has reviewed the project
description and the alternatives presented in the EIR and fully understands the project and project alternatives proposed for dev elopment. Further, this City Council finds that all potential adverse environmental impacts and all feasible mitigation measures to reduce the impacts from the project have been identified in the Draft EIR, the FEIR, and public testimony. This City Council also finds that a reasonable range of alternatives was considered in the EIR and this document and finds that approval of the project is appropriate.

This City Council has identified economic and social benefits and important policy objectives which result from implementing the project . The City Council has balanced these substantial social and economic benefits against the effects of the project. Given the substantial social and economic benefits that will accrue from the p roject, this City Council finds that the benefits identified herein override the unavoidable environmental effects.
114

California Public Resource Code 21002 provides: ‘In the event specific economic, social and other conditions make infeasib le such project alternatives or such mitigation measures, individual projects can be approved in spite o f one or more significant effects thereof.’ Section 2 1002.1(c) provides: ‘In the event that economic, social, or other conditions make it infeasible to mitigate one or more significant effects of a project on the environment, the project may nonetheless be approved or carried out at th e discretion of a public agency .. .’ Finally, California Administrative Code, Title 4, 15093(a) states: ‘If the benefits of a proposed project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered 'acceptable.’ The City Council hereby declares that the proposed project would result in project -specific and cumulatively significant and unavoidable environmental impacts. The City Council also declares that the foregoing benefits provided to the public through approval and implementation of the project outweigh the identified significant and unavoidable environmental impacts of the project.

The City Council finds
that each of the project benefits outweighs the unavoidable environmental impacts identified in the Draft EIR and therefore, finds those impacts to be acceptable.

Lancaster City CouncilOctober 14, 2025

Lancaster City Council
October 14, 2025