Cities Index.
Agenda packet

Los Alamitos City Council
November 18, 2024

Document
Agenda packet
Meeting
November 18, 2024
Body
Los Alamitos City Council
Pages
3,005
Original file
457.4 MB
Text extracted from the city's file for reading and search. Open the original on losalamitosca.api.civicclerk.com. That file is the official record.
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feet long in any parking space, driveway, or private street area except for the purpose of loading, unloading, making deliveries or emergency repairs except that the homeowners association may adopt rules and regulations to authorize exceptions.
ii. Residents shall park vehicles in garage spaces. Storage of personal items may occur in the garages only to the extent that vehicles may still be parked within the required garage spaces.
iii. The homeowners association shall be responsible for monitoring and enforcing all parking regulations on private property. The proposed CC&Rs shall include provisions requiring the association to develop and adopt an enforcement program for parking regulations within the development which may include measures for fire access and enforcement by a private security company. iv. Roadways within the community shall at all times remain open and unobstructed to allow public ingress and egress (including, without limitation, travel between Parcel 1 and Parcel 2); gates, fences and other means of access control are prohibited.
j. Provisions for enforcing individual trash cart placement at designated curb areas as shown on the approved “Trash Pick-up Plan” no earlier than noon (12:00 P.M.) on the day before scheduled collections and removed within twelve (12) hours of collection. k. Maintenance of all common areas, driveways, etc., shall be by the homeowners association.
l. Television and radio antennas shall be installed in accordance with the requirements of the LAMC.
m. All utility services serving the site shall be installed and maintained underground pursuant to LAMC 16.12.170.
n. The homeowners association shall be required to file the names, addresses, and telephone numbers of at least one (1) member of the homeowners association Board and, where applicable, a manager of the project before January 1st of each year with the Development Services Department for the purpose of contacting the association in the case of emergency or in those cases where the City has an interest in CC&R violations. o. The homeowners association shall be responsible for establishing and following procedures for providing access to public utilities for maintenance of their facilities within the project area, subject to those agencies' approval.
p. No amendment to alter, modify, terminate, or change the homeowners association's obligation to maintain the common areas and the project perimeter wall or other CC&R provisions in which the City has an interest, as noted above, or to alter, modify, terminate, or change the City's right to enforce maintenance of the common areas and maintenance of the project perimeter wall, shall be permitted without the prior written approval of the Development Services Department.

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FEES

29. In accordance with Government Code section 66477 and Chapter 16.18 of the Los Alamitos Municipal Code, the Applicant shall be required to pay $3,333,905.00 in parkland dedication (Quimby) fees prior to the final certificate of occupancy issued for the Project.

CONSTRUCTION

30. The Applicant shall deliver a construction schedule to the adjacent properties within 300 feet of the site to properly inform them of future construction, including the name and 24-hour contact information for a project manager for noise, dust, and other complaints.

31. All demolition and construction shall be done in accordance with Los Alamitos Municipal Code Demolition Chapter 8.13.

32. The Applicant must comply with all current California Building Codes and California Residential Codes, as applicable.

33. Project plans for the condominium development shall be subject to a complete code compliance review with the Development Services Department when the condominium plans are submitted for plan check and shall comply with all applicable City of Los Alamitos ordinances, regulations, and policies prior to building permit issuance, including, but not limited to, the requirements established or authorized by Title 15, 16, and 17 of the City of Los Alamitos Municipal Code.

34. The site shall be kept reasonably clean during construction and maintained in a safe, nuisance, and hazard-free condition. Dust control measures shall be employed to include spraying water on dry soil to ensure dust does not migrate onto adjacent properties.

35. During construction the site shall be maintained and kept clear of all trash, weeds, and overgrown vegetation.

36. Prior to demolition and construction, a temporary perimeter security fence not exceeding eight feet in height shall be installed around the project site to secure the site and shield the construction areas and public views. The fencing shall include a privacy screen material or approved equivalent. The fence/screen material shall be properly maintained and be free of rips, tears, fraying, graffiti, and any other damage or vandalism.

37. The Applicant will display a sign visible to the public with a 24-hour emergency contact number for an individual, such as the construction superintendent, should any resident have any questions about the construction.

38. The Project shall comply with all requirements of Chapter 17.20, Noise, of the Los Alamitos Municipal Code.

39. Noise sources associated with construction activities shall only occur between the hours of 7:00 a.m. and 8:00 p.m. on weekdays and on Saturdays and shall not take place at any time on Sundays or Federal holidays.

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40. All construction vehicles or equipment, fixed or mobile, operated within 1,000 feet of an existing dwelling shall be equipped with properly operating and maintained mufflers.

WQMP

41. Prior to issuance of any building permits, the Applicant shall submit to the City’s Water Quality Manager for review and approval a Final Water Quality Management Plan (WQMP). The reviewed and approved WQMP shall be recorded and a copy of the recorded WQMP shall be provided to the City’s Water Quality Manager. See also Condition No. 85.

LANDSCAPE

42. A landscape Irrigation Plan prepared by a licensed landscape architect shall be submitted to the Development Services Department prior to the issuance of building permits. The Irrigation Plan shall include an irrigation system layout with the location of controllers and points of connection with data on valve sizes and gallons per minute (G.P.M.), the size and location of sleeves and all spray heads, including the location of conventional systems and drip systems; an irrigation legend with complete specifications; irrigation notes and construction details of all assemblies and components; a recommended irrigation schedule, preferably on an annual basis; and a summary block on the initial page of submitted plans that will present the above information clearly and accurately. The City reserves the right to require subsequent checks, or approval of the landscape plans prior to issuance of a grading permit. See also Condition Nos. 66 and 67.

43. Landscaping shall comply with the City’s water conservation ordinances in accordance with Chapter 13.04 (Water Conservation) and Chapter 13.05 (Water Efficient Landscaping) of the Los Alamitos Municipal Code.

44. A phased landscape and irrigation plan shall be submitted for review and comply with the City’s Xeriscape Ordinance (Ord. No. 563). All required landscaping and irrigation shall be installed prior to the issuance of a certificate of occupancy for each corresponding phase.

45. All trees noted on the plans shall be planted outside of the Sight Safety Triangle or else be trimmed to eight feet in height from above the adjacent top of curb.

46. All landscaping on the site, including, without limitation, trees, shrubs and other vegetation, drainage and irrigation systems, shall be permanently maintained in good, first-class condition, healthy, without deterioration, free of waste and debris, through all phases of construction and after. Dead or diseased plants shall be promptly replaced with landscaping similar in type, size, and quality. Automatic Irrigation systems shall be properly maintained, and other reasonable and adequate landscape maintenance facilities and procedures shall be provided to fulfill the foregoing requirements.

47. The common open space area improvements shall be reviewed for consistency with the Project plans by the Development Services Department prior to issuance of building permits.

The common open space area identified as the “Neighborhood Green Space” on the Site Plan included as Figure 3-4 in the Draft EIR and centrally located within the Project site shall be

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completed at the time that the Applicant completes no more than 50 percent of the units (123 units).

LIGHTING

48. Prior to permit issuance Applicant shall submit a lighting plan to the Development Services Department to the satisfaction of the Development Services Director.

49. The Applicant shall provide adequate exterior lighting for each residential unit that maintains performance standards as described in Chapter 8.48 Lighting Performance Standards in the Los Alamitos Municipal Code. All lighting structures shall be placed so as to confine direct rays to the subject property.

50. The Applicant shall provide an illuminated uniform address number installed at each unit entryway.

UTILITIES

51. The Applicant shall submit detailed plans showing the proposed location of utilities and mechanical equipment to the Development Services Department for review and approval prior to the Building and Safety Division Plan check.

52. Above ground utility equipment (e.g., electrical, telephone, and cable TV) shall be screened if located in the front yard area of each unit, within the front yard setback, common open space area, or any parking spaces or sidewalks, and shall be screened to the satisfaction of the Development Services Director.

53. All exterior mechanical equipment shall be screened from view.

54. All utility meters, when not enclosed in a cabinet, shall be screened from view from any place on or off site, by either plant materials or decorative screen, while allowing sufficient access for reading.

SIGNAGE

55. All tract name signage at entry points to the project site shall be subject to the discretion and approval of the Development Services Director.

PARKING

56. Applicant shall construct and maintain at all times a minimum of 577 parking spaces on the combined parcels and a minimum nine (9) foot by nineteen (19) foot dimension per parking space with minimum drive aisle widths of twenty-four (24) feet.

57. Wheel stops/blocks or curbs as wheel stops shall be required for all parking spaces on exterior parking spaces as shown on the Project site plans.

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58. All units with a garage shall maintain within the garage the ability to park cars at all times.

Garages shall not be converted to any other use.

59. There shall be no business activities or day care conducted within or from the garages.

60. Residents shall not park or store vehicles anywhere on the site except within the designated parking spaces in the garage or driveways for their unit. However, the open parking spaces, located along the private driveways, may be utilized for residents or guest for temporary parking. Any issues arising from the use, application, or restriction of such open parking spaces shall be resolved by the Homeowner’s Association.

TRASH

61. Except as required for CC&Rs per Condition 28.j, Applicant shall design the refuse and recycling storage area in accordance with Section 17.16.090 of the Los Alamitos Municipal Code as applicable.

OTHER

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

63. The block wall on the south parcel line of the proposed Project that separates the Project from Lampson Avenue shall be 7 feet tall as measured from the exterior of the parcel and painted white.

MITIGATION MOINTORING AND REPORTING PLAN (MMRP)
Project Design Features (PDFs)

64. PDF AQ-1 - The Project will utilize Tier 4 Interim construction equipment during construction activities.

65. PDF B-1 - Pursuant to Figure 3-18, Landscape Plan, the Project will incorporate larger sized box tree species (including the western sycamore and cottonwood trees) that foliage specialist bats prefer and will plant the trees on the fringes of the development, adjacent to open space areas.

66. PDF B-2 - Pursuant to Figure 3-18, Landscape Plan, the Project will plant approximately 441 trees onsite (excluding shrubs and ground cover), including the western sycamore (Platanus racemosa), paperbark melaleuca (Melaleuca quinquenervia), olive (Olive sp.), southern magnolia (Magnolia grandiflora), Crape myrtle (Lagerstroemia indica), Brisbane box (Lophostemon confertus), Australian willow (Geijera parviflora), Italian cypress (Cupressus sempervirens), yew pine (Podocarpus macrophyllus) and other species. No plants listed on the California Invasive Plant Council (Cal-IPC)6 Inventory species will be planted and a list of approved species to planted shall be reviewed by a qualified biologist prior to planting.

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67. PDF GHG-1 - The Project will include solar photovoltaic panels with the capability to generate up to 1,229,520 kWh/annually.

68. PDF GHG-2 - The Project will be 100% electric and will not include natural gas.

69. PDF GHG-3 - The Project will provide a community electric vehicle for the affordable housing component for residents to drive short distance trips to the local grocery store.

70. PDF GHG-4 - The Project’s affordable apartment parking areas will be designed to provide electric vehicle (EV) charging stations. At minimum, the number of EV charging stations will equal the Tier 2 Residential Voluntary Measures of the California Green Building Standards Code, Section A4.106.8.2.1.

71. PDF HYD-1 - The Project will be built such that the finished floor elevation for the onsite buildings is set 1 foot minimum above the peak 100-year storm event water surface elevation in accordance with Orange County Flood Protection Requirements.

72. PDF N-1 - Prior to the issuance of occupancy permits, the Project will construct a 7-foot-high noise barrier along Lampson Avenue. The noise control barrier will be constructed so that the top of each wall and /or berm combination extends to the planned height above the pad elevation of the lot it is shielding. Since the pad elevations varies, the top of each wall and/or berm combination will be 7’ above each applicable pad elevation. When the roadway or terrain is elevated above the pad elevation, the barrier shall extend to the recommended height above the highest point between the residential home and the roadway. The barrier shall be built with a material surface weight of at least 4 pounds per square foot, with no decorative cutouts, perforations, or line-of-sight openings between residences and Lampson Avenue. The noise barrier shall be constructed using the following materials:
• Masonry block;
• Stucco veneer over wood framing (or foam core), or 1-inch-thick tongue and groove wood of at least four pounds per square foot;
• Material with sufficient weight per square foot capable of providing a minimum transmission loss of 20 dBA;
• Earthen berm; or,
• Any combination of these construction materials.

73. PDF N-2 - To comply with the State of California and City of Los Alamitos 45 A-weighted Decibels (dBA) Community Noise Equivalent Level (CNEL) interior noise standards for residential land use, the Project will provide the following or equivalent noise abatement measures on building plans:
• Windows & Glass Doors: At a minimum the Project will provide windows and glass doors that are well-fitted, well-weather-stripped assemblies with minimum sound transmission class (STC) ratings of 27. Additionally, all second-floor facades adjacent to Lampson Avenue and JFTB Los Alamitos will be provided windows and glass doors that are wellfitted, well-weathers-tripped assemblies with minimum sound transmission class (STC) ratings of 29.

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• Doors (Non-Glass): All exterior doors shall be well weather-stripped and have Wellsealed perimeter gaps around the doors are essential to achieve the minimum STC rating.
• Walls: At any penetrations of exterior walls by pipes, ducts, or conduits, the space between the wall and pipes, ducts, or conduits shall be caulked or filled with mortar to form an airtight seal.
• Roof: Roof sheathing of wood construction shall be per manufacturer’s specification or caulked plywood of at least one-half inch thick. Ceilings shall be per manufacturer’s specification or well-sealed gypsum board of at least one-half inch thick. Insulation with at least a rating of R-19 shall be used in the attic space. • Ventilation: Arrangements for any habitable room shall be such that any exterior door or window can be kept closed when the room is in use and still receive circulated air. A forced air circulation system (e.g. air conditioning) or active ventilation system (e.g. fresh air supply) shall be provided in compliance with applicable State and local Building Codes (e.g. California Building Code, Chapter 3, R338.3).

Mitigation Measures (MMs)

74. MM 4.3-1 - Vegetation clearing should be conducted outside of the nesting season (February 1 through September 15). If avoidance of the nesting season is not feasible, then a qualified biologist shall conduct a pre-construction nesting bird survey within three days prior to any disturbance to the Project site. Site disturbance includes disking, demolition activities, vegetation removal and grading. If active nests are identified, the biologist shall establish appropriate avoidance buffers around the nest (based on the species detected), and the buffer areas shall be avoided until the nests are no longer occupied (through routine nest monitoring by the qualified biologist) and the juvenile birds can survive independently from their nest(s).

In addition, if portions of the Project site have not been disturbed within three days after the initial nesting bird survey, additional nesting bird surveys will be conducted (within the nesting bird season, February 1 to September 15) until all portions of the Project site have been disturbed appropriately (as determined by a qualified biologist) as to not provide potential nesting habitat.

75. MM 4.3-2 - If tree removal or ground disturbance occurs during the raptor nesting season (from approximately January 1 to July 31), pre-removal/disturbance surveys shall be conducted. The surveys shall include areas of suitable nesting trees within 300-feet from the limits of disturbance (to the extent that access is available). The survey shall be conducted no more than three days prior to disturbance. Should nesting raptors be detected either onsite or offsite, work would be delayed until fledglings have left the nest and area no longer dependent on the nest at which time, work could proceed.

76. MM 4.3-3 - A qualified biologist shall conduct a pre-construction bat roost survey for roosting bats no more than 14 days prior to site disturbance. The pre-construction bat roost survey will consist of a minimum of two bat surveys (conducted consecutively or as determined by the biologist). If roosting bats are detected onsite outside of the bat maternity season, the roost tree will be removed in a manner to avoid and/or minimize injury to roosting bats. This may include using mechanical equipment to gently nudge the tree trunk multiple times prior to

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removal or for palm trees and other species, to de-frond or de-branch the tree using a mechanical lift and gently lower the cut branches to the ground. Regardless of the method, the fallen tree and/or material will be left undisturbed overnight until at least the next morning to give roosting bats time to exit before site disturbance.

If roosting bats are detected onsite during the maternity season, the Project shall avoid the subject roost(s) and incorporate an avoidance buffer (as determined by a qualified biologist) until after the maternity season or until a qualified biologist determines no maternity roosting is occurring. Once the qualified biologist approves removal of the subject roost tree(s), the same tree removal procedures as outlined above shall be implemented prior to tree removal.

77. MM 4.4-1 - Discovery of Inadvertent Resources. Prior to the issuance of any grading permits, the Applicant shall submit proof that a qualified consulting archaeologist meeting the Secretary of Interior's (36 CFR 61) Professional Qualifications Standards has been retained to conduct periodic spot checks during ground disturbing activities. Spot check should occur at initial ground exposure within the project; upon a 50 percent completion milestone of ground disturbance; upon an 80 percent milestone of ground disturbance; or at any other time determined necessary by the consulting archaeologist. If any potentially historic or archaeological resources are encountered during ground-disturbing activities, the archaeologist shall halt construction work within 50 feet of the find and assess the nature of the find for importance.
a) If the discovery is determined to not be important by the archaeologist (e.g. isolates and clearly non-significant deposits), work will be permitted to continue in the area. If a find is determined to be potentially important by the archaeologist, the Lead Agency shall be notified, and additional investigation would be required. Additional investigation work would include scientific recordation and, depending on the nature of the find, excavation. b) At the conclusion of ground disturbing activities, the archaeologist shall draft a report detailing the monitoring process and summarize any additional field study and analysis of resources, should any be discovered. The completed report shall be approved by the Planning Department and the Applicant shall provide verification that the report was submitted to the Lead Agency prior to the issuance of an occupancy permit. c) Excavated finds shall be curated at a repository determined by the archaeologist and approved by the City with verification provided to the City prior to the issuance of an occupancy permit.

78. MM 4.4-2 - Discovery of Human Remains. If human burial or skeletal remains are identified during excavation or construction, work in that location shall stop immediately until the find can be properly treated. The construction contractor would be required by law to comply with California Health and Safety Code Section 7050.5 “Disturbance of Human Remains.” The County Coroner must be contacted and if the Coroner recognizes the human remains to be those of a Native American or has reason to believe that they are those of a Native American, the Coroner is required to contact the Native American Heritage Commission (NAHC) by telephone within 24 hours. Once the NAHC receives notification of a discovery of Native American human remains from a county coroner, the NAHC is required to immediately notify those persons it believes to be most likely descended from the deceased Native American.

The descendants may, with the permission of the owner of the land, or his or her authorized

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representative, inspect the Site of the discovery of the Native American human remains and may recommend to the owner or the person responsible for the excavation work means for treatment or disposition, with appropriate dignity, of the human remains and any associated grave goods. The descendants shall complete their inspection and make recommendations or preferences for treatment within 48 hours of being granted access to the site. According to Public Resources Code Section 5097.94(k), the NAHC is authorized to mediate disputes arising between landowners and known descendants relating to the treatment and disposition of Native American human burials, skeletal remains, and items associated with Native American burials.

79. MM 4.6-1 - Prior to the issuance of grading permits or building permits, the City of Los Alamitos Public Works & Engineering Department shall verify that all of the recommendations provided in Section 4.0 of the Project’s December 21, 2021 “Preliminary Geotechnical Evaluation and Design Recommendations for Proposed Single-Family and Multi-Family Residential Development, 4665 Lampson Avenue, Los Alamitos, California,” prepared by LGC Geotechnical, Inc. and included as Technical Appendix F1 to the Project’s EIR, are incorporated into the Project’s grading and building plans and implemented by the construction contractors. These recommendations include but are not limited to a) Site Earthwork Considerations; b) Preliminary Foundation Recommendations; c) Site Grading Recommendations; d) Soil Bearing and Lateral Resistance Considerations; e) Lateral Earth Pressures for Retaining Walls Considerations; f) Nonstructural Concrete Flatwork Recommendations; and g) Preliminary Asphalt Concrete Pavement Design Parameters.

Alternatively, the Project shall comply with the findings and recommendations of any geotechnical studies that may be required in association with future grading and/or building permits.

80. MM 4.6-2 - If paleontological resources are discovered during earth disturbance activities, the discovery shall be cordoned off with a 50-foot radius buffer so as to protect the discovery from further potential damage, and an Orange County Certified Professional Paleontologist shall be consulted to assess the discovery.

If the discovery is determined to be significant by the paleontologist, a monitoring and recovery plan shall be initiated, which will include notification of appropriate personnel involved and monitoring of earth disturbance activities.
a) Monitoring of mass grading and excavation activities shall be performed by a qualified paleontologist or paleontological monitor. Monitoring will be conducted full-time in areas of grading or excavation in undisturbed sediments of alluvial deposits. b) Paleontological monitors will be equipped to salvage fossils as they are unearthed to avoid construction delays. The monitor must be empowered to temporarily halt or divert equipment to allow removal of fossils in a timely manner. Monitoring may be reduced if the potentially fossiliferous units are not present in the subsurface, or, if present, are determined upon exposure and examination by qualified paleontological personnel to have low potential to contain fossil resources. The monitor shall notify the project paleontologist, who will then notify the concerned parties of the discovery. c) Paleontological salvage during trenching and boring activities is typically from the generated spoils and does not delay the trenching or drilling activities. Fossils will be

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collected and placed in cardboard flats or plastic buckets and identified by field number, collector, and date collected. Notes will be taken on the map location and stratigraphy of the site, which is photographed before it is vacated, and the fossils are removed to a safe place. If the site involves remains from a large terrestrial vertebrate, such as large bone(s) or a mammoth tusk, that is/are too large to be easily removed by a single monitor, a fossil recovery crew shall excavate around the find, encase the find within a plaster and burlap jacket, and remove it after the plaster is set. For large fossils, use of the contractor’s construction equipment may be solicited to help remove the jacket to a safe location. d) Recovered specimens will be prepared to a point of identification and permanent preservation (not display), including screen-washing sediments to recover small invertebrates and vertebrates.
e) Recovered specimens shall be identified and curated of specimens into a professional, accredited public museum repository with a commitment to archival conservation and permanent retrievable storage (e.g., OC Parks). The paleontological program should include a written repository agreement prior to the initiation of monitoring activities. Prior to curation, the lead agency (e.g., the City of Los Alamitos) will be consulted on the repository/museum to receive the fossil material.
f) A final report of findings and significance will be prepared, including lists of all fossils recovered and necessary maps and graphics to accurately record their original location(s).

The report, when submitted to, and accepted by, the appropriate lead agency, will signify satisfactory completion of the project program to reduce impacts to any potential nonrenewable paleontological resources (i.e., fossils) that might have been lost or otherwise adversely affected without such a program in place.

81. MM 4.15-1 - Prior to the issuance of certificate of occupancy, the project applicant shall provide documentation that it has implemented the CAPCOA strategies identified below.

Verification that the CAPCOA strategies were completed shall be verified by the City’s Public Works Director.

1. Provide pedestrian and bicycle network improvements within the development connecting to existing off-site facilities, as detailed in Section 3.3.2 of this EIR.

2. Confirm with the OCTA whether providing new or re-routing existing transit services to the site would be feasible, as determined by OCTA pursuant to OCTA’s standards.

3. Install broadband infrastructure or other communication technologies that encourages telecommuting and working from home, which would reduce mobile source emission.

82. MM 4.16-1 - Retain a Native American Monitor Prior to Commencement of Ground-Disturbing Activities.

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

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demolition, pavement removal, potholing, auguring, grubbing, tree removal, boring, grading, excavation, drilling, and trenching.

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

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

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

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

83. MM 4.16-2 - Unanticipated Discovery of Human Remains and Associated Funerary Object.

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

2. If Native American human remains and/or grave goods discovered or recognized on the project site, then all construction activities shall immediately cease. Health and Safety Code Section 7050.5 dictates that any discoveries of human skeletal material shall be immediately reported to the County Coroner and all ground-disturbing activities shall immediately halt and shall remain halted until the coroner has determined the nature of the remains. If the coroner recognizes the human remains to be those of a Native American or has reason to believe they are Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission, and Public Resources Code Section 5097.98 shall be followed.

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

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4. Construction activities may resume in other parts of the project site at a minimum of 200 feet away from discovered human remains and/or burial goods, if the Kizh determines in its sole discretion that resuming construction activities at that distance is acceptable and provides the project manager express consent of that determination (along with any other mitigation measures the Kizh monitor and/or archaeologist deems necessary). (CEQA Guidelines Section 15064.5(f).)

5. Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human remains and/or burial goods. Any historic archaeological material that is not Native American in origin (non-TCR) shall be curated at a public, non-profit institution with a research interest in the materials, such as the Natural History Museum of Los Angeles County or the Fowler Museum, if such an institution agrees to accept the material.

If no institution accepts the archaeological material, it shall be offered to a local school or historical society in the area for educational purposes.

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

84. MM 4.16-3 - Procedures for Burials and Funerary Remains.

1. As the Most Likely Descendant (“MLD”), the Koo-nas-gna Burial Policy shall be implemented. To the Tribe, the term “human remains” encompasses more than human bones. In ancient as well as historic times, Tribal Traditions included, but were not limited to, the preparation of the soil for burial, the burial of funerary objects with the deceased, and the ceremonial burning of human remains.

2. If the discovery of human remains includes four or more burials, the discovery location shall be treated as a cemetery and a separate treatment plan shall be created.

3. The prepared soil and cremation soils are to be treated in the same manner as bone fragments that remain intact. Associated funerary objects are objects that, as part of the death rite or ceremony of a culture, are reasonably believed to have been placed with individual human remains either at the time of death or later; other items made exclusively for burial purposes or to contain human remains can also be considered as associated funerary objects. Cremations will either be removed in bulk or by means as necessary to ensure complete recovery of all sacred materials.

4. In the case where discovered human remains cannot be fully documented and recovered on the same day, the remains will be covered with muslin cloth and a steel plate that can be moved by heavy equipment placed over the excavation opening to protect the remains. If this type of steel plate is not available, a 24-hour guard should be posted outside of working hours. The Tribe will make every effort to recommend diverting the project and keeping the remains in situ and protected. If the project cannot be diverted, it may be determined that burials will be removed.

5. In the event preservation in place is not possible despite good faith efforts by the Applicant, before ground-disturbing activities may resume on the project site, the landowner shall arrange a designated site location within the footprint of the project for the respectful reburial of the human remains and/or ceremonial objects.

6. Each occurrence of human remains and associated funerary objects will be stored using opaque cloth bags. All human remains, funerary objects, sacred objects and objects of

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cultural patrimony will be removed to a secure container on site if possible. These items should be retained and reburied within six months of recovery. The site of reburial/repatriation shall be on the project site but at a location agreed upon between the Tribe and the landowner at a site to be protected in perpetuity. There shall be no publicity regarding any cultural materials recovered.

7. The Tribe will work closely with the project’s qualified archaeologist to ensure that the excavation is treated carefully, ethically, and respectfully. If data recovery is approved by the Tribe, documentation shall be prepared and shall include (at a minimum) detailed descriptive notes and sketches. All data recovery data recovery-related forms of documentation shall be approved in advance by the Tribe. If any data recovery is performed, once complete, a final report shall be submitted to the Tribe and the NAHC.

The Tribe does NOT authorize any scientific study or the utilization of any invasive and/or destructive diagnostics on human remains.

NPDES

85. Prior to the issuance of any building permits, the Applicant shall submit to the City for review and approval a Final Water Quality Management Plan (WQMP) that:
• Addresses Site Design BMPs (Best Management Practices) such as minimizing impervious areas, maximizing permeability, minimizing directly connected impervious areas, creating reduced or “zero discharge” areas, and conserving natural areas. • Incorporates the applicable Routine Source Control BMPs as defined in the DAMP. • Incorporates Treatment Control BMPs as defined in the DAMP. • Generally describes the long-term operation and maintenance requirements for the Treatment Control BMPs.
• Identifies the entity that will be responsible for long-term operation and maintenance of the Treatment Control BMPs.
• Describes the mechanism for funding the long-term operation and maintenance of the Treatment Control BMPs.

86. Prior to issuance of any Grading or Building Permit and as part of the future development’s compliance with the NPDES requirements the Applicant shall enroll electronically through the SMARTS program to comply with the State of California General Construction Permit. Proof of enrollment must be submitted to the City of Los Alamitos before issuance of grading or building permits. Also, a Stormwater Pollution Prevention Plan (SWPPP) shall be reviewed and approved by the Director of Public Works and the City Engineer for water quality construction activities on-site. A copy of the SWPPP shall be available and implemented at the construction site at all times. The SWPPP shall outline the source control and/or treatment control BMPs to avoid or mitigate runoff pollutants at the construction site to the “maximum extent practicable”.

87. Prior to obtaining grading permits, the Applicant shall submit a Stormwater Pollution Prevention Plan (SWPPP) for review and approval by the Building and Safety Division.

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88. Prior to issuance of any Grading Permit, the Director of Public Works and the Building Official shall confirm the Grading Plan specifications stipulate, in compliance with SCAQMD Rule 403, excessive fugitive dust emissions shall be controlled by regular watering or other dust prevention measures as specified in the SCAQMD’s Rules and Regulations. In addition, SCAQMD Rule 402, requires implementation of dust suppression techniques to prevent fugitive dust from creating a nuisance off-site. Implementation of the following measures would reduce short-term fugitive dust impacts on nearby sensitive receptors:
• All active portions of the construction site shall be watered twice daily to prevent excessive amounts of dust;
• On-site vehicle speed shall be limited to 15 miles per hour; • All on-site roads shall be paved as soon as feasible, watered twice daily, or chemically stabilized;
• Visible dust beyond the property line which emanates from the project shall be prevented to the maximum extent feasible;
• All material transported off-site shall be either sufficiently watered or securely covered to prevent excessive amounts of dust prior to departing the job site; Track-out devices shall be used at all construction site access points; and
• All delivery truck tires shall be watered down and/or scraped down prior to departing the job site.

89. All trucks that are to haul excavated or graded material onsite shall comply with State Vehicle Code Section 23114 (Spilling Loads on Highways), with special attention to Sections 23114(b)(F) and (e)(4) as amended, regarding the prevention of such material spilling onto public streets and roads. Prior to the issuance of grading permits, the Applicant shall demonstrate to the City of Los Alamitos how the project operations subject to that specification during hauling activities shall comply with the provisions set forth in Sections 23114(b)(F) and (e)(4).

ORANGE COUNTY FIRE AUTHORITY (OCFA)

90. PR105 - Conditional Use Permit (Conditions of Approval) The Applicant or responsible party shall submit the plan(s) listed below to the Orange County Fire Authority for review. Approval shall be obtained on each plan before the event specified.

1. As previously requested, provide a completed Water Availability Form, signed by a representative of the local water purveyor, showing the results of a recent fire hydrant flow test (within 6 months).

2. The site plan shall meet minimum requirements per OCFA Guideline B-01.

3. As previously requested, stated per OCFA Guideline B-01 Fire department access shall be available during the entire trajectory of the project. A phasing plan may be proposed under an AM&M. The plans were reviewed based on a single owner of the property. Per our discussion, the lot will be split and divided among more than one owner. Easement Agreements shall be approved and recorded before Fire Master Approval.

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4. Prior to OCFA clearance of a final map or issuance of a precise grading permit or a building permit, if a grading permit is not required:
* fire master plan (service code PR145)

5. Prior to issuance of a building permit:
* Architectural (service codes PR200-PR285)
* underground piping (service code PR470-PR475)
* fire sprinkler system (service codes PR400-PR465)

6. Prior to concealing interior construction:
* fire alarm system (service code PR500-PR530)
Temporary/Final Occupancy Inspections:

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

91. PR110 - Tentative Tract Map “B” and Fire Master Plan As previously indicated, the proposed site plans do not meet minimum fire department access.

Please see the redlined tentative track map for reference. These design issues will need to be resolved prior to submittal/approval of the B Map and/or f the Fire Master Plan. a. As previously requested, fire department lanes shall be deciphered on the Track Map by shading the minimum 20’ width. See redline item #1.
b. All entry signs shall be per OCFA Guideline B-0, Figure 6-Fire Lane Entrance Signs. See redline item #2.

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All portions of the buildings are within 150 feet of the public road as measured along the path of firefighter travel. All starting points for the hose pull shall be at the fire department access road. See redline item #3.

The plans have not been reviewed for Vehicular Gates. Obstructions to Emergency Vehicle Access shall meet minimum requirements per OCFA Guideline B-01Section B1. Reference redline item #4.

Required Fire Department Fire Access Road less than 36 ft. shall require signage on one or both sides of the road. See detail #6.

92. The Applicant shall enter into a Secured Fire Protection Agreement (SFPA) to provide for fairshare funding of capital improvements necessary to establish adequate fire protection facilities and equipment, and/or personnel. The SFPA would ensure that responses times and service ratios are met due to the implementation of the Project and no new fire station facilities would be required.

ENGINEERING / PUBLIC WORKS

93. A City public works encroachment permit shall be obtained for all work in public right-of-way before starting work. All work shall be done in accordance with APWA Standards and to the satisfaction of the City Engineer and must be completed before issuance of Certificate of Occupancy.

94. A bond or surety device shall be posted with the City in an amount and type sufficient to cover the amount of off-site and on-site work to be done, as approved by the City Engineer.

95. Pad certification by the Design Civil Engineer and Soil Engineer is required prior to the commencement of structural construction.

96. The final compaction report prepared by a qualified Soil Engineer shall be submitted to the City Engineer for review and approval before the commencement of structural construction.

97. The Applicant shall submit a Geotechnical Report for review and approval and shall prepared by a licensed Soils Engineer.

98. Prior to the issuance of any building permits, the Applicant shall provide to the City a Final Water Quality Management Plan (WQMP) that:
• Addresses Site Design BMPs (Best Management Practices) such as minimizing impervious areas, maximizing permeability, minimizing directly connected impervious areas, creating reduced or “zero discharge” areas, and conserving natural areas.
• Incorporates the applicable Routine Source Control BMPs as defined in the DAMP. • Incorporates Treatment Control BMPs as defined in the DAMP.

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• Generally describes the long-term operation and maintenance requirements for the Treatment Control BMPs.
• Identifies the entity responsible for long-term operation and maintenance of the Treatment Control BMPs.
• Describes the mechanism for funding the long-term operation and maintenance of the Treatment Control BMPs.

99. The Applicant shall submit Improvement Plans to a Registered Civil Engineer prepared for public works (off-site) and on-site improvements. Plan check fees shall be paid in advance. 100.An on-site grading and drainage plan shall be prepared and submitted to the City Engineer for approval. The plan shall be 24" x 36", with elevations to the nearest 0.01-foot, minimum scale 1" = 20'. Registered Civil Engineers shall prepare a plan. Public works improvements may be shown in this plan. Grading plan check fees must be paid in advance. 101.The Applicant shall submit a Drainage Report that shall contain Hydrologic and hydraulic calculations demonstrating adequate habitable onsite protection for the 100- year storm and street drainage assessing a 10-year return frequency storm (25-year frequency in sump areas) prepared by a Registered Civil Engineer shall be submitted with the Grading Plan.

Drainage Report shall be per the Orange County Hydrology Manual and the Orange County Local Drainage Manual as applicable.
102.Proposed Condition Drainage patterns are not to exceed the Existing Condition flow rates and must match the existing outlet locations. No net increase of flows will be allowed to enter Lampson Avenue or any other drainage conveyance without approval from the owner of the drainage facility.
103.The driveway and parking lot slope shall be a minimum slope of one 1.0% for asphalt and

0.5% for concrete.
104.Pursuant to and in accordance with Government Code Section 66020(d)(1), the Project Applicant is hereby notified as follows: The fees, dedications, reservations, and other exactions (“impositions”) imposed on this development, and which are subject to notification pursuant to Government Code Section 66020(d)(1) are:

Traffic Impact Fees: Yes, if you are increasing the total daily trips by 200 trips. 105.Provide a Traffic Impact Analysis for review and approval. Based on the review and approval of this analysis, additional conditions and/or fees may be required. Applicant is required to provide evidence to the Director of Development Services that the Applicant has conferred with the City of Seal Beach regarding the final Traffic Impact Analysis prior to issuance of grading permit.
106.All driveways, sidewalks and ADA Ramps shall meet current ADA requirements, and all offsite improvements are to be done per City Standards.

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107.A new 5-foot-wide concrete sidewalk shall be installed to be contained within the entire Los Alamitos right of way.
108.A Sewer Will-Serve letter is required prior to approval of building permits. Applicant must coordinate with the City of Seal Beach and/or the Rossmoor Los Alamitos Sewer District (RLAASD) to secure a connection to the sanitary sewer system provided by either the City of Seal Beach or the Rossmoor/Los Alamitos Sewer District
109.In relation to sewer connections, preliminary plans with the proposed lateral connections must be submitted, at no expense to the City of Los Alamitos, to the City of Seal Beach and/or the Rossmoor Los Alamitos Sewer District (RLAASD) to assess if plan check, inspection, and/or a sewer study is required. Approval of a sewer capacity study is required from the applicable sewer agency prior to issuance of a grading permit.
110.All Project improvements (within the public right of way) shall comply with Los Alamitos and all other applicable standards to ensure all intersection sight distance, pedestrian/bike crossing facilities, and street design requirements are complied with. 111.Prior to importation onsite, the Project Applicant shall submit evidence to the Development Services Director that all imported fill materials have been tested and meet the regulatory screening levels.

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Final Environmental Impact Report
SCH No. 2022090476

4665 Lampson Avenue
City of Los Alamitos, California

Lead Agency
City of Los Alamitos
3191 Katella Avenue
Los Alamitos, CA 90720

CEQA Consultant
T&B Planning, Inc.
3200 El Camino Real, Suite 100
Irvine, CA 92602
Project Applicant
Lampson Park Place, LLC
119 E. St Joseph Street
Arcadia, CA 91006
November 5, 2024

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4665 Lampson Avenue
Final Environmental Impact Report Table of Contents

Lead Agency: City of Los Alamitos SCH No. 2022090476
Page i

TABLE OF CONTENTS
Section Page

1.0 Introduction ............................................................................................................................1-1

1.1 Public Review Process.................................................................................................1-2

1.2 List of EIR Commenters..............................................................................................1-3

2.0 Master Responses to Comments Received During the Public Review Period.......................2-1

2.1 Master Response .........................................................................................................2-2

2.1.1 Transportation and Traffic Congestion.............................................................2-2

2.1.2 Roadway Safety on Lampson Avenue..............................................................2-4

2.1.3 Parking ...........................................................................................................2-8

2.1.4 Hydrology and Wastewater Infrastructure Analysis........................................ 2-10

2.1.5 Flooding ....................................................................................................... 2-15

2.1.6 Sewer ........................................................................................................... 2-16

2.1.7 Emergency Vehicle Access............................................................................ 2-17

2.1.8 Public Safety................................................................................................. 2-18

2.1.9 Proximity to the Los Alamitos Joint Forces Training Base (JFTB)................. 2-19

2.1.10 Loss of Existing Open Space and Provision of On-Site Amenities................. 2-21

3.0 Responses to Comments Received During the Public Review Period...................................3-1

4.0 Responses to Comments Received After the Public Review Period ......................................4-1

5.0 Clarification and Revisions ....................................................................................................5-1 Attachments (Provided on USB Drive)
A, Comment Letters 16 & 17 Attachments
B, VMT Analysis
C1, Updated Phase II Environmental Site Assessment Slip Sheet, EFI RTC C2, EFI Technical Memorandum
D, Nick Johnson Resume
E1, Updated Hydrology Study
E2, Updated PWQMP
F, Updated Noise Impact Analysis
G, Traffic Analysis
H, Safety Evaluation

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Final Environmental Impact Report Table of Contents

Lead Agency: City of Los Alamitos SCH No. 2022090476
Page ii
Attachments (cont.)
I, Shade and Shadow Study
J, Fire Master Plan & Fire Flow
K, Will-Serve Letters
L, Old Ranch Country Club Sewer Demand Calculations
M1, Updated Sewer Analysis
M2, Appendix A, Updated Table
N, Historic Research for Moon Trees
O, Mitigation Monitoring and Reporting Program

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Final Environmental Impact Report 1.0 Introduction
Lead Agency: City of Los Alamitos SCH No. 2022090476

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1.0 INTRODUCTION
In accordance with Section 15088 of the California Environmental Quality Act (CEQA) Guidelines, the City of Los Alamitos, as the Lead Agency, has evaluated the comments received on the Draft Environmental Impact Report (Draft EIR) for the 4665 Lampson Avenue Project (Project) (SCH No. 2022090476) and has prepared written responses to these comments. This document has been prepared in accordance with CEQA and represents the independent judgment of the lead agency.

Public Resources Code Section 21082.1(a) authorizes lead agencies, such as the City of Los Alamitos here, to prepare an EIR either directly by its own staff or under contract with a public or private entity.

More specifically, Section 15084(d) of the CEQA Guidelines provides that:

The lead agency may choose one of the following arrangements or a combination of them for preparing a draft EIR.
(1) Preparing the draft EIR directly with its own staff. (2) Contracting with another entity, public or private, to prepare the draft EIR. (3) Accepting a draft prepared by the applicant, a consultant retained by the applicant, or any other person.
(4) Executing a third party contract or memorandum of understanding with the applicant to govern the preparation of a draft EIR by an independent contractor. (5) Using a previously prepared EIR.

Pursuant to Public Resources Code Section 21082.1 and CEQA Guidelines 15084(e), to the extent a lead agency authorizes a consultant to prepare an EIR, the lead agency shall subject the draft to the agency’s own review and analysis. The EIR must reflect the independent judgment of the lead agency, and the lead agency remains responsible for the adequacy and objectivity of the EIR.

This document has been prepared in accordance with CEQA and represents the independent judgment of the lead agency.

According to State CEQA Guidelines Section 15132, the Final EIR shall consist of:
(a) The Draft EIR or a revision of the draft;
(b) Comments and recommendations received on the Draft EIR either verbatim or in summary;
(c) A list of persons, organizations, and public agencies commenting on the Draft EIR; (d) The responses of the Lead Agency to significant environmental points raised in the review and consultation process; and

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(e) Any other information added by the Lead Agency.

The City of Los Alamitos will consider certification of the EIR, adoption of a Mitigation Monitoring and Reporting Program, Findings and Facts, and a Statement of Overriding Considerations as part of the approval process for the Project.

This Final EIR document is organized as follows:

Section 1 provides a brief introduction to this document, a summary of the public review process, and a list of commenters.

Section 2 provides master responses for comments that were made by many commenters on the same issue.

Section 3 provides responses to the public comments received on the Draft EIR during the public review period. Responses are provided in the form of individual responses to comment letters received. Comment letters are followed immediately by the responses to each letter.

Section 4 provides responses to late comment letters received on the Draft EIR after the public review period. Responses are provided in the form of individual responses to comment letters received. Comment letters are followed immediately by the responses to each letter.

Section 5 contains revisions and clarifications to the Draft EIR as a result of the comments received from agencies and interested persons as well as errata to clarify, amplify, or make insignificant modifications to the EIR as authorized under CEQA. This information does not constitute significant new information pursuant to CEQA, and therefore recirculation of the EIR for further review pursuant to CEQA Guidelines Section 15088.5 is not required.

1.1 PUBLIC REVIEW PROCESS
In compliance with Section 15201 of the State CEQA Guidelines, the City of Los Alamitos (City) has taken steps to provide opportunities for public participation in the environmental review process. A Notice of Preparation (NOP) was distributed on October 3, 2022 to responsible agencies, local government agencies, and interested parties for a 30-day public review period (from October 3, 2022 to November 2, 2022) in order to solicit responses that would help the City identify the full scope and range of potential environmental concerns associated with the Project so that these issues could be fully examined in this EIR. The NOP was also distributed to the State of California Office of Planning and Research, State Clearinghouse (SCH) for distribution to State agencies. The Project was described; potential environmental effects associated with Project implementation were identified; and agencies and the public were invited to review and comment on the NOP. A copy of the NOP and comments received are included in Appendix A of the Draft EIR. The City received comment letters from eight (8) agencies and organizations and 201 individuals in response to the NOP. Substantive issues raised in response to the NOP and during the Scoping Meeting are summarized in Table 1-1, Summary of NOP Comments, and Table 1-2, Summary of Scoping Meeting Comments of the Draft EIR.

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Lead Agency: City of Los Alamitos SCH No. 2022090476

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CEQA requires that a Draft EIR have a review period lasting at least 45 days for projects that have been submitted to the SCH for review (State CEQA Guidelines, Section 15105[a]). The Draft EIR was distributed to various public agencies, organizations, and individuals on April 24, 2024; the EIR was available for public review and comment for a period of 45 days. The review period ended on June 10, 2024. The City used several methods to elicit comments on the Draft EIR. A Notice of Availability (NOA) and the Draft EIR was distributed to the SCH for distribution to State agencies and was posted on the City’s website. The NOA was also posted at the Orange County Clerk’s office on April 24, 2024. The NOA was mailed to responsible agencies, local government agencies, and interested parties that received the NOP, to individuals who had previously requested the NOA or EIR, and to individuals who provided NOP comments on April 24, 2024. The NOA was also published in the Event News Enterprise which started the week of April 22 through the week of May 6; the NOA and Draft EIR were made available for review, on the City’s web site at: https://cityoflosalamitos.org/203/PlanningCommission-Projects.

The Planning Commission held public hearings on September 25, 2024 and October 23, 2024, and City Council, is scheduled to hold a public hearing November 18, 2024 to consider whether to approve the proposed Project and associated actions and whether to certify the Final EIR for the Project.

1.2 LIST OF EIR COMMENTERS
In accordance with Section 15132 of the State CEQA Guidelines, the following includes a list of the agencies, organizations, and individuals that submitted comments on the Draft EIR and indicates the environmental topics raised by each commenter regarding the Draft EIR. The City received a total of 6 comments from agencies and organizations and 74 comments from individuals and interested parties on the Draft EIR during the public review period.

Section 2.0 provides Master Responses in response to environmental topical areas that were raised by several of the commenters. The use of master responses by lead agencies is a well-accepted means of responding to issues frequently raised in comments on a draft EIR. (S. Kostka & M. Zischke, Practice Under the California Environmental Quality Act (rev. 2023) Section 16.9.) Responses to each comment are in Section 3.0. The agency and organization comment letters have been assigned a letter (i.e., A, B, C) and the individual comment letters have been assigned a number (i.e., 1, 2, 3). Each comment within the transmittal is divided into sequential numbered comments (i.e., A-1, A-2, A-3; or 1-1, 1-2, 1-3).

Comment Letter
Number Agency, Organization, or Name Date
Comments Received During the Public Review Period
Agencies and Organizations
A Airport Land Use Commission (ALUC) for Orange County June 10, 2024 B California Department of Transportation (Caltrans) June 10, 2024 C City of Garden Grove May 29, 2024
D City of Seal Beach June 10, 2024
E Department of Toxic Substances Control (DTSC) June 5, 2024

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Final Environmental Impact Report 1.0 Introduction
Lead Agency: City of Los Alamitos SCH No. 2022090476

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Comment Letter
Number Agency, Organization, or Name Date
F Orange County Transportation Authority (OCTA) June 5, 2024 Individuals
1 A., Alexandria May 24, 2024
2 Balderama, Lelisa May 19, 2024
3 Balderama, Lelisa April 29, 2024
4 Barembaum, Susan May 13, 2024
5 Beaini, Maria April 29, 2024
6 Biery, James June 10, 2024
7 Boland, John June 6, 2024
8 Boyer, Barbara May 20, 2024
9 Brandt, Daniel June 10, 2024
10 Burstein, Valerie May 20, 2024
11 Campbell, Patty June 10, 2024
12 Chesser, Steven May 18, 2024
13 Chinn, Donna June 10, 2024
14 Chirco, Vita May 12, 2024
15 Chow, Mark and Julia April 28, 2024
16 Churchhill, Carol June 9, 2024
17 Churchhill, Carol May 20, 2024
18 De Boer, Kristal June 9, 2024
19 Deaton, Ellery June 7, 2024
20 DuRose, Kellie June 10, 2024
21 Eble, Chris May 5, 4024
22 Farjami, Fred and Susanne June 9, 2024
23 Frenkiel, Rosemary May 2, 2024
24 Fulton, L.C May 4, 2024
25 Garthwaite, Kim May 19, 2024
26 Gulec, Gizem May 19, 2024
27 Gulec, C.K. June 10, 2024
28 Gunvalsen Saks, Ann April 25, 2024
29 Horning, Donald June 10, 2024
30 Huffington, Leah, Lidia, and Hector June 7, 2024
31 Kalish, David No date
32 Lasser, Tom June 9, 2024
33 Lindow, Valerie June 6, 2024
34 Liu, Robert June 9, 2024
35 Lloyd, Renee June 8, 2024
36 Lundblad, Herbert May 22, 2024
37 Madison, Tamara April 29, 2024
38 Manzo, N June 10, 2024
39 Maulhardt, Thomas April 29, 2024
40 Maulhardt, Luciann May 23, 2024
41 Maurer, Robbi April 30, 2024
42 McGuire, Donna and Dean June 10, 2024
43 Miller, Gary June 10, 2024

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Final Environmental Impact Report 1.0 Introduction
Lead Agency: City of Los Alamitos SCH No. 2022090476

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Comment Letter
Number Agency, Organization, or Name Date
44 Mokhtari, Suzy May 1, 2024
45 Morgan, Ed and Sylvia May 20, 2024
46 Naime, Bayan May 5, 2024
47 Noud-Ikuta, Mary May 15, 2024
48 Orland, Jean June 4, 2024
49 Osburn, Justin June 10, 2024
50 Penney, Jennifer June 10, 2024
51 Polye, Jessica April 24, 2024
52 Riness, Janet May 7, 2024
53 Saad, Abram and Mirna April 25, 2024
54 Salling (Sakkubf), Brittany May 5, 2024
55 Senecal, Patty June 10, 2024
56 Serlin, Marc May 5, 2024
57 Shores, Julia and James May 7, 2024
58 Showalter, Catherine June 4, 2024
59 Smith, Paulette May 4, 2024
60 Smith, David May 4, 2024
61 Smitson, Eric April 29, 2024
62 Sprong, Marty June 10, 2024
63 Stathopoulos, Dora May 14, 2024
64 Still, Timothy May 16, 2024
65 Stohler, Michelle June 6, 2024
66 Sugihara, Tom May 17, 2024
67 Sustarsic, Schelly June 10, 2024
68 Thomas, Thom and Elizabeth June 3, 2024
69 Tilson, Jeffrey May 13, 2024
70 Werner, Teresa May 6, 2024
71 Wheeler, Curt and Cindy May 22, 2024
72 Wiest, Nancy May 17, 2024
73 Williams, Ksatria June 2, 2024
74 Williams, John June 6, 2024
Comments Received after the Public Review Period
I Rutan & Tucker, LLP on behalf of Los Alamitos Luxury
Apartments
September 19, 2024
II Santa Ana Regional Water Quality Control Board September 24, 2024 III City of Seal Beach Environmental Quality Control Board October 21, 2024

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Final Environmental Impact Report 2.0 Master Responses
Lead Agency: City of Los Alamitos SCH No. 2022090476

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2.0 MASTER RESPONSES TO COMMENTS RECEIVED DURING THE

PUBLIC REVIEW PERIOD
All of the comment letters received by the City have been included and responded to in this Final Environmental Impact Report (Final EIR). Comments that raise significant environmental concerns have been thoroughly addressed. Comments that do not require a response are indicated below and include those that (1) do not address the adequacy or completeness of the Draft EIR (i.e., are outside the scope of CEQA); (2) do not raise significant environmental issues; (3) do not address the Project; or (4) request the incorporation of additional information not relevant to environmental issues.

CEQA Guidelines Section 15204(a) outlines the parameters for public agencies and interested parties to submit comments and the Lead Agency’s responsibility for responding to specific comments. Per CEQA Guidelines Section 15204(a), comments should be related to:
[T]he sufficiency of the document in identifying and analyzing possible impacts on the environment and ways in which the significant effects of the project might be avoided or mitigated. Comments are most helpful when they suggest additional specific alternatives or mitigation measures that would provide better ways to avoid or mitigate the significant environmental effects. At the same time, reviewers should be aware that the adequacy of an EIR is determined in terms of what is reasonably feasible…CEQA does not require a lead agency to conduct every test or perform all research, study, and experimentation recommended or suggested by commenters. When responding to comments, lead agencies need only respond to significant environmental issues and do not need to provide all information requested by reviewers, as long as a good faith effort at full disclosure is made in the EIR.

CEQA Guidelines Section 15204(c) further advises that, “[r]eviewers should explain the basis for their comments, and should submit data or references offering facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of the comments. Pursuant to CEQA Guidelines Section 15064, an effect shall not be considered significant in the absence of substantial evidence.” Additionally, CEQA Guidelines Section 15204(d) notes that, “[e]ach responsible agency and trustee agency shall focus its comments on environmental information germane to that agency’s statutory responsibility;” but, pursuant to CEQA Guidelines Section 15204(e), “[t]his section shall not be used to restrict the ability of reviewers to comment on the general adequacy of a document or of the lead agency to reject comments not focused as recommended by this section [CEQA Guidelines Section 15204].”
Section 15088 of the California Environmental Quality Act (CEQA) Guidelines, Evaluation of and Response to Comments, states:
a) The lead agency shall evaluate comments on environmental issues received from persons who reviewed the draft EIR and shall prepare a written response. The lead agency shall

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respond to comments raising significant environmental issues received during the noticed comment period and any extensions and may respond to late comments. b) The lead agency shall provide a written proposed response, either in a printed copy or in an electronic format, to a public agency on comments made by that public agency at least 10 days prior to certifying an environmental impact report. c) The written response shall describe the disposition of significant environmental issues raised (e.g., revisions to the proposed project to mitigate anticipated impacts or objections). In particular, the major environmental issues raised when the Lead Agency’s position is at variance with recommendations and objections raised in the comments must be addressed in detail giving reasons why specific comments and suggestions were not accepted. There must be good faith, reasoned analysis in response. Conclusory statements unsupported by factual information will not suffice. The level of detail contained in the response, however, may correspond to the level of detail provided in the comment (i.e., responses to general comments may be general). A general response may be appropriate when a comment does not contain or specifically refer to readily available information, or does not explain the relevance of evidence submitted with the comment. d) The response to comments may take the form of a revision to the draft EIR or may be a separate section in the final EIR. Where the response to comments makes important changes in the information contained in the text of the draft EIR, the lead agency should either:

1. Revise the text in the body of the EIR; or

2. Include marginal notes showing that the information is revised in the response to comments.

As further discussed in Section 5.0 of this document, the Draft EIR revisions and information presented in the responses to comments do not result in any of the conditions set forth in CEQA Guidelines Section 15088.5; therefore, the EIR does not need to be recirculated prior to its certification.

This section presents detailed responses to comments that were made by many commenters on the same environmental issue. The master responses provide a means of giving a broader context to the response than may be possible in individual responses and eliminates unnecessary duplication in the responses In some cases, one or more master responses may be responsive to an individual comment.

2.1 MASTER RESPONSE

2.1.1 TRANSPORTATION AND TRAFFIC CONGESTION
Several commenters raised concerns regarding the Project’s traffic increases in areas that are currently congested during peak hours. As discussed in Section 4.15, Transportation, of the Draft EIR, pursuant to Senate Bill (SB) 743, changes to the CEQA Guidelines were adopted in December 2018, which

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require all lead agencies to adopt Vehicle Miles Travelled (VMT) as the measure for identifying transportation impacts for land use projects under CEQA. This Statewide mandate went into effect July 1, 2020. The issue of congestion is no longer a CEQA issue and for this reason is not addressed in the Draft EIR (refer to Page 4.15-1 of the Draft EIR). With the California Natural Resources Agency’s certification and adoption of the changes to the CEQA Guidelines, automobile delay, as measured by “level of service” and other similar metrics, no longer constitute a significant environmental effect under CEQA. (Pub. Resources Code, § 21099, subd. (b)(3)). Transportation analysis under CEQA is now based on VMT rather than impacts to automobile delay-based level of service (LOS) (traffic congestion).

Nonetheless, a Traffic Analysis (TA; Technical Appendix N1 of the Draft EIR [Updated TA is also included as Attachment G to the Final EIR]) was prepared for the Project to evaluate the Project’s traffic impacts with respect to congestion, the potential circulation system deficiencies that may result from the development of the proposed Project, and where necessary to recommend improvements to achieve acceptable operations consistent with General Plan level of service goals and policies. This TA was primarily prepared for non-CEQA purposes, although it does provide information (e.g. trip generation) to support the analyses in other technical reports (e.g., air quality, etc.).

A. Non-CEQA Topic for Informational Purposes
Although the Project is located in the City of Los Alamitos, access to the site via Lampson Avenue lies within the City of Seal Beach’s jurisdiction. The Project’s traffic study has been prepared in accordance with the City of Los Alamitos’ requirements and the City of Seal Beach’s Transportation Analysis Guidelines (June 2020, referred to as City Guidelines) as the study area intersections lie within the City of Seal Beach. The Project traffic study scoping agreement, provided in Appendix 1.1 of the TA, was provided for review and approval by the cities of Los Alamitos, Seal Beach, and Garden Grove.

Based on consultation with the City of Los Alamitos and the City of Seal Beach, ten study area sections were selected for analysis in the TA, shown in Table 1-1 in the TA. Additionally, a total of nine study area roadway segments were selected for evaluation based on City of Seal Beach’s Guidelines which require analysis of any roadway segment where a project contributes 1% or more of the total traffic on the segment. Pursuant to comments received on the Draft EIR and TA from the City of Seal Beach (see Comment Letter D in Section 3.0 of this Final EIR) and the City of Garden Grove (see Comment Letter C in Section 3.0 of this Final EIR), an updated TA was prepared and included as Attachment G to this Final EIR.

In the TA, Seal Beach Boulevard & Lampson Avenue was identified as a deficient intersection under Opening Year Cumulative (2026) and under General Plan Buildout traffic conditions. Restriping the number two westbound left turn lane as a shared left-right turn lane would improve the intersection operations to an acceptable LOS D. The Project Applicant’s responsibility for the Project’s contributions towards the deficient intersection would be addressed by payment of fair share fees to the jurisdiction that would construct the recommended improvement.

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Moreover, as discussed in Section 3.0, Project Description, of the Draft EIR, according to the City of Seal Beach General Plan, Lampson Avenue is a divided roadway with a raised median and designed to accommodate a maximum of 37,500 daily vehicle trips. The City of Seal Beach’s General Plan identifies two roadway segments that generally comprise the portion of Lampson Avenue fronting the Project site: Rose Street to Tulip (east of the Project) and Rose Street to Heather Street (adjacent and West of the Project). The Project is anticipated to generate 1,658 daily trips. At General Plan Buildout with the Project, these two segments of Lampson Avenue would carry between 15,350 and 15,750 daily trips (see Technical Appendix N1 of the EIR), below the maximum of 37,500 daily trips.

Therefore, the Project’s anticipated trip generation is well within the capacity of Lampson Avenue even at General Plan Buildout (refer to Page 3-17 of the Draft EIR).

Many commenters also expressed concerns regarding U-turns on Lampson Avenue at Heather Street.

As discussed in the Project’s Traffic Analysis, there are existing westbound U-turns occurring at the intersection of Heather Street and Lampson Avenue, however, the intersection operates at an acceptable LOS with the inclusion of these existing peak hour U-turns. Additionally, Project traffic is not anticipated to utilize Heather Street for U-turns along Lampson Avenue as all components of the Project would have access to the full access driveway at the primary neighborhood entry on Lampson Avenue for making southbound left turns.

Many commenters also expressed concerns on cut-through traffic into existing neighborhoods. Project traffic would utilize Lampson to access either Seal Beach Boulevard or Valley View to access the regional freeway system. There would be no reason for Project traffic to use roads within the existing neighborhoods to the south since they do not provide direct access or a shorter route to Seal Beach Boulevard or Valley View. The existing surrounding residential neighborhoods do not provide any direct connection to these facilities. Therefore, internal residential streets, including College Park East, are not a desirable alternative route to the regional roadway network. Minimal travel may occur within the adjacent neighborhood to access public parks, since there is an existing park directly adjacent to the Project site.

B. CEQA-Related Topic
As discussed in Section 4.15, Transportation, of the Draft EIR, the Project would result in significant VMT impacts with the implementation of Mitigation Measure MM 4.15-1. Even where the TDM measures are implemented to their maximum effectiveness, the Project would still not be able to reduce its VMT impact to a level of less than significant which requires a 31.8% reduction for baseline (2022) conditions and 27.7% for buildout (2045) conditions. Therefore, the Draft EIR identified a significant and unavoidable VMT impact for the Project on a direct and cumulatively considerable basis (refer to

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2.1.2 ROADWAY SAFETY ON LAMPSON AVENUE
Many commenters expressed concerns regarding vehicle and pedestrian safety on Lampson Avenue due to the potential for decreased visibility and an increase in traffic. A Safety Evaluation was prepared for the Project (see Attachment H of this Final EIR) which analyzed collision data, pedestrian and

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bicycle safety, and site access management (e.g. driveway sight distance, driveway spacing, project access and queuing, multimodal conflict points, and pedestrian/bicycle connections). A summary of the main findings are presented below.

Additionally, several comments were made regarding the proposed traffic signal at the primary neighborhood entry on Lampson Avenue. The Project’s Traffic Analysis (see Attachment G of this Final EIR) evaluated this issue and determined that the primary neighborhood entry is not anticipated to meet peak hour or planning level (daily volume) based traffic signal warrants and no traffic signal at this location is needed or required. However, due to public comments received during the Notice of Preparation and scoping period, the Project initially proposed to install a traffic signal at the primary neighborhood to alleviate neighborhood concerns related to safety. Subsequent public comments received on the Draft EIR during the 45-day public review period expressed concern with installing a traffic signal and after further traffic signal warrant and safety analyses, it was determined that the proposed traffic signal is not warranted (see Attachment G of this Final EIR). Therefore, the Project no longer proposes a traffic signal at this entryway. However, to address the public comments expressing concerns related to safety in this area, a Safety Evaluation was prepared for the Project (see Attachment H of this Final EIR). Based on the Safety Evaluation and for the reasons summarized below, the Project would not result in a safety impact or substantially increase hazards due to a geometric design feature.

A. Collision
As discussed in the Safety Evaluation (see Attachment H of this Final EIR), collision data was gathered by California Highway Patrol (CHP) Statewide Integrated Traffic Records System (SWITRS). The collision data includes 5 years of collision data gathered by CHP staff and members of its allied agencies throughout California (including the City of Los Alamitos). Table 1 of the Safety Evaluation provides a summary of the types of collisions by intersection for eight intersections. Table 2 of the Safety Evaluation provides a summary of the crash rate compared to the statewide average. The results indicated the following:
• Basswood Street & Lampson Avenue had a total of 1 reported collision in a 5-year period. The common collision included a sideswipe collision. Sideswipe collisions are commonly caused by failure to yield or impaired/distracted driving. The intersection of Basswood St. & Lampson Av. has a lower crash rate than the state average for similar facilities.
• Candleberry Avenue & Lampson Avenue had a total of 1 reported collision in a 5-year period. The common collisions included a broadside collision. Broadside collisions are commonly caused by failure to yield, failure to stop, or impaired/distracted driving. The intersection of Candleberry Av. & Lampson Av. has a lower crash rate than the state average for similar facilities.
• Rose Street & Lampson Avenue had a total of 2 reported collisions in a 5-year period.

The common collisions included broadside and overturn collisions. Overturned vehicles are commonly caused by unsafe speeds, improper maneuvers, or loss of vehicle control.

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The intersection of Rose St. & Lampson Av. has a lower crash rate than the state average for similar facilities.
• Tulip Street & Lampson Avenue had a total of 1 reported collision in a 5-year period.

The common collision included a broadside collision. The intersection of Tulip St. & Lampson Av. has a lower crash rate than the state average for similar facilities. • Valley View St. & Lampson Avenue had a total of 14 reported collisions in a 5-year period. The common collisions included rear-end and broadside collisions. Rear-end collisions are commonly caused by failure to yield, failure to stop, or impaired/distracted driving. The intersection of Valley View St. & Lampson Av. has a lower crash rate than the state average for similar facilities.

The existing crash rates for the study area intersections are lower than the statewide average crash rates. A Project would have the potential to create an increase in collision rate if it introduced a geometric design feature that did not meet safety standards or incompatible uses (e.g. farm equipment).

As demonstrated in the analysis below in Master Response 2.1.2C through 2.1.2E, implementation of Project improvements (within the public right-of-way) per Los Alamitos and Seal Beach standards ensures all that sight distance requirements, pedestrian crossing requirements, and street design requirements are met. Additionally, the Project vehicle mix is consistent with the adjacent land uses, including the residential neighborhood to the south. Therefore, it is not anticipated that the Project will result in a significant change in collision rates or result in an accident rate higher than the statewide average.

B. Bicycle and Pedestrian Facilities
As discussed in Section 4.7, Transportation, of the Draft EIR, existing sidewalks are present on both the westbound and eastbound side of Lampson Avenue, adjacent to the Project site. Crosswalks are present at the intersections of Lampson Avenue/Heather Street and Lampson Avenue/Rose Street (refer to Page 4.15-3 of the Draft EIR). Frontage improvements for the Project would include median improvements, sidewalks, driveway modifications needed to accommodate site access, and landscaping improvements as required by City standards (refer to Page 3-4 of the Draft EIR).

As discussed in the Safety Evaluation (Attachment H of this Final EIR), there are existing Class II (onstreet, striped) bike lanes on the north and south sides of Lampson Avenue from Basswood Street to the east. In addition, there is a Class I bike/pedestrian path on Seal Beach Boulevard north of Lampson Avenue and a Class II bike lane south of Lampson Avenue. The Project would not remove any existing bike/pedestrian paths and would maintain the existing Class II bike lane on Lampson Avenue along its frontage to maintain bicycle safety. The existing sidewalks adjacent to the Project met design standards and the Americans with Disabilities Act (ADA) standards at the time they were constructed.

As stated, the sidewalks along the Project frontage will be improved as part of the Project. Frontage improvements include sidewalks, driveway modifications to accommodate site access, median modifications, and landscaping improvements as required by City standards. The proposed sidewalk

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along the Project’s frontage on the north side of Lampson Avenue will provide connectivity with proposed sidewalks and paths internal to the Project.

The intersections at Lampson Avenue at Heather Avenue and Lampson Avenue at Rose Avenue are currently signalized and both have pedestrian crosswalks for Lampson Avenue. The wheelchair ramp on the north side of Lampson Avenue at Heather Avenue does not meet current ADA standards.

However, the wheelchair ramp on the north side of Lampson Avenue at Rose Avenue does meet ADA standard requirements.

All Project driveways will be designed to meet current City standards and accommodate pedestrian crossing per current ADA standards. These improvements will ensure the Project meets all compliance requirements.

C. Intersection Sight Distance
Intersection sight distance at the primary neighborhood entry was evaluated by identifying limited use areas pursuant to Orange County Standard Plan 1117 – Intersection Sight Distance. The limited use areas determine the necessary sight distance to allow 7 ½ seconds for the driver on the crossroad (or left turn pocket) to safely cross the main roadway or turn left while the approach vehicle travels at the assumed design speed of the main roadway. All Project driveways are required to meet these sight distance requirements. Exhibit 3 of the Safety Evaluation shows that the primary neighborhood entry will meet the sight distance requirements, and that the Project would not create any new sight distance issues or contribute to decreased visibility along Lampson Avenue.

D. Stopping Sight Distance
According to the Highway Design Manual (HDM), stopping sight distance is the minimum sight distance for a given design speed to be provided on multilane highways and on 2-lane roads when passing sight distance is not economically obtainable. Stopping sight distance also is to be provided for all users, including motorists and bicyclists, at all elements of interchanges and intersections at grade, including private road connections. Lampson Avenue has a posted speed limit of 45 miles per hour (mph). As stated in HDM Table 201, a stopping sight distance of 360 feet is the standard for a design speed of 45 mph. Therefore, the Project does not introduce any new stopping sight distance issues to Lampson Avenue.

E. On-Site Vehicle Circulation
The Project does not involve freight operations because the Project is a residential project. Since the proposed use is residential, a limited number of trucks would travel to the Project site (e.g. trash trucks, emergency vehicles, delivery vans). Therefore, congestion from freight trucks to and from the Project site would be negligible and there will be no conflicts between freight trucks and passenger vehicles.

Attachment D of the Safety Evaluation identifies the on-site circulation for the site. The exhibits identify various vehicle paths (front-loading garbage trucks, fire trucks, delivery trucks, etc.) for various internal drive aisles, which allow for two-way traffic. Access to and from the site will be

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accommodated via driveways on Lampson Avenue. As shown in Attachment D of the Safety Evaluation, the vehicle turning templates show acceptable turning movements for the various vehicles and trucks anticipated to access the site. Therefore, there will be no conflicts between garbage trucks, fire trucks, and delivery trucks and passenger vehicles.

F. Conclusion
A review of available collision data indicates that the study area intersections have lower crash rates than the statewide average of intersections with similar configuration and settings. The addition of Project traffic is not anticipated to increase the crash rates by a significant margin. As discussed throughout this evaluation, the implementation of Project improvements (within the public right of way) per Los Alamitos, Seal Beach, Orange County Public Works, Highway Design Manual (HDM), and American with Disabilities Act (ADA) standards ensures all sight distance requirements, pedestrian crossing requirements, and street design requirements are met. Additionally, the Project TA, Attachment G of the Final EIR, indicates the highest peak hour volume along Lampson Avenue at Driveway 2 is 561 vehicles (Refer to Exhibit 3-8 of the TA). The highest Project peak hour volume of 50 vehicles occurs at Driveway 2 in the evening (Refer to Exhibit 4-2 of the TA). The Project contributes 9% of the additional vehicles to the evening peak hour ([50/561]*100=9%). Therefore, the addition of Project-related traffic is not anticipated to cause any new or exacerbate any existing safety deficiencies along Lampson Avenue or in the vicinity of the Project’s interface with Lampson Avenue.

The City will impose upon the Project a condition of approval that will ensure that the intersection sight distance, pedestrian/bike facilities, and street facilities satisfy CA MUTCD, ADA, City of Los Alamitos, and City of Seal Beach standards.

2.1.3 PARKING
As of 2010, the CEQA Guidelines Appendix G, no longer requires an evaluation of parking for a project. This elimination of the requirement to analyze parking was in response to case law holding that the inconvenience resulting from a parking shortage is a social impact; pursuant to these cases, a parking shortage is not an environmental impact necessary for analysis under CEQA unless secondary indirect environmental impacts may result from any such parking shortage as indirect environmental impacts. Moreover, a condition of approval has been included which requires the parking garages onsite be used for primarily parking purposes. Nevertheless, due to previous comments received during the NOP period related to concerns about parking, two technical studies were prepared for the Project and incorporated into the Draft EIR to analyze the Project’s onsite parking supply (Technical Appendix P of the Draft EIR) and potential parking impacts to nearby parks (Technical Appendix Q of the Draft EIR). A summary of the findings from these technical studies is further discussed below.

A. Arbor Park/Arbor Dog Park Parking
Many commenters expressed concerns regarding parking for Arbor Park and Arbor Dog Park. As discussed in Section 4.15, Transportation, of the Draft EIR, Walker Consultants prepared an analysis to evaluate the parking need at Arbor Park and Arbor Dog Park, including American Youth Soccer Organization (AYSO) Region 159 uses at Arbor Park for soccer practices on weeknights and soccer

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games on weekends (see Technical Appendix Q of the Draft EIR). AYSO parking demand is highest during Saturday soccer games with a parking demand that fluctuates between 97 to 339 spaces between the hours of 8:00 AM and 2:00PM and a peak parking demand of 339 spaces at noon. AYSO currently uses parking spaces on the Project site on an informal basis (i.e., the owner of the Project site does not have a formal arrangement with AYSO) for soccer games, many of which would not be available upon Project implementation.

Walker was engaged to evaluate options to assist AYSO in resolving its parking needs following Project buildout. Two options were considered: 1) a voluntary commitment by the Project to provide a 10-foot strip of land along the north boundary of the Project site, or 2) a voluntary commitment by the Project to provide a 10-foot strip of land in addition to improvements 2’-10” to 4’- 3” in width on the north side of the Arbor Park parking lot (see Figures 1 and 4 of Technical Appendix Q of the Draft EIR for the proposed parking layouts). The Project’s voluntary commitment to either of these options would allow for up to 154 or 200 parking spaces for users of Arbor Park, respectively.

Following implementation of these options, if an inadequate amount of parking still remained to accommodate an AYSO soccer game event, vehicles would have the option of dropping off players/visitors at the park and/or seeking available parking off-site and walking to the park.

Ultimately, Walker concludes that to resolve any parking shortages related to these soccer events, the AYSO could re-program its event schedule to ensure that these events are distributed throughout the day in such a way as to accommodate simultaneous arrivals of attendees for these events. Additionally, any change in vehicle trip distance over time would be negligible, as it would only occur on Saturdays during soccer season,1 which typically lasts from 8AM to 2PM. Moreover, attendees in vehicles would arrive at certain appointed times to watch or participate in these events, and therefore these vehicles are not expected to circle or idle in the parking lot to wait until a parking space became available.

The potential for parking in adjacent neighborhoods would not cause any indirect environmental impacts. Attendees for these events who are unable to find parking even with these additional parking spaces voluntarily provided by the Project could search for parking elsewhere, such as the nearby College Park East or West Garden Grove neighborhoods. The final destination for these attendees and the number of attendees seeking parking elsewhere is unknown given the potential for existing or future parking regulatory controls (e.g. neighborhood permitted parking) in these neighborhoods, the possibility that AYSO may ultimately re-program its event schedule, and the inherent variations in the number of attendees and participants from season to season.

Nonetheless, the need for attendees to seek parking in nearby neighborhoods would not constitute additional new vehicle trips or vehicle miles traveled attributable to the Project because soccer events 1 Parking demand is low on weeknights for AYSO practices. As documented in Technical Appendix Q of the Draft EIR:
“On the weekday, parking demand related to the AYSO leagues was low and could have been entirely accommodated within the existing gravel parking area, if needed. Over the course of the observations, a small number of soccerrelated parking occurred in the 4665 Lampson parking lot.

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at Arbor Park are not an element of the Project. Additionally, any change in vehicle trip distance over time would be negligible, as it would only occur on Saturdays during soccer season, which typically lasts from 8AM to 2PM. Moreover, attendees in vehicles would arrive at certain appointed times to watch or participate in these events, and therefore these vehicles are not expected to circle or idle in the parking lot to wait until a parking space became available. As such, vehicles unable to find adequate parking would not result in any significant transportation impacts related to congestion at the site (which is a level of service concept no longer considered a significant impact under CEQA in any event) or air quality impacts related to emissions (refer to Pages 4.15-15 through 4.15-16 of the Draft EIR).

B. On-site Parking
Many commenters expressed concerns regarding the lack of proposed onsite parking and the potential for overflow parking from the Project to nearby streets and Arbor Park. As discussed in Section 3.0, Project Description, of the Draft EIR, the Project would provide 577 parking spaces (475 spaces for the single family detached and townhomes and 102 for the apartments). These 577 spaces exceed the 4410 parking spaces that would be required pursuant to the State’s Density Bonus Law (refer to Page 3-4 of the Draft EIR).

As part of the Project, Walker Consultants prepared a parking analysis (Technical Appendix P of the Draft EIR) to determine the appropriate amount of parking needed for the Project. Based on the City’s off-street parking requirements in the Municipal Code, the Project would be required to provide 679 parking spaces. The Project qualifies for a density bonus and parking concessions under the State Density Bonus Law (Government Code Section 65915) which would reduce the Project’s minimum off-street parking requirement to 441 parking spaces. The Project is proposing to provide 577 parking spaces, approximately 15% fewer than City code requirements, but 30.8% above what is required under Government Code Section 65915(p).

Therefore, the Project would provide more than adequate parking based on nationally recognized Urban Land Institute/National Parking Association Standards for market-rate residential development and would meet the minimum parking requirements of the City of Seal Beach, the adjacent jurisdiction.

Based on the analysis conducted in the parking analysis, the Project’s proposed parking supply is appropriate to serve the potential parking needs of the Project. As a result, Project residents would have adequate parking on-site and would not park on streets in the adjacent neighborhood or Arbor Park.

Moreover, a condition of approval would be included which requires the parking garages onsite be used for primarily parking purposes.

2.1.4 HYDROLOGY AND WASTEWATER INFRASTRUCTURE ANALYSIS
A number of residents expressed concern that the Project would exacerbate flooding conditions in College Park East and stated that the Project would add additional flows down Lampson to Ironwood and Hazelnut Avenues. A Hydrology Study (Technical Appendix I3 of the Draft EIR) was prepared for

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the Project, which demonstrated that the Project’s peak hour flows would not exceed the existing condition flows.

Based on comments received from the City of Seal Beach (Comment Letter D, herein), the Hydrology Study was updated and included as Attachment E of this Final EIR. The updated analysis expanded the hydrologic analysis and street capacity analysis for the Lampson Avenue downstream tributary area to the existing sump catch basin within Lampson Avenue. The peak flow rates were reduced based on the detention routing analysis and incorporation of the storm water sump pump system onsite which controls the outflow, mitigating the peak flow discharge rate. The updated analysis resulted in the following changes to the Draft EIR.

1. Pages 3-9, 3-10 of the Draft EIR are revised as follows:

D. Stormwater Drainage Infrastructure

1. Preferred Stormwater Drainage
The proposed Project site’s stormwater runoff would be conveyed by roof downspouts or street surface flow to the proposed gutters and collected by thru-curb inlet bio-filtration devices or catch basin inlets for water quality treatment. The bio-filtration devices include internal overflow bypass that direct flows via on-site underground storm drain system to an underground detention system located under parking areas at the southwest portion of the Project site. From the detention system, a stormwater sump pump located in the southwest corner of the Project site would outlet flow into the existing 18” outlet storm drain pipe at the southwest corner of the site, which conveys stormwater runoff to match the historical flow pattern across the Los Alamitos Joint Forces Training Base (JFTB) property directly west of the site. The detention system and pump will be sized so that the outlet flows from the developed site will be equal to, or less than, existing conditions for all storm events. In the event the stormwater pump fails or the outlet pipe becomes clogged, the emergency overflow for the site will be conveyed through a parkway drain discharging flow onto Lampson Avenue, matching historical overflow drainage patterns.

2. Alternate Stormwater Drainage
An alternate plan for stormwater conveyance is proposed in the event the preferred route (historical flow) across the JFTB, as described above, is not available. The alternate would include stormwater outflow onto Lampson Avenue, which would subsequently flow west to an existing stormwater catch basin approximately 2,200 feet west of the Project site. Due to existing flooding concerns on Lampson Avenue, the onsite pump system would allow for low flows to enter Lampson Avenue up until the time that the flows begin to exceed the allowed 25-year storm event in Lampson Avenue. At that point, peak flows would be detained onsite.

Once the flows are no longer above the allowed 25-year storm event in Lampson Avenue, onsite flows to Lampson Avenue would resume. Under the Alternate Off-Site Storm Drain plan, stormwater will be detained and mitigated onsite such that Lampson Avenue meets OC

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Hydrology flooding standards. Approximately 33,106 32,300 cf of water would need to be detained onsite to ensure that offsite 25-year flows are not exceeded. Detained volumes would be discharged from the site via a pump system at flow rates that do not exceed the existing condition flow rates.

2. Pages 4.9-17 and 4.9-19 are hereby modified as follows to reflect the changes made in the updated Hydrology Study.

1. Storm Drain Facilities – Preferred Route
The preferred treatment of stormwater runoff for the Project would be conveyance by roof downspouts or street surface flow to proposed gutters and collected by thru-curb inlet biofiltration devices or catch basin inlets for water quality treatment. The bio-filtration devices include internal overflow bypass that direct flows via onsite underground storm drain system to an underground detention system located under parking areas at the southwest portion of the site. From the detention system, a stormwater sump pump located in the southwest corner of the site will outlet flows into the existing 18” storm drain pipe at the southwest corner of the site to outlet to the JFTB. The detention system and pump will be sized so that the outlet flows from the developed site will be equal to, or less than, existing flows. In the event the stormwater pump fails or the outlet pipe becomes clogged, the emergency overflow for the site will flow onto Lampson Avenue matching historical overflow drainage patterns.

The combined, total 100-year peak flow rate for the Project site is 31.5140.28 cfs under existing conditions. The combined, total 100-year peak flow rate for the Project Site is approximately

42.1544.31 cfs under the proposed conditions without improvements. Figure 4.9-4, Proposed Conditions Hydrology Map illustrates the post development drainage conditions of the Project site. The proposed drainage design would follow the existing drainage pattern with surface flows to on-site drainage facilities that would ultimately outlet into the existing storm drain pipe at the southwest corner of the Project site. The results from the hydrology study demonstrate that the proposed conditions of the Project site of 42.1544.31 cfs would generate a higher peak runoff flowrate than the existing condition of the site of 31.5140.28 cfs.

Due to increased peak runoff flows created from the proposed change in land use and increased impervious coverage by 48%, stormwater would need to be detained and minimized mitigated on-site to match existing conditions. By matching the maximum flows conveyed by the outlet pipe and providing a 20 percent factor for safety for preliminary sizing, approximately 10,000 cubic feet (cf) would be required to be detained on-site based on a conservative 100-year storm event. To prevent overflow into Lampson Ave, the detention system will be sized to match the maximum flows conveyed by the outlet pipe, approximately 33,106 cubic feet. In addition, a proposed stormwater pump system with upstream detention storage has been incorporated into the onsite drainage design to provide onsite peak flow and volume detention for the development for all storm events. The pump system will control the outflow discharge rate matching the existing 2-year peak flow at approximately 8.9 cfs. As such, the proposed on-site

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detention facilities will be designed to detain a minimum volume of 10,000 cf and detained volumes that would be discharged from the site via a pump system at flow rates that do not exceed the existing condition flow rates. As such, downstream facilities would not be hydrologically impacted by the proposed Project. Impacts would be less than significant and no mitigation is required.

2. Alternate Drain Facilities
In the event the preferred route (historical flow across the JFTB) is not available, an alternate treatment of stormwater runoff for the Project would be conveyance to offsite storm drain facilities. Figure 4.9-5, Proposed Alternate Conditions Hydrology Map illustrates the postdevelopment drainage conditions for this drainage and detention alternate. The proposed site’s stormwater runoff would be conveyed by roof downspouts or street surface flow to proposed gutters and collected by thru-curb inlet bio-filtration devices or catch basin inlets for water quality treatment. The bio-filtration devices include internal overflow bypass that direct flows via on-site underground storm drain system to an underground detention system located under parking areas at the southwest portion of the site. From the detention system, a stormwater sump pump located in the southwest corner of the site will outlet flows onto Lampson Avenue via a parkway culvert. Due to existing flooding concerns on Lampson Avenue, the onsite pump system would allow for low flows to enter Lampson Avenue up until the time that the flows begin to exceed the pre-development allowed 25-year storm event in Lampson Avenue. At that point, peak flows would be detained onsite. Once the flows are no longer above the predevelopment allowed 25-year storm event in Lampson Avenue, onsite flows would continue pumping to Lampson Avenue normally.

Under the Alternate Storm Drain plan, stormwater will need to be detained and minimized mitigated onsite such that Lampson Avenue meets OC Hydrology flooding standards. Onsite and offsite small unit hydrographs were analyzed using AES Rational Method Analysis to identify the time that the flows exceed the allowed offsite 25-year storm event flows to prevent flooding of one travel lane of the half-street per the OC Local Drainage Manual. Approximately 33,106 32,300 cf of water would need to be detained onsite to ensure that offsite 25-year flows are not exceeded. By matching the maximum flows and providing an additional 20 percent factor of safety for preliminary sizing, approximately 38,800 cf of water would be detained onsite. Detained volumes would be discharged from the site via a pump system at flow rates that do not exceed the existing condition flow rates. Downstream facilities would not be hydrologically impacted by the proposed improvements. Additionally, the proposed finished floor elevations for the onsite buildings would be set 1-foot minimum above the 100-year storm event water surface elevation in accordance with Orange County Flood Protection Requirements.

3. Page 4.9-21 of the Draft EIR is hereby modified as follows to reflect the changes made in the updated Hydrology Study.

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3. Outlet Runoff to Arbor Park to North: Arbor Park is within the JFTB and drains south to the same earthen channel outlet as the project site. If the proposed flows from the Project are not allowed to outlet to the JFTB at the southwest corner of the site, proposed flows from the Project would not be allowed to outlet to the JFTB to the north of the site either since they are essentially the same outlet location. In addition, the existing site does not flow in the northerly Arbor Park/ JFTB area as the site drains in the southwesterly direction, therefore directing stormwater runoff to the north would change the historic drainage pattern which can potentially cause downstream flooding.

4. Outlet Runoff to Golf Course to East: The golf course to the east is within the JFTB and drains east, ultimately outletting to the Bolsa Chica Channel. OutlettingDischarging to the east does not match the historical drainage pattern and the Bolsa Chica Channel was not designed to accommodate flows from the Project site; therefore, runoff to the golf course to the east would potentially cause downstream flooding. In addition, the golf course and Bolsa Chica Channel are upstream from the site, therefore, this option would not be feasible due to elevation differences.

5. Construct storm drain pipe under Lampson Avenue to east: OutlettingDischarging to the east does not match the historical drainage pattern and the Bolsa Chica Channel was not designed to accommodate flows from the site. Additionally, installation of underground storm drain pipe within Lampson Avenue is infeasible due to conflicts with existing utilities, maintenance concerns, and head losses as described above (see #1). Similarly to item #4, changing the historical drainage pattern may potentially cause unforeseen drainage impacts.

4. Page 4.9-23 of the Draft EIR is hereby modified as follows to reflect the changes made in the updated Hydrology Study.

1. On-Site Drain Facilities
The results from the hydrology report demonstrate that the proposed drainage conditions would generate a higher peak runoff flowrate than the existing conditions on the Project site due to an increase in impervious area and change in land use. The preferred detention facilities would be designed to detain the increased peak flow between the existing outlet pipe flows and proposed conditions. Detained volumes would be discharged from the site via a pump system at flow rates that do not exceed the existing condition flow rates. Downstream facilities would not be hydrologically impacted by the proposed Project site improvements (C&V, 2024a).

2. Alternative Storm Drain Facilities
A second hydrology report was prepared for the alternate stormwater conveyance plan. The results from the report demonstrated that the proposed condition of the alternate would generate a 10 percent (44.31 cfs proposed/40.28 cfs existing) higher 100-year storm event peak runoff flowrate than the existing condition of the site due to an increase in impervious area and change

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in land use. The proposed underground detention facilities would be designed to detain the increased flows under the proposed conditions, which would be discharged from the site via a pump station at flow rates that would not exceed the existing condition flow rates. Downstream facilities would not be hydrologically impacted by the proposed Project site improvements. (C&V, 2023) (C&V, 2024a).

2.1.5 FLOODING
Many commenters expressed flooding and storm drainage concerns on Lampson Avenue and impacts to College Park East. As shown in Figure 4.9-3, Existing Flood Hazard Zone, according to the Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM) No. 06059C0116J (effective 12/03/2009), the Project site is located within FEMA Flood Zone D. Flood Zone D is correlated with a possible risk of flooding, but the probability has not been determined. It may be noted that the area south of the Project site, including adjacent Lampson Avenue, is located within FEMA Flood Zone X (areas determined to be outside the 0.2% annual chance floodplain) according to the FEMA FIRM No. 06059C0118J (effective 12/03/2009). According to the Hydrology Report for the proposed storm drain facilities, during a peak 100-year storm event, stormwater flows would be detained within the on-site underground detention basin. Detained volumes will be discharged from the site via a pump system at flow rates that do not exceed the existing condition flow rates.

Additionally, the Project’s proposed finished floor elevations would be set at least 1 foot above the peak 100-year storm event water surface elevation in accordance with Orange County Flood Protection requirements.

Similarly, according to the Hydrology Report for the alternate stormwater conveyance plan, during a peak 100- year storm event, stormwater flows would be detained with the proposed detention facilities.

Detained volumes would be discharged from the site via a pump system at flow rates that do not exceed the existing condition flow rates. Downstream facilities would not be hydrologically impacted by the proposed improvements. Additionally, proposed floor elevations for the onsite buildings would be set at least 1 foot above the peak 100-year storm event water surface elevation in accordance with Orange County Flood Protection requirements (refer to Page 4.9-24 of the Draft EIR).

As discussed in Section 4.9, Hydrology and Water Quality, of the Draft EIR, the Project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff. The Project’s preferred storm drain system and alternate storm drain system would be sized and designed in accordance with the City’s drainage requirements and Orange County Hydrology Manual to ensure that off-site flows are conveyed through the Project site and flows originating off-site are discharged from the site at a volume and rate that can be accommodated by existing and planned downstream storm drain facilities.

Additionally, the Project’s storm drainage infrastructure would adequately detain 100-year flows, discharge detained flows at rate that do not exceed existing flows, and the Project’s finish floor elevations would be at least 1 foot above the water surface elevation. Accordingly, the Project is not

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anticipated to risk the release of pollutants due to project inundation. Impacts would be less than significant and no mitigation is required (refer to Pages 4.9-23 through 4.9-25 of the Draft EIR).

Cumulative development such as Old Ranch Country Club Specific Plan development would be required to comply with federal, State, and local regulations and applicable regional and local master drainage plans in order to mitigate flood hazards both on- and off-site. Compliance with federal, State, and local regulations and applicable drainage plans would require development sites to be protected from flooding during peak storm events (i.e., 100-year storm) and also would not allow development projects to expose downstream properties to increased flooding risks during peak storm events. In addition, future development proposals within the San Gabriel-Coyote Creek Watershed would be required to prepare hydrologic and hydraulic calculations, subject to review and approval by the responsible City Engineer, to demonstrate that substantial on- and/or off-site flood hazards would not occur. Accordingly, the construction and operation of the Project would not contribute to cumulatively considerable flooding impacts (refer to Pages 4.9-27 of the Draft EIR).

2.1.6 SEWER
Many commenters expressed concerns with the increase in wastewater to the existing system and the old age of the infrastructure.

As discussed in Section 4.17, Utilities and Service Systems, of the Draft EIR, the existing sewer mains of three manholes (Basswood and Aster Street [Manhole A-16]; Candleberry Avenue and Aster Street [Manhole A-21]; and Elder Avenue [Manhole A-25]) were analyzed. Flow monitoring was conducted under the existing conditions of the three manholes. The existing Project site peak flow was subtracted from the projected Project site flow. The delta flow was then added to the existing monitored peak flows to obtain the proposed development conditions. The results from the Sanitary Sewer Analysis (refer to Technical Appendix O of the Draft EIR) demonstrate that the proposed flows, in addition to the observed flows, create a proposed depth of flow that would not impact the existing surrounding sanitary sewer systems. Based on sewer monitoring data collected in preparation of the Sanitary Sewer Analysis, the sewer systems in all three locations indicated good flow, along with hydraulics and relatively low depths. Wastewater volumes produced by the proposed development would not exceed the existing sewer capacity in the public system, and the existing sewer system has adequate capacity for the proposed development. Accordingly, impacts would be less than significant, and no mitigation is required (refer to Pages 4.17-17 to 4.17-19).

Many commenters also expressed concerns regarding the increase in cost for utility infrastructure improvements that may be needed due to the increase in capacity to existing systems and aging infrastructure. The Project is subject to connection and service fees to offset increased demand and assist in facility expansion and service (at the time of need). Additionally, the Project Applicant would be required to pay development impact fees which will be used for any future needed improvements on the infrastructure systems.

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2.1.7 EMERGENCY VEHICLE ACCESS
Several commenters raised concerns regarding potential impacts to emergency access and evacuations.

In the event of an evacuation in the nearby area, Lampson Avenue has adequate capacity to handle vehicle evacuations. As described above, Lampson Avenue is a divided roadway with a raised median and designed to accommodate a maximum of 37,500 daily vehicle trips. The City of Seal Beach’s General Plan identifies two roadway segments that generally comprise the portion of Lampson Avenue fronting the Project site: Rose Street to Tulip (east of the Project) and Rose Street to Heather Street (adjacent and West of the Project). At General Plan Buildout with the Project, these two segments of Lampson Avenue would carry between 15,350 and 15,750 daily trips (see Technical Appendix N1 of the EIR), below the maximum of 37,500 daily trips. Therefore, the Project’s anticipated trip generation is well within the capacity of Lampson Avenue even at General Plan Buildout (refer to Page 3-17 of the Draft EIR). Additionally, in the event of an evacuation, traffic would be controlled by local law enforcement and vehicles would be directed away from the area.

As discussed in Section 4.15, Transportation, of the Draft EIR, the Project would provide adequate emergency access for emergency vehicles via Lampson Avenue. A restricted emergency vehicle access point with Lampson Avenue would be provided at the eastern end of the site. The Project also includes a fire master plan (see Attachment J of this Final EIR) to ensure proper installation and maintenance of fire access roadways, proper siting of hydrants, adequate water supply, and access to the structures.

The Project would be required to comply with all applicable fire codes and ordinances for construction, access, water mains, fire flows, and fire hydrants.

The effectiveness of emergency response and firefighting operations is directly related to the proper installation and maintenance of fire access roadways, the proper sitting of hydrants, adequate water supply, and access to structures. In accordance with OCFA Guideline B-09, Fire Master Plans for Commercial & Residential Development, Firesafe Planning Solutions prepared a Fire Master Plan for the Project (see Figure 4.8-3, Fire Master Plan, of the Draft EIR). The Fire Master Plan demonstrates the Project’s compliance with the California Fire and Building Codes and other regulations regarding emergency access to the Project site, including but not limited to required fire access and roadway design, fire lane identification, and access to structures. Compliance with OCFA Guidelines ensures that the Project is designed and constructed to provide adequate emergency access for emergency vehicles.

Furthermore, the Project would be required to comply with all applicable fire code and ordinances for construction, access, water mains, fire flows, and fire hydrants. For example, site plans would be submitted to OCFA to ensure compliance with OCFA standard conditions, including fire flow requirements based upon the tenant type, building size, and building type. Access to and around structures would meet OCFA and CFC requirements. Additionally, pursuant to LAMC Section 12.08, the Project would be required to provide adequate emergency access along abutting roadways during temporary construction activities within the public right-of-way. Specifically, the Project’s compliance with LAMC 12.08.200 would ensure adequate access for all vehicles during temporary lane closures (refer to Pages 4.15-17 through 4.15-18 of the Draft EIR).

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2.1.8 PUBLIC SAFETY
Many commenters raised concerns regarding public safety due to the Project’s increase in population.

As discussed in Section 4.13, Public Services, the Los Alamitos Police Department was contacted to document the existing and planned police protection facilities and to determine whether the Project would require the construction or expansion of new facilities. Buildout of the Project would increase demands for police protection services in the City, including the potential need for parking enforcement. During the construction and operation of the Project, the need for police services is expected to grow due to the increase in population. Crime and safety issues during Project construction may include theft of building materials and construction equipment, malicious mischief, graffiti, and vandalism. After construction, the Project is anticipated to generate a typical range of police service calls as similar developments. Additionally, it should be noted that an increase in crime is not an environmental impact on the physical environment unless it leads to an increase in services or decrease in response times resulting in the need for construction of additional facilities.

However, per correspondence with Los Alamitos Police Department, the anticipated increase in demands on police services resulting from the implementation of the Project would not adversely impact Los Alamitos Police Department’s existing resources. There are currently no staffing or equipment deficiencies in the service area. The increase in potential services needed would not require the construction of a new police station or improvements to the existing station that serves the Project site. The existing resources would be adequate to meet the additional demands generated by the Project.

The Los Alamitos Police Department has not indicated the need for a new police station or expansion of existing facilities due to the Project. Responses times and service ratios would be met and would not require the construction of new facilities.

The Seal Beach Police Department indicated that the Project site is within the City of Los Alamitos and serviced by Los Alamitos Police Department. The Seal Beach Police Department provides service to Lampson Avenue and requested that the Draft EIR address traffic flow and safety, which were addressed in the Draft EIR and Master Responses 2.1.1, Transportation and Traffic Congestion, and

2.1.2 Roadway Safety on Lampson Avenue, above.

Moreover, Project development would result in increased property tax and, indirectly, sales tax revenue proportionally increasing the City’s General Fund revenue, providing funding for police protection services, equipment, and/or personnel. Because the Project does not include construction of new police facilities and does not generate a need for additional facilities, increases in demands for police protection resulting from implementation of the Project impacts would be less than significant. No mitigation is required (refer to Pages 4.13-8 through 4.13-10 of the Draft EIR).

As discussed in Section 4.13, Public Services of the Draft EIR, considering the existing firefighting resources available in the City, implementation of the Project is not expected to result in the need for new or physically altered governmental facilities, the construction of which could cause significant environmental impact. Per correspondence with the OCFA, there are currently no deficiencies in fire protection service provided to the Project site. In order to maintain acceptable service ratios, OCFA uses a fair share approach to mitigate fire service response impacts and facility/equipment needs.

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Project development would occur in an area of the City already served by OCFA; therefore, the Project would not result in an expansion of OCFA’s service area. In the event of an emergency within the Project site that requires more resources than the primary fire stations that serve the area could provide, OCFA would direct resources to the site from other OCFA stations nearby (refer to Page 4.13-8 through

4.13-10 of the Draft EIR). As a result, response times would not decrease to necessitate the construction of a new fire station.

2.1.9 PROXIMITY TO THE LOS ALAMITOS JOINT FORCES TRAINING BASE (JFTB) A. Safety
Many commenters expressed concerns related to safety hazards based on the Project's proximity to the Los Alamitos JFTB and stated that two State Agencies, Cal Trans Division of Aeronautics and the California Airport Land Use Commission, had issued warnings that projects within close proximity to the JFTB have safety and health issues. As discussed in Section 2.4.3, Airport Environs Land Use Plan for The Joint Forces Training Base Los Alamitos, the Airport Land Use Commission’s (ALUC) previous finding that the City’s Housing Element, including the Project site, was inconsistent with the Airport Environs Land Use Plan for the Joint Forces Training Base Los Alamitos, was overruled by the Los Alamitos City Council on December 11, 2023, pursuant to Public Utilities Code Sections 21670 and 21676.

As discussed in Section 4.8, Hazards and Hazardous Materials, of this EIR, the Project site is not located within the CZs or APZ (refer to Figure 4.8-1, JFTB Impact Zones) for the JFTB. Therefore, the Project does not concentrate people in areas susceptible to aircraft accidents. Moreover, the FAA issued Determinations of No Hazard to Air Navigation (Technical Appendix J2 of the Draft EIR) after its aeronautical study of the Project determined that the structures would not exceed obstruction standards and would not be a hazard to air navigation on January 26, 2022. Military safety areas are intended to protect people on the ground from airplanes and the FAA airspace determinations are intended to protect airplanes from structures and interference on the ground. As such, the Project would not result in a safety hazard for people residing at the Project site (refer to Page 4.8-18 of the Draft EIR).

Additionally, as shown in Figure 4.8-2, Los Alamitos JFTB Flight Patterns, the Project site is not located within any of the flight patterns in the JFTB. As discussed in Section 4.10, Land Use and Planning, of the Draft EIR, the ALUC mandates the provision of the State’s real estate disclosure regarding buyer and renter notification for new residential land uses within an airport influence area even if these state laws were to be revised or rescinded. The ALUC also requires that signs providing these disclosures and notices be “prominently posted” in real estate sales offices and within the new development depicting overflight areas and helicopter traffic patterns. Buyer awareness is required as part of the City’s approval process for the Project. The buyer awareness notification process is built into the real estate disclosure laws of the State to ensure that potential buyers are fully informed before buying a home near an airport if they are sensitive to the types of annoyances or disruptions that may come with the location (refer to Page 4.10-18 of the Draft EIR).

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Many comments also provided suggested mitigation measures to be included in the Draft EIR.

However, based on the preceding information, the Project would not result in significant impacts related to any safety hazards associated with the JFTB. Therefore, additional mitigation measures related to safety hazards are not warranted.

B. Noise Impacts and Noise Insulation
Many commenters expressed concerns regarding noise impacts for Project residents due to the proximity of the Los Alamitos JFTB. Additionally, commenters expressed concerns regarding the need for noise insultation in walls, windows, and ceilings for the Project’s structures. As discussed in Section

4.11, Noise, of the Draft EIR, an on-site exterior aircraft noise impact analysis has been completed to determine the noise exposure levels that would result from adjacent JFTB Los Alamitos aircraft noise sources in the Project study area, and to identify environmental impacts from the proposed Project and potential noise abatement measures for the proposed Project that would achieve acceptable Project noise levels, if required.

The JFTB Los Alamitos is located adjacent to, and northwest of the Project. Figure 4.11-4, APHC 2020 Airport Noise Level Contour Boundaries, of the Draft EIR shows the Project site in relation to the airport’s projected noise level contour boundaries, as provided by the 2020 Noise Assessment for Los Alamitos Airfield, Joint Forces Training Base Los Alamitos. As shown on Figure 4.11-5, On-Site Aircraft Noise Level Contours, of the Draft EIR, the northwestern portion of the Project site would locate residential uses between the 60 and 65 dBA CNEL noise level contours. Residential land uses exposed to noise levels less than 60 dBA CNEL are “normally consistent.” Residential uses exposed to noise levels between 60 and 65 dBA CNEL are considered “conditionally consistent” with AELUP Noise limitations, requiring that sound attenuation as identified by the California Noise Insulation Standards, Title 25, California Code of Regulations is implemented to ensure that the interior CNEL does not exceed 45 dBA.

The interior noise level is the difference between the predicted exterior noise level at the building facade and the noise reduction of the structure. Typical building construction would provide a Noise Reduction (NR) of approximately 12 dBA with “windows open” and a minimum 25 dBA noise reduction with “windows closed.” However, sound leaks, cracks and openings within the window assembly can greatly diminish its effectiveness in reducing noise. Several methods are used to improve interior noise reduction, including: (1) weather-stripped solid core exterior doors; (2) upgraded dual glazed windows; (3) mechanical ventilation/air conditioning; and (4) exterior wall/roof assembles free of cut outs or openings.

The Project will implement sound attenuation methods to ensure the interior CNEL does not exceed 45 dB. For example, the Project will provide mechanical ventilation (e.g. air conditioning) in all units.

In addition, with implementation of PDF-N-2, which includes the use of windows with a STC rating of 29 on all second floor facades adjacent to Lampson Avenue and JFTB Los Alamitos, the Project would be designed to achieve a 25 dBA reduction and meet the 45 dBA CNEL interior noise standard.

Accordingly, the Project would not expose people residing or working in the Project area to excessive

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noise levels from airport or aircraft operations, and impacts would be less than significant. No mitigation is required (refer to Page 4.11-31 of the Draft EIR).

2.1.10 LOSS OF EXISTING OPEN SPACE AND PROVISION OF ON-SITE AMENITIES Many commenters expressed concerns regarding loss of existing open space and failure to provide onsite amenities for Project residents. As discussed in Section 2.0, Environmental Setting, under existing conditions, the Project site is currently developed with a vacant two-story, 88,000 sf commercial office building (most recently occupied by WestEd, California Department of Fish and Wildlife, National Comfort Institute, Inc., and James J. Mentas Attorney at Law) located centrally within the Project site and surface parking lot located within the western portion of the Project site. The remainder of the Project site consists of undeveloped/vacant land, which includes approximately 5.97 acres of developed/ornamental land and approximately 6.40 acres of disturbed/ornamental land (refer to Pages 2-6 through 2-7 of the Draft EIR) which provides very little value as open space or for recreation as the site was used for commercial uses and existing trees appear to be in declining health from possibly a variety of reasons including but not limited to an unknown disease and stress from drought.

The Project would provide a variety of common open space amenities, as well as a variety of privately maintained open space and decks. The Project would provide a total of 58,027 square feet (sf) or 1.33 acres of open space on the Project site, including 16,508 sf of usable common open space and 41,519 sf of private open space (homeowner maintained). The Project would result in an increase in residents; however, as explained in the following paragraph, the Project is not anticipated to increase the use of the existing parks such that substantial additional use or physical deterioration of the existing parks would occur or be accelerated.

Based on the Project’s Parks Impact Analysis (Technical Appendix M of the Draft EIR), it is anticipated that a negligible amount of Project residents will regularly visit parks in close proximity to the Project site specifically, Arbor Park, Arbor Dog Park, and Heather Park. Specifically, it is anticipated that a total of 178 Project residents would visit the designed neighborhood open spaces within the Project site and 131 Project residents would visit Arbor Park, Arbor Dog Park, and Heather Park as the parks they visit most often. Project residents are anticipated to visit (frequent) Arbor Park and Heather Park as follows: approximately 22 users 2 times per week, 18 users once per week, 27 users once or twice per month, 32 users several times per year, and 20 users once or twice per year (see Table 2, Technical Appendix M of this Draft EIR). Project residents’ dogs are anticipated to visit (frequent) Arbor Dog Park 147 times once per week. (sees Tables 3 and 4, Technical Appendix M of this Draft EIR).

The carrying capacity of Arbor Park and Heather Park is 270 and 67 visitors, respectively, and there is no calculation for carrying capacity for Arbor Dog Park due to the nature of a dog park. Carrying capacity (referring to the number of visitors that can be accommodated in a park without unacceptable impacts to the quality of the visitor experience) can be calculated for a park utilizing the amenities, such as playgrounds, baseball fields, and open lawn areas present in the park. Because the projected number of Project visitors to these parks are well within the carrying capacity stated above, there is sufficient capacity at existing nearby neighborhood parks to accommodate the Project residents. With full occupancy of the Project, the designed neighborhood open spaces within the Project site, the

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capacity and existing maintenance and usage of existing parks, and the anticipated visitation of the Project residents to the existing parks; the Project is not anticipated to increase the use of the existing parks such that substantial additional use or physical deterioration of the existing parks would occur or be accelerated.

Based on the Project’s Parks Impact Analysis (Technical Appendix M of this EIR), there is sufficient capacity at existing neighborhood parks to accommodate the Project residents and impacts would be less than significant. Refer to Section 4.14, Recreation, of the Draft EIR for further discussion (refer to Pages 4.14-8 to 4.14-9 of the Draft EIR).

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3.0 RESPONSES TO COMMENTS RECEIVED DURING THE PUBLIC REVIEW PERIOD This section includes responses to substantive Draft EIR comments received by the City. With respect to comment letters received, aside from certain courtesy statements, introductions, and closings, individual comments within the body of each letter have been identified and numbered. A copy of each comment letter and the City’s responses to each applicable comment are included in this section.

Brackets delineating the individual comments and a numeric identifier have been added to the right margin of the letter. Responses to each comment identified are included on the page(s) following each comment letter. Responses to comments are being sent to the agencies and organizations that provided comments at least 10 days prior to the City’s consideration of the Project and EIR.

Revisions to the Draft EIR have been prepared to make minor corrections and clarifications to the Draft EIR as a result of City review, and comments received during the public review period (refer to Section

5.0, Draft EIR Clarifications and Revisions, of this document). Therefore, this Response to Comments section, and the Draft EIR Clarifications and Revisions section, are included as part of this Final EIR along with the Draft EIR for consideration by the City prior to a vote to certify the EIR.

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Responses to Comment A
Airport Land Use Commission (ALUC) for Orange County, dated June 10, 2024.

A-1 The commenter provides introductory remarks and a summary of the Project. For clarification regarding the proposed open space, the Project would provide 58,027 sf of open space, including approximately 16,508 sf of usable common open space, approximately 41,519 sf of private open space, and approximately 78,038 sf of planting area (refer to Page 3-7 of the Draft EIR).

A-2 The commenter states the Project site was included in the City’s Housing Element Update and ALUC had previously found the updated Housing Element to be inconsistent with the Airport Environs Land Use Plan (AELUP) for JFTB for reasons listed in the comment. The Draft EIR acknowledges that ALUC previously found the Housing Element to be inconsistent with the AELUP. As provided in Section 2.0, Environmental Setting, of the Draft EIR, City’s Housing Element received certification from the State Housing and Community Development Department (HCD). However, the Housing Element received an inconsistent finding from ALUC on January 19, 2023. On February 21, 2023, the City Council adopted Resolution 2023- 04, providing notice of the City's intent to overrule ALUC's determination. The City Council conducted a Study Session and reviewed information related to ALUC's finding of inconsistency on July 17, 2023. A Public Hearing was held on August 21, 2023, where the City Council considered the adoption of a resolution overruling the ALUC's determination but failed to receive the required two-thirds affirmative vote (four affirmative votes were required). On September 21, 2023, the ALUC voted to require the City to submit all discretionary actions related to Housing Element Sites 6 (4655 Lampson Avenue), 7 (Laurel Park), and 10 (5030- 5084 Katella) to ALUC for review until such time as the General Plan is revised, or the City overrules ALUC’s determination. On December 11, 2023, the City received a four/fifths vote from the Los Alamitos City Council to overrule ALUC’s finding and adopt the City’s Housing Element pursuant to the State Aeronautics Act. Accordingly, approval from ALUC is not required for the Project because the Project site is listed as a Housing Opportunity Site in the City’s Housing Element, which was included in the City Council’s vote to overrule the ALUC (refer to Page 2-6 of the Draft EIR).

Refer to Response to Comment A-3 through A-5 related to the inconsistency reasoning.

A-3 The commenter states that the Housing Element inconsistency finding was based on AELUP Section 2.1.1 – “aircraft noise emanating from airports may be incompatible with the general welfare of inhabitants in the vicinity of an airport.” The commenter merely restates the text of this section and does not provide further information to evaluate the assertion that the Project is inconsistent or explain why the Project would be inconsistent with this finding. Refer to Response to Comment A-6 related to noise impacts from aircrafts.

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A-4 The commenter states that the Housing Element inconsistency finding was also based on Public Utilities Code (PUC) Section 21674, which states that the Commission is charged to assist local agencies in ensuring compatible land uses in the vicinity of existing airports. The commenter merely restates the text of this section and does not provide further information to evaluate the assertion that the Project is inconsistent or to assess why the commenter believes the Project would be inconsistent with this finding. The Draft EIR documented the proper procedural requirements with respect to ALUC input as described in Response to Comment A2.

A-5 The commenter states that the Housing Element inconsistency finding was based on AELUP General Land Use Policies in Section 3.2.1, which states that Land uses may be found to be inconsistent with the AELUP if it 1) places people so that they are affected adversely by aircraft noise and 2) concentrates people in areas susceptible to aircraft accidents. Refer to Response to Comment A-3 regarding aircraft noise impacts. As discussed in Section 4.10, Land Use and Planning, of the Draft EIR, the Project site is not located within the clear zones or accident potential zone (refer to Figure 4.8-1, JFTB Impact Zones) for the JFTB. Therefore, the Project does not concentrate people in areas susceptible to aircraft accidents and would not result in a safety hazard for people residing at the Project site (refer to Page 4.10-15 of the Draft EIR).

The commenter does not provide additional information related to aircraft accidents that would affect the finding documented in the Draft EIR.

A-6 The commenter states while the City overruled ALUC on December 11, 2023, the commenter has additional comments regarding the Project. The commenter summarizes threshold c in Section 4.11, Noise, of the Draft EIR, and states that projects within the 60 dB noise contour must use sound attenuation as required by the California Noise Insulation Standards, Title 25, California Code of Regulations. The Draft EIR acknowledges that the Project is near JFTB and evaluates noise emanating from the airport in Section 4.11, Noise, of the Draft EIR. An on-site exterior aircraft noise impact analysis has been completed to evaluate the potential noise exposure levels that would result from adjacent JFTB Los Alamitos aircraft noise sources in the Project study area, and to identify environmental impacts from the proposed Project and potential noise abatement measures for the proposed Project that would achieve acceptable Project noise levels, if required. As shown on Figure 4.11-5, On-Site Aircraft Noise Level Contours, the northwestern portion of the Project site would locate residential uses between the 60 and 65 dBA CNEL noise level contours. Residential land uses exposed to noise levels less than 60 dBA CNEL are “normally consistent.” Residential uses exposed to noise levels between 60 and 65 dBA CNEL are considered “conditionally consistent” with AELUP Noise limitations, requiring that sound attenuation as identified by the California Noise Insulation Standards, Title 25, California Code of Regulations is implemented to ensure that the interior CNEL does not exceed 45 dBA.

The Project will implement sound attenuation methods to ensure the interior CNEL does not exceed 45 dBA. For example, the Project will provide mechanical ventilation (e.g. air conditioning) in all units. In addition, with implementation of PDF-N-2, which includes the

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use of windows with a STC rating of 29 on all second floor facades adjacent to Lampson Avenue and JFTB Los Alamitos, the Project would be designed to achieve a 25 dBA reduction and meet the 45 dBA CNEL interior noise standard. Accordingly, the Project would not expose people residing or working in the Project area to excessive noise levels from airport or aircraft operations, and impacts would be less than significant. No mitigation is required (refer to Page

4.11-31 of the Draft EIR).

Refer also to Master Response 2.1.9, Proximity to the Los Alamitos Joint Forces Training Base (JFTB), related to noise impacts. A portion of the Project is within the 60 dBA noise contour, and as such, the Project will implement PDF-N-2, which includes the use of windows with a STC rating of 29 on all second floor facades adjacent to Lampson Avenue and JFTB Los Alamitos, ensuring the Project is designed to achieve a 25 dBA reduction and meet the 45 dBA CNEL interior noise standard. Thus, no further response is required.

A-7 The commenter also recommends a posting of “NOTICE OF AIRPORT IN VICINITY”. The commenter’s recommendation is already addressed in Section 4.10, Land Use and Planning, of the Draft EIR (refer to Page 4.10-18 of the Draft EIR). As discussed in Section 4.10, Land Use and Planning of the Draft EIR, the buyer awareness notification process is built into the real estate disclosure laws of the State to ensure that potential buyers are fully informed before buying a home near an airport if they are sensitive to the types of annoyances or disruptions that may come with the location. Buyer awareness is required as part of the City’s approval process for the Project including the statement “NOTICE OF AIRPORT IN VICINITY”. Refer also to Master Response 2.1.9, Proximity to the Los Alamitos Joint Forces Training Base (JFTB), related to buyer awareness. Thus, no further response is required.

A-8 The commenter provides concluding remarks, and the City acknowledges Julie Fitch as the contact person for ALUC. No further response is required.

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4665 Lampson Avenue
Final Environmental Impact Report
Lead Agency: City of Los Alamitos SCH No. 2022090476
Comment Letter B
“Provide a safe and reliable transportation network that serves all people and respects the environment” DISTRICT 12
1750 East 4th Street, Suite 100 | SANTA ANA, CA 92705
(657) 328-6000 | FAX (657) 328-6522 TTY 711
https://dot.ca.gov/caltrans-near-me/district12
June 10, 2024
Mr. Tom Oliver File: LDR/CEQA
Associate Planner SCH: 2022090476
City of Los Alamitos 12-ORA-2022-02577
3191 Katella Avenue I-405, PM 21.086
Los Alamitos, CA 90740 SR 22, PM R0.668
SR-39, PM 9.279
Dear Mr. Oliver,
Thank you for including the California Department of Transportation (Caltrans) in the review of the Draft Environmental Impact Report (EIR) for the 4665 Lampson Avenue Project. The Project Applicant proposes to redevelop the existing office building with a residential development consisting of a variety of different product types, including:
cluster homes, townhomes, and apartments. The unit mix would include 55 cluster homes, 114 townhomes, and 77 affordable multi-family apartment homes. The mixed density for the Project would be 20 dwelling units per acre (DUA). The Project would provide approximately 21,000 sf of common open space, which includes a central 14,000 sf neighborhood open space area. Under the City's R-3 development standards, the maximum building height for the Project is 35 feet. The Project would provide a total of 557 parking spaces: 459 parking spaces for the cluster homes and townhomes and 98 parking spaces for the affordable multifamily apartment homes.

Vehicle access to the Project site would be provided via one driveway on Lampson Avenue.

The 4655 Lampson Avenue Project (Project) site is located in the City of Los Alamitos, Orange County, California. The 12.3-acre Project site is located north of Lampson Avenue and northwest of the intersection of Lampson Avenue and Rose Street. The project is located less than a half mile from Interstate 405 (I-405), The project is also two and a quarter mile from Interstate 605 (I-605), two miles from State Route (SR) SR-39 and almost a mile from SR-22. All four State Routes are owned and operated by Caltrans. Caltrans is a responsible agency on this project, and has the following comments:

B-1

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Lead Agency: City of Los Alamitos SCH No. 2022090476
City of Los Alamitos
June 10, 2024

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“Provide a safe and reliable transportation network that serves all people and respects the environment”

1. To ensure safe operations, please assess the capacity(s) (storage length) of the off-ramps at Valley View St./Bolsa Chica Rd. This assessment should determine if the ramp(s) is/are able to accommodate the demand(s) and will not create a back-up onto the freeway mainline.

2. Regional access to the project is through the I-405, I-605, and SR 22 freeway.

Therefore, the document should include a discussion on any potential impacts of this project I-405, I-605, and SR 22 ramps and mainline.

3. In the Traffic Impact Analysis, please include HCM intersection analysis along with current and projected capacities of local street, and state highways or freeways including ramps that might be impacted.

4. If impact analysis leads to findings of significance on State facilities, please coordinate with Caltrans District 12 Local Development on development of a Traffic Mitigation Agreement or similar effort.

5. Caltrans encourages the design of Complete Streets that include high-quality pedestrian, bicycle, and transit facilities that are safe and comfortable for users of all ages and abilities. Improvements may include providing secure bicycle parking, pedestrian-oriented LED lighting, and comfortable connections to nearby active transportation and/or transit facilities. Complete Streets improvements also promote regional connectivity, improve air quality, reduce congestion, promote improved first-/last-mile connections, and increase safety for all modes of transportation.

6. New residential infill development offers an opportunity to encourage multimodal transportation options. Caltrans encourages the project to look at opportunities to include Complete Streets improvements in the project, and/or to improve bicycle, pedestrian, and transit access and connectivity to nearby bikeway, sidewalk, and transit facilities.

7. Encourage the use of transit among future residents, visitors, and workers of the development. Increasing multimodal transportation may lead to a reduction to congestion, Vehicle Miles Traveled, and improve air quality. Provide adequate wayfinding signage and related amenities to the transit stops within the project vicinity.

8. There is an existing Class II bike lane on Lampson Avenue. Consider adding signage for drivers to watch for bicyclists and pedestrians near driveways on Lampson Avenue. Also, consider green conflict zone paint on the Class II near driveways.

B-2
B-3
B-4
B-5
B-6
B-7
B-8
B-9

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Final Environmental Impact Report
Lead Agency: City of Los Alamitos SCH No. 2022090476
City of Los Alamitos
June 10, 2024

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“Provide a safe and reliable transportation network that serves all people and respects the environment”

9. During project construction, if there are any impacts to the existing bike lanes on Lampson Avenue, please ensure that appropriate temporary detours are provided to maintain safe bicycle access to Lampson Ave.

10.Please ensure that truck parking, ingress and egress, and staging will not interfere with vehicle parking, pedestrian paths, or bicycle lanes/bicycle parking.

11.Establish freight pick up and drop off times that do not coincide with peak commute hours to reduce passenger vehicle conflicts and congestion for freight. Consider designating on-street freight-only parking and delivery time windows so trucks will not resort to double parking, thus causing street traffic congestion.

Caltrans’ mission is to provide a safe, sustainable, equitable, integrated, and efficient transportation system to enhance California’s economy and livability. Please continue to coordinate with Caltrans for any future developments that could potentially impact State transportation facilities. If you have any questions, please do not hesitate to contact Julie Lugaro at: [email protected].

Sincerely,
Scott Shelley
Branch Chief, Regional-LDR-Transit Planning
Caltrans, District 12
B-10
B-11
B-12
B-13

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Responses to Comment B
California Department of Transportation (Caltrans), dated June 10, 2024.

B-1 The commenter provides an introductory statement and summarizes the Project and states that Caltrans is a responsible agency on the project. For clarification regarding the proposed common open space, the Project would provide 58,027 sf of open space, including approximately 16,508 sf of usable common open space, approximately 41,519 sf of private open space, and approximately 78,038 sf of planting area (refer to Page 3-7 of the Draft EIR).

Additionally, vehicle access to the Project site would be provided via two driveways on Lampson Avenue, one for the apartment entry on the western side and one for the primary neighborhood entry central to the site. Furthermore, a restricted emergency vehicle access point with Lampson Avenue would be provided at the eastern end of the site (refer to Page 3-4 of the Draft EIR). There are no expected discretionary or administrative actions needed from Caltrans on this Project; therefore, Caltrans is not considered a responsible agency for this Project.

B-2 The commenter requests an analysis of the capacities (storage length) of off-ramps at Valley View Street and Bolsa Chica Road to determine if the ramps are able to accommodate the demand and will not create a back-up onto the freeway mainline. Although the Caltrans guidelines have been updated and no longer include guidelines related to level of service, Caltrans used to require an analysis of capacities at State facilities when a Project contributes 50 or more peak hour trips to a State off-ramp or intersection. However, this is still a reasonable metric to determine whether a Project would have a measurable impact on State facilities. As shown in Exhibit 4-2 of the Traffic Analysis (Attachment G of this Final EIR), the Project would send less than 50 peak hour trips to the off-ramps at Valley View Street and Bolsa Chica Road (25 AM and 42 PM peak hour trips, respectively). As a result, since the Project would contribute less than 50 peak hour trips to a State off-ramp, and industry standard recognizes that any contribution less than 50 peak hour trips does not cause a significant increase in delay or create a safety hazard; therefore, an analysis of capacities of off-ramps at Valley View Street and Bolsa Chica Road is not needed or required.

B-3 The commenter states that the document should include a discussion on any potential impacts of the Project on I-405, I-605, and SR-22 freeway ramps and mainline. For the reasons stated above, the Project would not have measurable impact to these State facilities, including ramps or mainline facilities. Refer to Response to Comment B-2. Specifically, the peak hour trips at the freeway ramps at I-405, I-605, and SR-22 are listed below and the Project would contribute less than 50 peak hour trips to these ramps, and industry standard recognizes that any contribution less than 50 peak hour trips does not cause a significant increase in delay. • I-405/I-605 via Seal Beach Boulevard: 35 AM and 45 PM peak hour trips • SR-22/I-405 via Valley View/Bolsa Chica: 25 AM and 42 PM peak hour trips

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B-4 The commenter states that the Project’s Traffic Analysis (Technical Appendix N1 of the Draft EIR) should include HCM intersection analysis along with current and projected capacities of local street, and state highways or freeways including ramps that might be impacted. As discussed previously, transportation analysis under CEQA is now based on VMT rather than impacts to automobile delay-LOS based on intersection analysis (traffic congestion).

The intersection analysis methodology complies with the traffic guidelines of the jurisdiction where the study area intersections are located. The study area intersections (see Table 1-1 of Attachment G of this Final EIR) are within the jurisdictions of Los Alamitos, Seal Beach, and Garden Grove; and not Caltrans. The cities of Los Alamitos, Seal Beach, and Garden Grove require Intersection Capacity Utilization (ICU) analysis and not HCM per their respective Traffic Study Guidelines. Because Caltrans does not have jurisdiction over study area intersections, HCM intersectional analysis is not required.

B-5 The commenter states that if the impact analysis leads to findings of significance on State facilities, to coordinate with Caltrans District 12 Local Development on development of a Traffic Mitigation Agreement or similar effort. This comment is noted. Please refer to responses to Comments B-2 through B-4 regarding Project’s impacts on State facilities. No further response is required.

B-6 The commenter states that Caltrans encourages the design of Complete Streets that include high-quality pedestrian, bicycle, and transit facilities that are safe and comfortable for users of all ages and abilities. The Project has been designed to incorporate pedestrian improvements and tie into regional bicycle facilities. Frontage improvements would include sidewalk improvements, driveway modifications to accommodate site access, and landscaping improvements as required by City standards, which would improve the safety and comfort of pedestrian and bicycle crossings. As discussed in Section 3.0, Project Description, of the Draft EIR, non-motorized circulation would include pedestrian connectivity with existing sidewalks along Lampson Avenue, including an existing signalized pedestrian connection to the south at Rose Street and Lampson Avenue and pedestrian “paseo” connections with Arbor Park and the Arbor Dog Park to the north. The Project would provide pedestrian gates to be controlled by the Homeowners’ Association to restrict residents from entering Arbor Park and Arbor Dog Park outside of hours specified by JTFB. The Project would also promote the use of bicycles as an alternative means of transportation by providing short-term and/or long-term bicycle parking accommodations (refer to Pages 3-4 and 3-5 of the Draft EIR). Refer also to Master Response 2.1.2, Roadway Safety on Lampson Avenue, related to Pedestrian and Bicycle Facilities. Refer also to Response to Comment B-7.

B-7 The commenter encourages the Project to look at opportunities to encourage multimodal transportation options, to include Complete Streets improvements in the Project, and/or to improve bicycle, pedestrian, and transit access and connectivity to nearby bikeway, sidewalk, and transit facilities. As discussed in Table 4.15-1, Consistency with the General Plan Mobility and Circulation Element, of the Draft EIR, the Project facilitates multimodal mobility. An offPage 588 of 3005 4665 Lampson Avenue
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site pedestrian circulation system would be available in proximity to the Project site with an interconnected paved sidewalk system with the roadway right-of-way separated from vehicular travel lanes by a landscaped parkway. There are existing Class II (on-street, striped) bike lanes on the north and south sides of Lampson Avenue from Basswood Street to the east.

Additionally, there is a Class I bike/pedestrian path along Seal Beach Boulevard, north of Lampson Avenue and a Class II bike lane south of Lampson Avenue. The Project would maintain the existing Class II bike lane on Lampson Avenue along the Project site’s frontage.

Moreover, bike lane improvements are currently ongoing on Lampson Avenue between Basswood Street and Seal Beach Boulevard, which will connect to the existing Class I bike lane on Lampson Avenue (refer to Page 4.15-10 of the Draft EIR). Refer also to Response to Comment B-6.

B-8 The commenter encourages the use of transit among future residents, visitors, and workers of the Project to reduce congestion, Vehicle Miles Traveled and improve air quality. The commenter also encourages the provision of adequate wayfinding signage and related amenities to the transit stops within the Project vicinity. There is currently no transit service to the Project site or within a 0.25 mile radius. The nearest OCTA bus stop from the Project site is Route 123, approximately 1.2 miles at the intersection of Valley View Street and Lampson Avenue. As discussed in Section 4.15, Transportation of the Draft EIR, however, Mitigation Measure MM 4.15-1 includes implementing CAPCOA strategies such as coordination with OCTA to provide new or re-routing existing transit services to the site, as determined to be feasible by OCTA pursuant to OCTA’s standards (refer to Page 4.15-19 of the Draft EIR).

Additionally, regarding air quality impacts, as discussed in Section 4.2, Air Quality, of the Draft EIR, the Project would not exceed criteria pollutant thresholds established by the South Coast AQMD for emissions of any criteria pollutant and impacts would be less than significant (refer to Pages 4.2-24 and 4.2-25 of the Draft EIR).

B-9 The commenter states that there is an existing Class II bike lane on Lampson Avenue and recommends adding signage for drivers to watch for bicyclists and pedestrians near driveways on Lampson Avenue and green conflict zone paint on the Class II bike lane near driveways.

Refer to Master Response 2.1.2, Roadway Safety on Lampson Avenue, related to sight distance and other safety measures implemented by the Project. As demonstrated, the Project would not result in a safety hazard. However, this comment will be taken under consideration; the City Engineer will evaluate the need for signage and/or green conflict zone paint during review of the Project’s construction drawings. Thus, no further response is required.

B-10 The commenter requests that appropriate temporary detours are provided to maintain safe bicycle access to Lampson Avenue if there are encroachments to existing bike lanes during construction. As discussed in 4.8, Hazards and Hazardous Materials, of the Draft EIR, during construction, the Project would result in roadway improvements along Lampson, including replacement of the existing median curb and construction of the two proposed driveways.

Construction on Lampson will require an encroachment permit and approval from the City Engineer. Lane closures that may be required for median improvements would be temporary

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and require a permit and compliance with LAMC 12.08.200, Safety precautions–Obstruction of traffic. Compliance with LAMC 12.08.200 would ensure safe crossing and access for all vehicles and pedestrians/bicyclists at all times (refer to Pages 4.8-21 of the Draft EIR).

B-11 The commenter requests to ensure that truck parking, ingress and egress, and staging will not interfere with vehicle parking, pedestrian paths, or bicycle lanes/bicycle parking. During construction all staging will occur on the Project site to ensure that there are no conflicts with vehicle parking, pedestrian paths, or bicycle lanes/parking. Refer also to Response to Comment B-10 above regarding temporary closures during construction. Operationally, since the proposed use is residential, a limited number of trucks would travel to the Project site (e.g. trash trucks, emergency vehicles, delivery vans). Figure 4.8-3, Fire Master Plan, demonstrated adequate turning radii for emergency vehicles to access the Project site. A Safety Evaluation was prepared for the Project (Attachment H of this Final EIR), which evaluated on-site vehicle circulation. The Safety Evaluation identifies the on-site circulation for the site, including various vehicle paths (front-loading garbage trucks, fire trucks, delivery trucks, etc.) for various internal drive aisles, which allow for two-way traffic. Access to and from the site will be accommodated via driveways on Lampson Avenue. The vehicle turning templates show acceptable turning movements for the various vehicles and trucks anticipated to access the site (see Attachment D of Attachment H of this Final EIR). Therefore, truck parking, ingress and egress, and construction staging would not interfere with vehicle parking, pedestrian paths, or bicycle lanes/bicycle parking.

B-12 The commenter requests that the Project establish freight Pick up and drop off times that do not coincide with peak commute hours to reduce passenger vehicle conflicts and congestion for freight. The Project does not involve freight operations as it is a residential project. As it relates to delivery trucks refer to Response to Comment B-11. There would be no conflicts between delivery trucks and passenger cars and congestion is not an impact evaluated under CEQA (see Master Response 2.1.2, Roadway Safety on Lampson Avenue). However, this comment is noted for the record.

B-13 The commenter provides concluding remarks, and the City acknowledges Julie Lugaro as the contact person for Caltrans. Thus, no further response is required.

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Final Environmental Impact Report
Lead Agency: City of Los Alamitos SCH No. 2022090476
Comment Letter C
May 29, 2024
City of Los Alamitos
Attn: Tom Oliver, Associate Planner
3191 Katella Avenue
Los Alamitos, CA 90720
[email protected]
RE: Notice of Availability of Draft Environmental Impact Report for the 4665 Lampson Avenue Project
Dear Tom,
Thank you for providing the Notice of Availability of Draft Environmental Impact Report for the 4665 Lampson Avenue Project. Department staff of the City of Garden Grove have reviewed the available documents. The following comments are provided for your consideration:
 Please see attached redlines, by the City of Garden Grove Public Works Department, Traffic Engineering Division, on the Traffic Analysis Report by Urban Crossroads, dated June 1, 2023.

If you have any questions, please contact me at (714) 741-5314 or [email protected].

Sincerely,
Chris Chung
Senior Planner
Attachments: Redlines on the Traffic Analysis Report by Urban Crossroads, dated June 1, 2023 C-1

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Lead Agency: City of Los Alamitos SCH No. 2022090476
N1_TA Report - GG Engineering Comments 5 10 24.pdf Markup Summary
Subject: Callout
Page Label: 13
Author: juann
Date: 5/10/2024 2:14:27 PM
Status:

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Why were the following intersections not studied?

11. Lampson/Manley

12. Lampson/Blackmer
Callout (17)
Subject: Callout
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Date: 5/9/2024 1:50:55 PM
Status:

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Lampson/Manley
Subject: Callout
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Lampson/Blackmer
Subject: Callout
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elaborate on HCM and ICU methodology and why
HCM is appropriate to use at Valley
View/Lampson.

Subject: Callout
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Author: juann
Date: 5/10/2024 3:13:47 PM
Status:

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Who provided timing sheet to you? AM/PM cycle
length: 130 seconds.

Subject: Callout
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Author: juann
Date: 5/10/2024 3:16:16 PM
Status:

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130 seconds
Why were the following intersections not studied?

11. Lampson/Manley

12. Lampson/Blackmer
Lampson/Manley
Lampson/Blackmer
elaborate on HCM and ICU methodology and why HCM is appropriate to use at Valley View/Lampson.

Who provided timing sheet to you?
AM/PM cycle length: 130 seconds.
130 seconds
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Subject: Callout
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Date: 5/10/2024 3:45:58 PM
Status:

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review comments in appendices, which I've
attached at the end of this document and update
values.

Subject: Callout
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Author: juann
Date: 5/10/2024 3:32:46 PM
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where is ideal flow? Lane capacities of 1700 per
hour per lane for through and turn lanes shall be
used per City of Garden Grove's TIA Guidelines.

Subject: Callout
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Author: juann
Date: 5/10/2024 3:41:12 PM
Status:

Color:

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where is ideal flow? Lane capacities of 1700 per
hour per lane for through and turn lanes shall be
used per City of Garden Grove's TIA Guidelines.

Subject: Callout
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Date: 5/10/2024 3:39:02 PM
Status:

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review city's tia guidelines
Subject: Callout
Page Label: 66
Author: juann
Date: 5/10/2024 3:40:14 PM
Status:

Color:

Layer:

Space:

Who provided timing sheet to you? AM/PM cycle
length: 130 seconds.

Subject: Callout
Page Label: 66
Author: juann
Date: 5/10/2024 3:40:18 PM
Status:

Color:

Layer:

Space:
review city's tia guidelines
review comments in appendices,
which I've attached at the end of this
document and update values.
where is ideal flow? Lane capacities of 1700 per hour per lane for through and turn lanes shall be used per City of Garden Grove's TIA Guidelines. where is ideal flow? Lane capacities of 1700 per hour per lane for through and turn lanes shall be used per City of Garden Grove's TIA Guidelines. review city's tia guidelines
Who provided timing sheet to you?
AM/PM cycle length: 130 seconds.
review city's tia guidelines
C-1
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Lead Agency: City of Los Alamitos SCH No. 2022090476
Subject: Callout
Page Label: 67
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Status:

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130 seconds
Subject: Callout
Page Label: 67
Author: juann
Date: 5/10/2024 3:41:53 PM
Status:

Color:

Layer:

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where is ideal flow? Lane capacities of 1700 per
hour per lane for through and turn lanes shall be
used per City of Garden Grove's TIA Guidelines.

Subject: Callout
Page Label: 68
Author: juann
Date: 5/10/2024 3:42:17 PM
Status:

Color:

Layer:

Space:
where is ideal flow? Lane capacities of 1700 per
hour per lane for through and turn lanes shall be
used per City of Garden Grove's TIA Guidelines.

Subject: Callout
Page Label: 50
Author: juann
Date: 5/10/2024 3:45:25 PM
Status:

Color:

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who provided the timing sheet?
Subject: Callout
Page Label: 50
Author: juann
Date: 5/13/2024 9:39:02 AM
Status:

Color:

Layer:

Space:

Perform left turn queuing analysis to determine if
left turn pockets are adequate.

Subject: Cloud+
Page Label: 63
Author: juann
Date: 5/10/2024 3:28:53 PM
Status:

Color:

Layer:

Space:

Lane capacities of 1700 per hour per lane for
through and turn lanes shall be used per City of
Garden Grove's TIA Guidelines.

Cloud+ (2)
130 seconds
where is ideal flow? Lane capacities of 1700 per hour per lane for through and turn lanes shall be used per City of Garden Grove's TIA Guidelines. where is ideal flow? Lane capacities of 1700 per hour per lane for through and turn lanes shall be used per City of Garden Grove's TIA Guidelines. who provided the timing sheet?
Perform left turn queuing analysis to
determine if left turn pockets are
adequate.

Lane capacities of 1700 per hour per lane for through and turn lanes shall be used per City of Garden Grove's TIA Guidelines.

C-1
(CONT.)

Page 594 of 3005 ends

4665 Lampson Avenue
Final Environmental Impact Report
Lead Agency: City of Los Alamitos SCH No. 2022090476
Subject: Cloud+
Page Label: 66
Author: juann
Date: 5/10/2024 3:40:04 PM
Status:

Color:

Layer:

Space:

Lane capacities of 1700 per hour per lane for
through and turn lanes shall be used per City of
Garden Grove's TIA Guidelines.

Subject: Rectangle
Page Label: 50
Author: juann
Date: 5/10/2024 3:29:14 PM
Status:

Color:

Layer:

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Rectangle (2)
Subject: Rectangle
Page Label: 50
Author: juann
Date: 5/10/2024 3:03:14 PM
Status:

Color:

Layer:

Space:

Subject: Text Box
Page Label: 63
Author: juann
Date: 5/10/2024 3:35:34 PM
Status:

Color:

Layer:

Space:
incorporate comments to All sheets!!!!
Text Box (5)
Subject: Text Box
Page Label: 64
Author: juann
Date: 5/10/2024 3:35:44 PM
Status:

Color:

Layer:

Space:
incorporate comments to All sheets!!!!
Subject: Text Box
Page Label: 65
Author: juann
Date: 5/10/2024 3:35:49 PM
Status:

Color:

Layer:

Space:
incorporate comments to All sheets!!!!
Lane capacities of 1700 per hour per lane for through and turn lanes shall be used per City of Garden Grove's TIA Guidelines. incorporate comments to All sheets!!!!
incorporate comments to All sheets!!!!
incorporate comments to All sheets!!!!
C-1
(CONT.)

Page 595 of 3005 ends

4665 Lampson Avenue
Final Environmental Impact Report
Lead Agency: City of Los Alamitos SCH No. 2022090476
Subject: Text Box
Page Label: 66
Author: juann
Date: 5/10/2024 3:40:09 PM
Status:

Color:

Layer:

Space:

Incorporate comments from Appendices 5.1
Subject: Text Box
Page Label: 67
Author: juann
Date: 5/10/2024 3:41:45 PM
Status:

Color:

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incorporate comments to All sheets!!!!
Incorporate comments from Appendices 5.1
incorporate comments to All sheets!!!!
C-1
(CONT.)

Page 596 of 3005 ends

4665 Lampson Avenue
Final Environmental Impact Report
Lead Agency: City of Los Alamitos SCH No. 2022090476
CITY OF GARDEN GROVE ENGINEERING COMMENTS 5 10 24

Page 597 of 3005 ends

4665 Lampson Avenue
Final Environmental Impact Report
Lead Agency: City of Los Alamitos SCH No. 2022090476
Why were the following intersections not studied?

11. Lampson/Manley

12. Lampson/Blackmer
C-2

Page 598 of 3005 ends

4665 Lampson Avenue
Final Environmental Impact Report
Lead Agency: City of Los Alamitos SCH No. 2022090476
Lampson/Manley
Lampson/Blackmer
C-2
(CONT.)

Page 599 of 3005 ends

4665 Lampson Avenue
Final Environmental Impact Report
Lead Agency: City of Los Alamitos SCH No. 2022090476
elaborate on HCM and ICU methodology and why HCM is appropriate to use at Valley View/Lampson. review comments in appendices,
which I've attached at the end of this
document and update values.
who provided the timing sheet?
Perform left turn queuing analysis to
determine if left turn pockets are
adequate.

C-3
C-4
C-5
C-6

Page 600 of 3005 ends

4665 Lampson Avenue
Final Environmental Impact Report
Lead Agency: City of Los Alamitos SCH No. 2022090476
Who provided timing sheet to you?
AM/PM cycle length: 130 seconds.

Lane capacities of 1700 per hour per lane for through and turn lanes shall be used per City of Garden Grove's TIA Guidelines. incorporate comments to All sheets!!!!
review city's tia guidelines C-7
C-8

Page 601 of 3005 ends

4665 Lampson Avenue
Final Environmental Impact Report
Lead Agency: City of Los Alamitos SCH No. 2022090476
130 seconds
where is ideal flow? Lane capacities of 1700 per hour per lane for through and turn lanes shall be used per City of Garden Grove's TIA Guidelines. incorporate comments to All sheets!!!!

Page 602 of 3005 ends

4665 Lampson Avenue
Final Environmental Impact Report
Lead Agency: City of Los Alamitos SCH No. 2022090476
where is ideal flow? Lane capacities of 1700 per hour per lane for through and turn lanes shall be used per City of Garden Grove's TIA Guidelines. incorporate comments to All sheets!!!!
C-8

Page 603 of 3005 ends

4665 Lampson Avenue
Final Environmental Impact Report
Lead Agency: City of Los Alamitos SCH No. 2022090476
Incorporate comments from Appendices 5.1 Who provided timing sheet to you? AM/PM cycle length: 130 seconds.

Lane capacities of 1700 per hour per lane for through and turn lanes shall be used per City of Garden Grove's TIA Guidelines. review city's tia guidelines

Page 604 of 3005 ends

4665 Lampson Avenue
Final Environmental Impact Report
Lead Agency: City of Los Alamitos SCH No. 2022090476
130 seconds
where is ideal flow? Lane capacities of 1700 per hour per lane for through and turn lanes shall be used per City of Garden Grove's TIA Guidelines. incorporate comments to All sheets!!!!

Page 605 of 3005 ends

4665 Lampson Avenue
Final Environmental Impact Report
Lead Agency: City of Los Alamitos SCH No. 2022090476
where is ideal flow? Lane capacities of 1700 per hour per lane for through and turn lanes shall be used per City of Garden Grove's TIA Guidelines.

Page 606 of 3005 ends

4665 Lampson Avenue
Final Environmental Impact Report 3.0 Responses to Comments Lead Agency: City of Los Alamitos SCH No. 2022090476

Page 3 ends

Responses to Comment C
City of Garden Grove, dated May 29, 2024.

C-1 The commenter provides redlines to the Project’s Traffic Analysis (Technical Appendix N1 of the Draft EIR). Pursuant to the commenter’s request, the Project’s Traffic Analysis has been revised and included as Attachment G to this Final EIR. Additionally, responses to each redline/comment bubble on the TA pages provided by the commenter are addressed below.

C-2 The commenter inquires why Lampson/Manley and Lampson/Blackmer were not studied. Both Manley and Blackmer are not identified as City General Plan roadways. However, both Manley and Blackmer are signalized intersections that provide access into existing residential neighborhoods to the north and south. Similar to the signalized intersections at Rose and Tulip, it is anticipated these intersections would also operate at acceptable LOS and would have similar affects to the intersections due to added eastbound and westbound through traffic from the Project, and therefore no further study of these intersections was required. Additionally, the Project scoping agreement was provided to the City of Garden Grove on August 24, 2022 requesting a review of the scoping agreement and applicable cumulative project information.

The City did not identify these intersections for inclusion at the time of scoping, and for that reason as well these intersections were not included.

C-3 The commenter inquires why HCM methodology is appropriate to use at Valley View/Lampson. Pursuant to the commenter’s request and the City of Garden Grove’s traffic study guidelines, the HCM analysis for the intersection of Valley View and Lampson has been removed. Only ICU methodology has been utilized to evaluate the signalized intersection.

C-4 The commenter inquires about who provided the timing sheet and AM/PM cycle length of 130 seconds. The timing sheet was requested from each applicable agency at the time of scoping but was not responded to by Garden Grove. However, Pursuant to the commenter’s request, the revised Traffic Analysis (Attachment G to this Final EIR) has been updated to reflect the 130-second cycle length denoted by City of Garden Grove staff for the intersection of Valley View and Lampson. This revision has been made to both peak hours for all study area intersections.

C-5 The commenter requests review of the comments made in the appendices and update values.

Pursuant to the commenter’s request, applicable cycle length, clearance time, and saturation flow rates have been updated as denoted, consistent with the City of Garden Grove’s Guidelines. Consistent with the City’s Guidelines the clearance or lost time has been updated to 5% of the cycle length which is rounded up to 7 seconds. The revised Traffic Analysis is included in Attachment G to this Final EIR.

C-6 The commenter requests to perform left turn queuing analysis to determine if left turn pockets are adequate at the intersection of Valley View/Lampson. Pursuant to the commenter’s request, a queuing analysis has been performed for General Plan Buildout With Project traffic

Page 607 of 3005 ends

4665 Lampson Avenue
Final Environmental Impact Report 3.0 Responses to Comments Lead Agency: City of Los Alamitos SCH No. 2022090476

Page 3 ends

conditions to verify the queuing needs for the left turn pockets and results are reported in Table 6-3 of the updated Traffic Analysis (see Attachment G to this Final EIR).

C-7 The commenter requests to review the City’s TIA Guidelines regarding Minimum Green. Note that minimum green is not an applicable input parameter for the ICU methodology. However, consistent with the City’s Guidelines the clearance or lost time has been updated to 5% of the cycle length which is rounded up to 7 seconds (see Attachment G to this Final EIR).

C-8 The commenter inquires about the ideal flow and that lane capacities of 1700 per hour per lane for through and turn lanes shall be used per the City of Garden Grove’s TIA Guidelines. This comment is no longer applicable as the HCM based analysis for Valley View/Lampson has been removed. However, all of the ICU analysis for the intersection of Valley View/Lampson has been revised to assume 1700 vehicle per hour per lane per the City’s Guidelines as noted in the comment.

Page 608 of 3005 ends

4665 Lampson Avenue
Final Environmental Impact Report
Lead Agency: City of Los Alamitos SCH No. 2022090476
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4665 Lampson Avenue
Final Environmental Impact Report
Lead Agency: City of Los Alamitos SCH No. 2022090476
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Page 610 of 3005 ends

4665 Lampson Avenue
Final Environmental Impact Report
Lead Agency: City of Los Alamitos SCH No. 2022090476
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Page 611 of 3005 ends

4665 Lampson Avenue
Final Environmental Impact Report
Lead Agency: City of Los Alamitos SCH No. 2022090476
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Page 612 of 3005 ends

4665 Lampson Avenue
Final Environmental Impact Report
Lead Agency: City of Los Alamitos SCH No. 2022090476
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Page 613 of 3005 ends

4665 Lampson Avenue
Final Environmental Impact Report
Lead Agency: City of Los Alamitos SCH No. 2022090476
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4665 Lampson Avenue
Final Environmental Impact Report
Lead Agency: City of Los Alamitos SCH No. 2022090476
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4665 Lampson Avenue
Final Environmental Impact Report
Lead Agency: City of Los Alamitos SCH No. 2022090476
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4665 Lampson Avenue
Final Environmental Impact Report 3.0 Responses to Comments Lead Agency: City of Los Alamitos SCH No. 2022090476

Page 3 ends

Responses to Comment D
City of Seal Beach, dated June 10, 2024.

D-1 The commenter provides introductory remarks and summarizes the Project. The commenter states that the Draft EIR should more thoroughly disclose the regulatory powers of the City of Seal Beach that apply to this Project and impacts to the City of Seal Beach. The City acknowledges the City of Seal Beach’s concerns related to its approval authority and impacts of the Project on Seal Beach services and infrastructure. Revisions to the Draft EIR have been made to address these concerns. Specific responses and revisions to the Draft EIR have been provided in responses to Comments D-2, D-4, D-5, and D-8, below.

D-2 The commenter states that the City of Seal Beach should be listed as a Responsible Agency as it has discretionary approval of the inter-jurisdictional sewer service agreement and other Project improvements. Please note that the City of Seal Beach was acknowledged as a responsible agency in the Draft EIR in Table 3-6, Project-Related Approvals/Permits. Pursuant to the commenter’s request, the City of Seal Beach has also been added to the summary of responsible agencies in Section 1.0, Introduction, of the Draft EIR. Page 1-37 of the Draft EIR has been revised as shown below and in Section 5.0 of this Final EIR.

For the Project, the City of Seal Beach, Orange County Airport Land Use Commission (ALUC), Regional Water Quality Control Board (RWQCB), Orange County Sanitation District (OCSD), Southern California Gas Company (SoCalGas), Southern California Edison (SCE), and the South Coast Air Quality Management District (SCAQMD) are identified as Responsible Agencies. Regardless, this EIR can be used by any Trustee Agency or Responsible Agency, whether identified in this EIR or not, as part of their decision-making processes in relation to the proposed Project.

D-3 The commenter states that the City of Seal Beach did not request a traffic signal to be installed at the primary neighborhood access and that the text be revised to reflect the change.

Additionally, the commenter recommends that the proposed traffic signal should be applied for, approved, and permitted by the Seal Beach and mitigation measures be included to fund the capital and maintenance cost of the signal.

The City acknowledges that the City of Seal Beach did not request that a traffic signal be installed at the primary neighborhood entry. As demonstrated in Section 6.5 of the Traffic Analysis (Attachment G of this Final EIR), the traffic signal does not meet peak hour or planning level warrant criteria. As a result, the Project no longer proposes a traffic signal in this location. Additionally, refer to Master Response 2.1.2, Roadway Safety on Lampson Avenue, for a detailed discussion of the traffic signal warrant analysis and Master Response

2.1.2, Roadway Safety on Lampson Avenue, regarding the Project’s safety impacts.

Page 617 of 3005 ends

4665 Lampson Avenue
Final Environmental Impact Report 3.0 Responses to Comments Lead Agency: City of Los Alamitos SCH No. 2022090476

Page 3 ends
Page 3 ends

EIR.

Vehicle access to the Project site would be provided via two driveways on Lampson Avenue, one for the apartment entry on the western side and one for the primary neighborhood entry central to the site. Additionally, a restricted emergency vehicle access point with Lampson Avenue would be provided at the eastern end of the site. The Project would implement stop controls for the southbound approach at all driveways on Lampson Avenue. The driveway for the apartment entry would be restricted to right-in/right-out only. Vehicular circulation would be unrestricted throughout the Project site. The primary neighborhood entry is not anticipated to meet a peak hour or planning level (daily volume) based traffic signal warrants. However, per the request of the City of Seal Beach and in response to public comments during scoping, the Project will install a traffic signal at the primary neighborhood entry in coordination with both the City of Los Alamitos and City of Seal Beach.

D-4 The commenter states that the Draft EIR should disclose that the proposed water infrastructure is not in place and is contingent upon receiving a Seal Beach City Council-approved agreement with the proposed water purveyor.

Golden State Water Company (GSWC) is currently installing a public 12” water main from the intersection of Blackmer Street and Apia Drive to Lampson Avenue and Lunar Drive, approximately 600’ east of the site, which provides adequate water services to support the development. As directed by GSWC, a New Business Application is required to request a main line extension on Lampson Avenue at Lunar Drive to the site, including in-tract public improvements. This would include the main line, water meters, and public fire hydrants to service the Project site. A separate encroachment permit from the City of Seal Beach and Agreement of Franchise Facilities between GSWC and the City of Seal Beach is required.

Pursuant to the commenter’s request, Page 3-9 and Table 3-6 on Page 3-18 of the Draft EIR have been revised as shown below and in Section 5.0 of this Final EIR.

Golden State Water Company would provide water service to the Project.

Domestic water lines would be provided as shown in Figure 3-23, Utility Plan.

In addition, the Project would include a 1,200 feet watermain extension between the eastern driveway and the existing GSWC watermain at the intersection of Lunar and Lampson. The Project would include, at a minimum, an 8” watermain size for the extension. The proposed water infrastructure would require an encroachment permit from the City of Seal Beach and Agreement of Franchise Facilities between GSWC and the City of Seal Beach.

City of Seal Beach • Issuance of Public Works Permit
(encroachment permit) for infrastructure

Page 618 of 3005 ends

4665 Lampson Avenue
Final Environmental Impact Report 3.0 Responses to Comments Lead Agency: City of Los Alamitos SCH No. 2022090476

Page 3 ends

improvements within the Lampson Ave.
right-of-way.
• Agreement of Franchise Facilities between
GSWC and the City of Seal Beach
• Agreement between the Rossmoor/Los
Alamitos Area Sewer District and the City
of Seal Beach for Inter-Jurisdictional
Wastewater Services.
• Approval of stormwater
discharge/conveyance, if required.
• Approval Water Quality Management Plan,
if required.
• Approval of infrastructure plans
directly/indirectly related to Seal Beach, if
required.

D-5 The commenter states that the Draft EIR should disclose that Seal Beach sanitary sewer service is contingent upon receiving a Seal Beach City Council-approved agreement for service outside the Seal Beach service area boundaries and LAFCO approval, if required. Additionally, the commenter states that the Draft EIR should include an alternative that addresses what would occur if Seal Beach does not approve an inter-jurisdictional sewer service agreement.

The Project site is located within Rossmoor/Los Alamitos Area Sewer District’s (RLAASD) sewer service area boundaries. RLAASD does not, however, have sewer lines that connect to the Project site. As a result, since approximately January 1975, the City of Seal Beach has been providing sewer services to the Project site.

It is expected that the proposed agreement for Inter-Jurisdictional Wastewater Services (Wastewater Agreement) between the City of Seal Beach and RLAASD is exempt from review and/or approval by LAFCO pursuant to California Government Code §56133. This statute generally states that a city or district may provide new or extended services by contract or agreement outside its jurisdictional boundary only if it first requests and receives written approval from LAFCO in which the affected territory is located (Cal. Gov. Code §56133(a)).

A subsection of this statute, §56133(e), however, provides limited exceptions to where LAFCO approval is not required for new or extended services. First, §56133(e)(1) states that the section does not apply to, “(1) Two or more public agencies where the public service to be provided is an alternative to, or substitute for, public services already being provided by an existing public service provider.” (Cal. Gov. Code §56133(e)(1)). The Wastewater Agreement between the City of Seal Beach and RLAASD represents a straightforward substitution of one service provider (Seal Beach) for another (RLAASD), and no third party service provider will be displaced by the agreement. Second, §56133(e)(4) states that the section does not apply to, “(4) An extended service that a city or district was providing on or before January 1, 2001.” (Cal.

Gov. Code §56133(e)(4)). The City of Seal Beach began providing sewer service to the Project

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4665 Lampson Avenue
Final Environmental Impact Report 3.0 Responses to Comments Lead Agency: City of Los Alamitos SCH No. 2022090476

Page 3 ends

site on or about January 1975. Therefore, it is anticipated that the agreement will be exempt from review and approval by LAFCO. Nevertheless, the Project Applicant will follow all applicable and required LAFCO processes and procedures related to sanitary sewer service.

Additionally, the Project Applicant would be required to pay connection or service fees to the City of Seal Beach to provide service.

The Project site is within the Rossmoor-Los Alamitos Area Sewer District service area, however there are limited to no feasible alternative sanitary sewer connection options within the surrounding area in the event the City of Seal Beach does not approve an inter-jurisdictional sewer service agreement2
. Any other option would require prohibitively expensive construction, as well as difficult to resolve engineering issues related to crossing conflicts, elevation changes, and potential downstream capacity concerns because the existing site is not currently oriented to discharge to this area. Furthermore, the existing site (when the office use was previously occupied) discharged to the City of Seal Beach public sanitary sewer system and therefore the site is currently configured such that discharges to Seal Beach sanitary sewer service would be most efficient and logical.

Pursuant to the commenter’s request, Page 3-9 of the Draft EIR has been revised as shown below and in Section 5.0 of this Final EIR.

Although the Project site is in the City of Los Alamitos, sanitary sewer will be served by the City of Seal Beach via the Rossmoor-Los Alamitos Area Sewer District. The Rossmoor/Los Alamitos Sewer District would provide wastewater conveyance and treatment services to the Project. A lift station and force main is proposed at the southeast corner of the Project site (refer to Figure 3-23, Utility Plan). The Project would connect the force main to the existing 8- inch sanitary sewer line at the southeast corner of the site. All connections to existing sanitary sewer lines require approval by the City of Seal Beach and would be constructed in accordance with the City of Seal Beach standards.

Additionally, an agreement between the Rossmoor/Los Alamitos Area Sewer District and the City of Seal Beach would be required for Inter-Jurisdictional Wastewater Services.

D-6 The commenter states that the Draft EIR should disclose that the proposed alternate stormwater drainage would flow onto Seal Beach right-of-way and requires approval from the City of Seal Beach.
2 The City of Seal Beach has indicated that the inter-jurisdictional sewer service agreement requires Seal Beach City Council approval and therefore is considered a discretionary action. This EIR is intended to provide the environmental clearance for future discretionary and ministerial actions relating to this Project, including the inter-jurisdictional sewer service agreement.

Page 620 of 3005 ends

4665 Lampson Avenue
Final Environmental Impact Report 3.0 Responses to Comments Lead Agency: City of Los Alamitos SCH No. 2022090476

Page 3 ends

The preferred treatment of stormwater runoff for the Project would flow to the existing 18” storm drain, located near the southwest corner of the site, that ultimately discharges to the existing JFTB drainage facilities consistent of at-grade depressed basins and hydraulically connected pipes. However, it is noted in Section 4.9, Hydrology and Water Quality, of the Draft EIR and in the updated Hydrology Study (Attachment E of this Final EIR), that in the event the existing 18” pipe is clogged or the existing at-grade depressed basins reach capacity, stormwater runoff from the site overflows onto Lampson Avenue in the existing condition based on field survey topographic findings and photographic evidence. Therefore, a parkway drain is proposed on Lampson Avenue, near the southwest corner of the site, to provide proper emergency overflow, matching the historic drainage condition. Any proposed improvements and/or stormwater runoff tributary to Lampson Avenue is subject to the City of Seal Beach’s review and approval.

Pursuant to the commenter’s request, Page 3-10 of the Draft EIR has been revised as shown below and in Section 5.0 of this Final EIR.

An alternate plan for stormwater conveyance is proposed in the event the preferred route (historical flow) across the JFTB, as described above, is not available. The alternate would include stormwater outflow onto Lampson Avenue within Seal Beach right-of-way, which would subsequently flow west to an existing stormwater catch basin approximately 2,200 feet west of the Project site. Stormwater outflow onto Lampson Avenue would require installation of a parkway drain on Lampson and a related encroachment permit from the City of Seal Beach. Due to existing flooding concerns on Lampson Avenue, the onsite pump system would allow for low flows to enter Lampson Avenue up until the time that the flows begin to exceed the allowed 25-year storm event in Lampson Avenue. At that point, peak flows would be detained onsite. Once the flows are no longer above the allowed 25-year storm event in Lampson Avenue, onsite flows to Lampson Avenue would resume. Under the Alternate Off-Site Storm Drain plan, stormwater will be detained and mitigated onsite such that Lampson Avenue meets OC Hydrology flooding standards.

Approximately 32,300 cf of water would need to be detained onsite to ensure that offsite 25-year flows are not exceeded. Detained volumes would be discharged from the site via a pump system at flow rates that do not exceed the existing condition flow rates.

D-7 The commenter states that the Project is proposing 102 on-site parking spaces less than the City of Los Alamitos Municipal Code requirements. The commenter requests an analysis to determine whether provided parking will have any parking impacts on Seal Beach. A parking evaluation was included in the Draft EIR and a Parking Analysis was provided as Technical Appendix P of the Draft EIR. Refer also to Master Response 2.1.3, Parking, for a detailed

Page 621 of 3005 ends

4665 Lampson Avenue
Final Environmental Impact Report 3.0 Responses to Comments Lead Agency: City of Los Alamitos SCH No. 2022090476

Page 3 ends

discussion on parking impacts. As concluded, the Project’s proposed parking supply is appropriate to serve the potential parking needs of the Project. As a result, Project residents would have adequate parking on-site and would not park on streets in the adjacent neighborhood in the City of Seal Beach.

D-8 The commenter recommends including the Stormwater Pollution Prevention Plan (SWPPP) & Dewatering Plan, Water Quality Management Plan, Traffic Impact Study, and approval of infrastructure plans directly/indirectly related to Seal Beach in the list of approvals and permits required from Seal Beach.

The City of Los Alamitos, as Lead Agency, is ultimately responsible for review and approval of the Project’s Traffic Analysis and Water Quality Management Plan per the County of Orange MS4 Permit requirements. The City acknowledges that the City of Seal Beach, as a Responsible Agency, has review and approval authority for infrastructure plans directly and indirectly related to Seal Beach. However, the SWPPP and Dewatering Plan is a State-reviewed and permitted document, therefore the State Water Resources Control Board (SWRCB) is also noted as a Responsible Agency for the SWPPP.

Pursuant to the commenter’s request, Page 3-8 of the Draft EIR has been revised as shown in Response to Comment D-4 and in Section 5.0 of this Final EIR.

D-9 The commenter asked for clarification as to whether all proposed components of the Old Ranch Country Club Development were included in the Project’s cumulative analysis. The development capacity for the Old Ranch Country Club Development identified in the cumulative impact modeling was based on the City of Seal Beach’s Housing Element Sites Inventory capacity identified for this site. To ensure the cumulative impact modeling is as accurate as possible, the modeling was updated, where appropriate, to include the additional development capacities identified by the commenter. Specifically, the Traffic Analysis (Attachment G to this Final EIR) has been updated to include all proposed components of the Old Ranch Country Club for cumulative traffic impact analysis related to congestion or automobile delay. Except with respect to projects specific to transportation improvements, the CEQA Guidelines specify that a project’s effects on automobile delay shall not constitute a significant environmental impact. As such, the updated Traffic Analysis does not change the findings of the Draft EIR, since LOS is not a significant impact under CEQA.

With respect to noise impacts (off-site traffic) related to this update in the modeling, there was a slight cumulative increase from existing conditions of 71.6 CNEL dBA to General Plan Buildout conditions of 73.2 CNEL dBA along a portion of Lampson Avenue. Without the additional development capacity at Old Ranch Country Club, the General Plan Buildout conditions with Project were 72.8 CNEL dBA. As a result, the General Plan Buildout with Project, including building of Old Ranch Country Club results in a cumulative increase of 0.4 CNEL dBA. However, the Project’s cumulative contribution to the General Plan Buildout

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condition, including with the inclusion of the additional development capacities at the Old Ranch Country Club is 0.2 dBA (see Segment #1, Table 8-9 in Attachment F to this Final EIR).

Because the cumulative incremental noise level threshold is 1.5 dBA, the Project’s cumulative contribution of 0.2 dBA is not a significant cumulatively considerable impact under CEQA.

Therefore, adjusting the cumulative impact modeling to include this additional development capacity at Old Ranch Country Club does not result in a new significant environmental impact resulting from the Project or a substantial increase in the severity of an impact requiring recirculation of the draft EIR. The Project’s Noise Impact Analysis has been updated accordingly and included as Attachment F to this Final EIR.

D-10 The commenter requests disclosure of any documentation of overflows onto Lampson Avenue due to clogging of the outlet pipe. Per field survey topographic findings and photographic evidence, existing stormwater runoff from the site ponds within the existing concrete channel and overflows on to Lampson Avenue near the southwest corner and through existing driveways along the property frontage. A Ponding Exhibit (Attachment E to this Final EIR) has been prepared for the existing conditions based on the tributary 100-year storm event which shows the water ponding based on the primary overflow elevation near the southwest corner of the site. Because water ponding currently exists even with the existing JFTB stormwater conveyance facilities, it can be reasonably assumed that the downstream, existing JFTB facilities are clogged.

D-11 The commenter requests clarification on the discrepancy related to the 25-year storm event street flows being contained below the top of curb along Lampson Avenue. A hydrologic analysis and street capacity analysis per Orange County Hydrology & Hydraulics Manuals were prepared for Lampson Avenue along the site frontage. Calculation results indicate that Lampson Avenue flooding does not occur along the Project site, but rather downstream at the sump condition near the Old Ranch Country Club. The hydrologic analysis and street capacity analysis for Lampson Avenue has been expanded downstream to determine the depth of flow (see Attachment E to this Final EIR). Two areas were analyzed; Section A-A is located near the southwest corner of the site and Section B-B at the existing low-point sump catch basin approximately 2,100 linear feet from the site near the Old Ranch Country Club. Both street capacity analysis indicate that the 100-year water surface elevation is held within the street and less than the existing top of curb elevations.

D-12 The commenter requests that the Project’s SWPPP be submitted to City of Seal Beach for concurrence, and that a separate dewatering plan be submitted to the City of Seal Beach for review and approval prior to the City of Los Alamitos issuing grading permits. The Project would comply with state requirements related to the submittal of a SWPPP. The SWPPP and Dewatering Plan will be made available as referenced to the City of Seal Beach, however these are State-reviewed documents that will be processed, approved and permitted by the State Water Resources Control Board (SWRCB) as appropriate. Both documents shall be approved by the SWRCB prior to issuance of grading permit by the City of Los Alamitos.

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D-13 The commenter requests that the Project’s Water Quality Management Plan (WQMP) require approval from the City of Seal Beach and the Project Applicant shall be responsible for monitoring, maintaining, and reporting to the City of Seal Beach. The Project’s Water Quality Management Plan will be reviewed and approved by the City of Los Alamitos and Seal Beach, as may be required. If required, a maintenance covenant/agreement will be executed by the property owner for monitoring, maintenance, and operation of all privately installed water quality facilities per City of Los Alamitos code requirements and to the satisfaction of the City of Seal Beach. It should be noted that City of Los Alamitos is ultimately the responsible agency for review/ approval of the Water Quality Management Plan per the County of Orange MS4 Permit requirements. Refer to Response to Comment D-8.

D-14 The commenter states that flooding issues along Lampson Avenue under existing conditions is not consistent with the listed level of significance before mitigation of “Less than Significant Impact.” The commenter requests clarification of the analysis under threshold c in Section 4.9, Hydrology and Water Quality, of the Draft EIR, and an explanation of the basis for the conclusion.

The Draft EIR documented the existing hydrological conditions in Section 4.9 of the Draft EIR. As stated, based on field observations from C&V, the existing concrete channel along the site’s southerly property line currently ponds back to the existing driveway and overflows onto Lampson Avenue. Based on the existing topography of the site, in the event the outlet pipe was to become clogged, the existing overflows from the property would flow onto Lampson Avenue at the low point at the southwest corner of the site (refer to Page 4.9-1 of the Draft EIR). As required by CEQA, in determining whether the Project’s impacts are significant, the Draft EIR evaluated the Project’s impacts compared to existing environmental conditions. The analysis provided under Threshold c demonstrates that the Project has been designed (under two stormwater drainage facility options) to detain peak runoff flows on-site to ensure that increased flow rates do not exceed the existing condition flow rates. As such, downstream facilities would not be hydrologically impacted by the proposed Project. Impacts would be less than significant and no mitigation is required (refer to Pages 4.9-18 to 4.9-19).

Refer to Master Response 2.1.4, Hydrology and Wastewater Infrastructure Analysis, related to flooding impacts. Thus, no further response is required.

D-15 The commenter states that the preferred route for emergency overflow onto Lampson Avenue has not been approved by the City of Seal Beach. Emergency overflow in the existing condition is based on field survey topographic elevations and photographic evidence when stormwater runoff that cannot discharge through the existing 18” storm drain pipe to existing JFTB facilities will overflow on to Lampson Avenue. This is a historic condition. Refer to Ponding Exhibit (Attachment E to this Final EIR) prepared for the existing condition identifying the inundation area during the 100-year storm event in the existing condition. As stated in Response to Comment D-4, an encroachment permit may be required to implement the

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preferred drainage route. However, there are no required agreements to allow for drainage overflow onto Lampson Avenue, as this is a historic, existing drainage condition. Lampson Avenue is considered a public right-of-way and can accept stormwater runoff from adjacent sites. The existing topography identifies that stormwater runoff in the historic condition overflows onto Lampson Avenue near the southwest corner of the site.

D-16 The commenter states that clogged pipes should not take place provided that proper WQMP monitoring and maintenance are in place and requests explanation of why this scenario is discussed. Page 4.9-17 of the Draft EIR states that in the event the stormwater pump fails or the outlet pipe becomes clogged, the emergency overflow for the site will flow onto Lampson Avenue matching historical drainage patterns. Although proper maintenance would ensure that clogged pipes should not take place, this has occurred historically as observed and documented in the existing conditions (refer to Page 4.9-1 of the Draft EIR).

Appropriate maintenance and frequency information is part of the Project’s Water Quality Management Plan and recorded maintenance covenant/agreement as required per the County of Orange. However, in the remote event that proposed water quality and/or drainage facilities fail, become clogged, and/or are not maintained properly, emergency overflow through the Project site is provided and incorporated into the grading/drainage design. This ensures that the proposed building finish floor elevations are set at minimum 1’ higher than the 100-year water surface elevation for the tributary area and a safe vehicular path of travel is being maintained for emergency vehicles and proper maneuvering throughout the site. As part of the County of Orange’s MS4 Permit requirements, the responsible reviewing agency, such as the City of Los Alamitos is obligated to conduct yearly inspections of installed water quality facilities and report to the County.

D-17 The commenter states that the Draft EIR should analyze all potential drainage resulting from the site and disclose any agreements where Seal Beach accepts Los Alamitos stormwater conveyance of any volume. Refer to Response to Comment D-14. The Draft EIR demonstrates that the Project has been designed (under two stormwater drainage facility options) to detain peak runoff flows on-site to ensure that increased flow rates do not exceed the existing condition flow rates. As such, downstream facilities would not be hydrologically impacted by the proposed Project. Impacts would be less than significant and no mitigation is required (refer to Pages 4.9-18 to 4.9-19).

The existing site generally flows in a north to south direction into an existing westerly flowing concrete channel along the site’s southerly property line. The westerly flowing channel is collected via an offsite 18-inch corrugated metal pipe (CMP) that flows under the offsite driveway to Arbor Park and discharges into an offsite earthen channel on the west side of the driveway. Runoff flows within this earthen channel are then collected by an existing 24-inch CMP that flows westerly, discharges into a westerly flowing earthen channel within the JFTB, and then drains to the Old Ranch Country Club to the south. Runoff is ultimately conveyed

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downstream into the San Gabriel River. There is currently not an agreement in place that Seal Beach accept Los Alamitos stormwater conveyance of any volume. Additionally, there are no required agreements to allow for drainage overflow onto Lampson Avenue, as this is considered a historic, existing drainage condition. Lampson Avenue is considered a public right-of-way, therefore can accept stormwater runoff from adjacent sites. Based on the existing topography, stormwater runoff in the existing historic condition overflows onto Lampson Avenue near the southwest corner of the site.

D-18 The commenter states that the Alternate Storm Drain Facilities scenario would be contingent upon approval from the City of Seal Beach. Refer to Response to Comment D-6 for the revised language in the Draft EIR related to approval from City of Seal Beach. The Project Applicant will be required to seek approvals from Seal Beach, as applicable. As stated in Response to Comment D-4, an encroachment permit may be required to implement the preferred drainage route. There are no required agreements to allow for drainage overflow onto Lampson Avenue, as this is a historic, existing drainage condition. Lampson Avenue is considered a public rightof-way and can accept stormwater runoff from adjacent sites.

D-19 The commenter requests that the Draft EIR substantiate that drainage to the north is not allowable for use as detention, Bolsa Chica Channel’s capacity, and the conclusion of the inability to construct an underground storm drain facility within the Lampson Avenue rightof-way.

Option #3 to outlet runoff to Arbor Park/ JFTB north of the site was evaluated, however based on topography and existing surface drainage facilities, stormwater runoff from Arbor Park drains south to the same downstream discharge location near the southwest corner of the site and Lampson Avenue. If JFTB does not allow for discharge at the southwest corner of the site, then JFTB is unlikely to allow a northerly discharge offsite. In addition, the existing site does not flow northerly to the Arbor Park/ JFTB area, as the site drains in the southwesterly direction. Therefore, directing stormwater runoff to the north would change the historic drainage pattern which can potentially cause downstream flooding because it would add additional flows to this area that do not currently occur.

Option #4 to outlet to the Golf Course, east of the site which conveys stormwater runoff to the Bolsa Chica Channel was evaluated, however similar to Option #3, the golf course is considered JFTB property, therefore requires JFTB approval for discharge and the site is not tributary to these existing facilities. Regardless of whether the Bolsa Chica Channel has capacity to accept stormwater runoff from the site, discharging to the Golf Course and subsequent Bolsa Chica Channel would change the historic drainage pattern which can potentially cause downstream flooding because it would add additional flows to this area that do not currently occur.

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Option #5 to construct a public storm drain system within Lampson Avenue that drains east to the Bolsa Chica Channel was evaluated and as with Option #4 the site does not historically drain to this facility, therefore a direct connection to the channel would change the historic drainage pattern which may potentially cause downstream flooding, since it would add additional flows to an area that do not currently occur within the channel or site. In addition, there are existing public facilities such as gas, water, sewer mains located within Lampson Avenue which will prevent a feasible gravity fed storm drain system from being installed.

D-20 The commenter requests disclosure of what threshold was used to determine downstream hydrological impacts and how the determination of no impact was arrived at. Per methods identified within the Orange County Hydrology Manual, the proposed increased peak flow/volume generated by the Project will be contained with an upstream onsite detention and pump system with a controlled outflow to match the existing historic overflow condition; therefore, no downstream impact is anticipated. The downstream junction structure will be equipped with a Connector Pipe Screen (CPS) device for full trash capture of the 1-yr, 1-hr peak flow rate sized for the entire site to ensure trash collection prior to overflow.

D-21 The commenter inquires whether the northerly 10-foot proposed dedication was included in the hydrology calculation and, if not, where will it be included. Additionally, the commenter inquires about the roles and responsibilities of the 10-foot dedication. The Project’s Preliminary Hydrology Study (Attachment E of this Final EIR) has been revised providing additional information regarding the 10’ wide dedication area along the northerly property line.

To summarize those revisions, the 10’ wide dedication area is outside the proposed residential development and will not be tributary to the Project site’s proposed storm drain system.

Existing conditions show that this area of the site currently drains in the northerly direction.

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EIR.

The Project Applicant proposes to dedicate or grant an easement for the northern 10 feet of property abutting Arbor Park and Arbor Dog Park to the City of Los Alamitos, or other entity, with authority over the two parks.

D-22 The commenter states that the provided hydrograph calculations from the Project’s Preliminary Hydrology Report (Technical Appendix I1 of the Draft EIR) represent the unit hydrograph only and refers to the example problem in the Orange County Hydrology Manual to complete the small-area runoff hydrograph calculation.

Pursuant to the commenter’s request, the Small Unit Hydrograph and detention routing calculations for the onsite proposed condition have been updated as part of the revised Preliminary Hydrology Report (Attachment E of this Final EIR) which utilizes the requirements set forth in Orange County Hydrology Manual and confirms the required upstream detention and outflow mitigation discharge rate compared to the existing condition.

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Existing historic drainage patterns will be maintained without causing the potential increase of tributary flooding; therefore, impacts would be less than significant.

D-23 The commenter states that the discussion in Section 4.10, Land Use and Planning, of the Draft EIR, should be expanded to include the City of Seal Beach within the regulatory framework, given the number of discretionary approvals from Seal Beach that are required to implement the Project. The City acknowledges that the Project would need approval from the City of Seal Beach for certain off-site infrastructure improvements and agreements. Pursuant to the Commenter’s request, Page 4.10-33 of the Draft EIR has been revised as shown below and in Section 5.0 of this Final EIR.

4. City of Seal Beach General Plan
Table 4.10-3, Seal Beach General Plan Consistency Analysis, provides an analysis of the Project’s consistency with all applicable General Plan goals and policies that were adopted for the purpose of avoiding or mitigating an environmental effect. As shown in Table 4.10-3, the Project would not conflict with any of the applicable General Plan goals and policies.

Accordingly, the Project would have a less-than-significant impact with respect to a conflict with the City of Los Alamitos General Plan and mitigation is not required.

Table 4.10-3 Seal Beach General Plan Consistency Analysis General Plan Policy Consistency
Circulation Element
Objective: Provide a citywide system of safe, efficient, and attractive bicycle and pedestrian routes for commuter, school, and recreational use.

Policy: Maintain existing pedestrian facilities
and require new development to provide
pedestrian walkways between developments,
schools, and public facilities.

No Conflict. The Project would promote future
residents of the Project to walk, bike, or ride the
bus to and from developments, schools, and
public facilities. Project frontage improvements
such as sidewalk improvements, the existing
bike lanes on Lampson Avenue adjacent to the
Project site, and bike storage would promote
residents and students to utilize these facilities.

Therefore, the Project would not conflict with
this policy.

Growth Management Element

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General Plan Policy Consistency
Goal 3: Cooperate with Neighboring Jurisdictions and the County of Orange and County of Los Angeles to Achieve Reduction in Regional Traffic Congestion.

Policy 3.1 - The City shall participate in interjurisdictional planning forums within its established growth management areas as adopted
by the Regional Advisory Planning Council and
will continue to participate in forums with
neighboring or affected jurisdictions to address
transportation or other planning issues.

No Conflict. The City of Seal Beach is a
responsible agency for the Project. Table 3-6,
Project-Related Approval/Permits, lists all
approvals and decisions required by the City of
Seal Beach for the Project. Additionally, the City
of Los Alamitos and City of Seal Beach have
been in coordination throughout the planning
process for this Project including the preparation
of the Traffic Analysis. Therefore, the Project
would not conflict with this policy.

D-24 The commenter states that Arbor Dog Park, Arbor Park Fields, and Heather Park which are currently operated and maintained by Seal Beach should be included in Table 4.14-1, Existing Parks and Recreation Facilities, of the Draft EIR. The purpose of Table 4.14-1 is to identify parks and recreational facilities that are located within the City of Los Alamitos and its sphere of influence and as presented in the City’s General Plan. As such, Arbor Dog Park and Arbor Park Fields were identified in Table 4.14-1 of the Draft EIR (refer to Page 4.14-2 of the Draft EIR), because they are located in Los Alamitos, while Heather Park was not included in this table. Details on the City of Seal Beach Park system and parks closest to the Project site operated by Seal Beach, including Arbor Park, Arbor Dog Park, and Heather Park, are described on Pages 4.14-4 through 4.14-6 of the Draft EIR. Accordingly, no corrections or revisions to the Draft EIR are required.

D-25 The commenter states that the closest parks to the Project are owned and operated by the City of Seal Beach and that while the Draft EIR includes a discussion of the Project applicant paying in-lieu fees to the City of Los Alamitos, it does not address impact on the deterioration and maintenance on Seal Beach. Section 4.14, Recreation, of the Draft EIR analyzes the Project’s impact on existing neighborhood and regional parks, including those closest to the Project site.

The Draft EIR concluded that implementation of the Project would not result in significant impacts related to the physical deterioration of recreational facilities and impacts would be less than significant. (refer to Pages 4.14-9 and 4.14-10).

D-26 The commenter states that the Arbor Park usage assumption is understated in the Park Impact Analysis (Technical Appendix M of the Draft EIR) compared to what was observed and documented in the Arbor Park Parking Study and Layout (Technical Appendix Q of the Draft EIR).

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A direct comparison of the two reports mentioned by the commenter cannot be made because each report was prepared for a separate and distinct purpose and each analysis was based on conservative assumptions for the issue being addressed (i.e., impacts to parks and impacts of parking to AYSO events, respectively). The purpose of the Park Impact Analysis (Technical Appendix M) is to evaluate the potential impact of future Project residents’ regular use of parks in close proximity to the Project site, including Arbor Park, Arbor Dog Park, and Heather Park.

On the other hand, the purpose of the Arbor Park Parking Study and Layout (Technical Appendix Q) is to specifically address parking needs for AYSO 150 events and observed peak parking demand during AYSO events with all nine soccer fields in use concurrently.

Nevertheless, the Park Impact Analysis (Technical Appendix M) acknowledges the AYSO events. Specifically, Pages 2 and 3 of Technical Appendix M states:

Arbor Park is primarily a permitted park, which means
groups/organizations/individuals must apply to the City of Seal Beach for approval for requested dates and times to utilize the park. Applicants provide information including, but not limited to, the type of activity and must follow the rules and regulations set forth by the City of Seal Beach. Arbor Park is primarily permitted to AYSO Region 159, serving the Los Alamitos, Rossmoor, and Seal Beach area. AYSO Region 159 was permitted to use Arbor Park for 1,052 hours in each calendar year 2022 and 2023. No other groups received permits. Typically, Arbor Park is permitted on Saturdays and weekday afternoons for AYSO Region 159 games and practices. Arbor Park’s permitted use is comparable to other similar active parks in the City of Seal Beach system.

Although Arbor Park is primarily a permitted park, the park is available and used by others outside of permitted times. Residents participate in allowable nonpermitted/passive uses such as informal/family sports activities (i.e., soccer, ultimate frisbee, playing catch with the football/baseball) and walking.

In accordance with “Recreation Areas, Their Design and Equipment,” a carrying capacity (referring to the number of visitors that can be accommodated in a park without unacceptable impacts to the quality of the visitor experience) can be calculated for a park utilizing the amenities, such as playgrounds, baseball fields, and open lawn areas present in the park. In general, a carrying capacity is not calculated for a community park that an agency can monitor for usage through a permitting process. However, for the purpose of this analysis, during non-permitted times, it is estimated at full capacity that 270 visitors can be accommodated at Arbor Park. Based upon City of Seal Beach staff monitoring and observations, Arbor Park is currently not at full capacity usage.

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Therefore, the Park Impact Analysis (Technical Appendix M) identifies that Arbor Park is a permitted park and also identifies the number of AYSO games and practices in the 2022 and 2023 calendar years. The analysis calculates carrying capacity in accordance with “Recreation Areas, Their Design and Equipment,”3 prepared for the National Recreation Association, and therefore, the analysis utilizes an appropriate industry standard and does not understate the usage of Arbor Park. Accordingly, no corrections or revisions to the Draft EIR are required.

D-27 The commenter states that as the Project takes access off Lampson Avenue, the basis for determining significance should be based on Seal Beach’s guidelines. Refer to Master Response 2.1.1, Transportation and Traffic Congestion, this traffic study has been prepared in accordance with the City of Los Alamitos’ requirements (as the Lead Agency for the Project) and the City of Seal Beach’s Transportation Analysis Guidelines (June 2020, referred to as City Guidelines) as the study area intersections are located within the City of Seal Beach. The recommendations for off-site roadway improvements within the jurisdiction of the City of Seal Beach were made in compliance with Seal Beach Guidelines. As stated previously, the CEQA Guidelines specify that a project’s effects on automobile delay shall not constitute a significant environmental impact.

D-28 The commenter requests clarification on how the fair share requirements would be used to benefit the Project’s site’s surrounding roadway network within the City of Seal Beach. As stated in the Traffic Analysis (Attachment G of this Final EIR), transportation improvements are funded through a combination of improvements constructed by the Project or fair share contributions. When off-site improvements are identified with a minor share of responsibility assigned to proposed development, the approving jurisdiction may elect to collect a fair share contribution or require the development to construct improvements. The Project’s fair share contribution to Seal Beach Boulevard and Lampson Avenue is 3.8% in the AM peak hour and

5.1% in the PM peak hour (see Table 7-1 of Attachment G of this Final EIR). As stated previously, the CEQA Guidelines specify that a project’s effects on automobile delay shall not constitute a significant environmental impact. This comment does not raise any issues concerning the environmental analysis provided in the Draft EIR and thus no further response is required.

D-29 The commenter states that site access modifications to the Project site are within Seal Beach jurisdiction and improvements shall require approval and compliance with Seal Beach. The City acknowledges and agrees with the commenter. Table 3-6, Project-Related Approvals/Permits, of the Draft EIR acknowledges that the Project would require an encroachment permit for infrastructure improvements within the Lampson Avenue right-ofway. 3 “Recreation Areas, Their Design and Equipment” – second edition, George D. Butler, The Ronald Press Company, New York, copyright 1958, by National Recreation Association Incorporated, pg. 96

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D-30 The commenter requests clarification on where the intended off-site parking is with respect to AYSO events and whether it would impact Seal Beach’s parking supply.

Parking shortfalls relative to parking demand during AYSO Saturday games are not considered a significant environmental impact under CEQA. As discussed in the Draft EIR, there is a potential for inadequate parking during AYSO Saturday games as it currently operates (see Pages 4.2-25 and 4.2-26). If there is inadequate parking, visitors to the AYSO games would have the option of dropping off players or parking off-site. It is expected that any off-site parking would occur in available parking spaces and within walking distance (0.25 to 0.5 mile radius) of Arbor Park.

D-31 The commenter states that construction traffic impacts shall be confirmed with Seal Beach and an approval permit from Seal Beach is required. The City acknowledges that the Project would require an encroachment permit for infrastructure improvements, including construction, within the Lampson Avenue right-of-way. Refer to Response to Comment D-29.

D-32 The commenter requests for clarification on whether a traffic signal would be provided at the main Project site access. As evaluated and determined in the Project’s Traffic Analysis (see Attachment G of this Final EIR), the primary neighborhood entry is not anticipated to meet a peak hour or planning level (daily volume) based traffic signal warrants. Therefore, the Project does not propose installation of a traffic signal. Refer to Master Response 2.1.2, Roadway Safety on Lampson Avenue.

D-33 The commenter requests that Traffic Analysis indicate that the queuing analysis conducted for the site driveway was for the unsignalized case. As provided in the updated Traffic Analysis (Attachment G of this Final EIR), both Project driveways on Lampson Avenue were evaluated assuming cross-street stop-controlled intersections for the purposes of the queuing assessment.

D-34 The comment requests that the title in Section 3.3 of the Project’s Traffic Analysis (Technical Appendix N1 of the Draft EIR) to be revised to the City of Seal Beach. Pursuant to the commenter’s request, the Project’s Traffic Analysis has been updated accordingly and included as Attachment G to this Final EIR.

D-35 The commenter requests Exhibit 3-3 of the Traffic Analysis to show the location of the Project site for context. Pursuant to the commenter’s request, the Project’s Traffic Analysis has been updated accordingly and included as Attachment G to this Final EIR.

D-36 The commenter requests that Exhibit 3-4 of the Traffic Analysis show city boundaries to indicate Los Alamitos and Seal Beach. Pursuant to the commenter’s request, the Project’s Traffic Analysis has been updated accordingly and included as Attachment G to this Final EIR.

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D-37 The commenter requests Exhibit 3-5 of the Traffic Analysis to show the location of the Project site for context. Pursuant to the commenter’s request, the Project’s Traffic Analysis has been updated accordingly and included as Attachment G to this Final EIR.

D-38 The commenter requests feasibility documentation of how the recommended mitigation measure can be achieved within the geometric configuration without sacrificing westbound left-turn storage.

Pursuant to the commenter’s request, the Traffic Analysis has been revised to include a queuing analysis to demonstrate the feasibility of the recommended improvement at Seal Beach Boulevard and Lampson Avenue. Additionally, a queuing analysis was performed at the intersection of Valley View Street and Lampson Avenue. The updated Traffic Analysis is included in Attachment G to this Final EIR. The queuing analysis was conducted for General Plan Buildout Without and With Project traffic conditions since these analysis scenarios have the highest traffic volumes and would result in the most conservative analysis (see Table 6-4 of Attachment G) As shown, there are no queuing issues in the turn lanes anticipated at Seal Beach Boulevard and Lampson Avenue. The intersection of Valley View Street and Lampson Avenue is anticipated to have the same queuing issues under both Without and With Project traffic conditions where the addition of Project traffic would not add more than one vehicle length to any of the deficient turning movements (approximately 25-feet). Therefore, the recommended improvement at Seal Beach Boulevard and Lampson Avenue is feasible and the Project’s fair share contribution would be 5.1% (see Table 7-1 of the Traffic Analysis in Attachment G). As stated previously, the CEQA Guidelines specify that a project’s effects on automobile delay shall not constitute a significant environmental impact; therefore, the recommended improvement is not mitigation measure.

D-39 The commenter states the City of Seal Beach Traffic Impact Study Guidelines state that intersections or roadway links with more than five or more reported accidents within the most recent 12-month period within significant influence of the project shall be analyzed and will require mitigation. Further, the commenter states that no crash analysis was provided in the Draft EIR. Refer to Master Response 2.1.2, Roadway Safety on Lampson Avenue, and Attachment H, Safety Evaluation. Thus, no further response is required.

D-40 The commenter states that no link analysis was provided pursuant to the City of Seal Beach Traffic Impact Study Guidelines. As discussed previously, transportation impacts under CEQA is now based on VMT rather than automobile delay- LOS (traffic congestion). However, the LOS analysis was prepared pursuant to the City of Los Alamitos and Seal Beach Transportation Guidelines.

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The following roadway segments, in boldface, were evaluated. since the Project would represent 1% or more of the total direction volume under General Plan Buildout traffic conditions:

The roadway segment analysis indicates that all study area roadway segments would operate at an acceptable LOS under all analysis scenarios. As such, no roadway segment widening is recommended.

D-41 The commenter requests clarification on how the reduction in parking from the Los Alamitos Luxury Apartment project impacts surrounding on/off street parking.

The discussion of the Los Alamitos Luxury Apartment project in the Parking Analysis (Technical Appendix P of the Draft EIR) is presented to demonstrate a precedent for a reduction in parking standards in the City of Los Alamitos, which is a jurisdiction that has a high parking standard in comparison to neighboring Seal Beach parking requirements. The analysis demonstrates that the Project would provide adequate parking for future residents and visitors of the Project and therefore, would not require any off-site parking. Refer to Response to Comment D-7 and Master Response 2.1.3, Parking, for a discussion of parking impacts.

D-42 The commenter inquires whether there will be overflow provisions during AYSO peak parking demand. The Arbor Park Parking Study and Layout (Technical Appendix Q of the Draft EIR) considers options for parking overflow that would be voluntarily provided by the Project if there is a parking shortage. For non-CEQA informational purposes, Walker Consulting found that any parking shortages at AYSO events could be eliminated in their entirety if AYSO spread out its soccer events and eliminated the large number of overlapping games. Refer to Response to Comment D-30 and Master Response 2.1.3, Parking, for a discussion of parking impacts. Thus, no further response is required.

D-43 The commenter inquires about the Caltrans park-and-ride and whether there are requirements for a substitute location. The park-and-ride that previously occupied the Project site has not # Roadway Segment Limits Project 2045 WP Project %
1 Seal Beach Bl. North of Lampson Av. 308 48,860 0.6%
2 Seal Beach Bl. South of Lampson Av. 538 47,018 1.1%
3 Lampson Av. Seal Beach Bl. to Old Ranch Plaza 846 23,220 3.6% 4 Lampson Av. Old Ranch Plaza to Basswood St. 846 20,854 4.1% 5 Lampson Av. Basswood St. to Candleberry Av. 846 16,825 5.0% 6 Lampson Av. Candleberry Av. to Heather St. 846 15,012 5.6% 7 Lampson Av. Heather St. to Rose St. 846 15,287 5.5%
8 Lampson Av. Rose St. to Tulip St. 692 15,686 4.4%
9 Lampson Av. Tulip St. to Valley View St. 692 16,878 4.1% 10 Lampson Av. East of Valley View St. 230 12,915 1.8%
11 Valley View St. North of Lampson Av. 154 50,882 0.3% 12 Valley View St. North of Lampson Av. 308 49,969 0.6%

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been in operation for the past 18 months and when in operation had limited usage. There are no requirements or proposal to provide a substitute park-and-ride location.

D-44 The commenter requests a condition of approval requirement to work with the American Youth Soccer Organization (AYSO) and Seal Beach to address the remaining parking shortfall.

Parking shortfalls relative to parking demand during AYSO Saturday games are not considered a significant environmental impact under CEQA; therefore, the City has no legal authority under CEQA to impose a condition to this effect. However, the Project Applicant has agreed to coordinate with the City of Seal Beach and AYSO to help coordinate usage of Arbor Park, as needed.

D-45 The commenter requests that all mitigation measures identified in this letter be incorporated into a Mitigation Monitoring and Reporting Program (MMRP) and that all project design features that avoid or reduce impacts and mitigation measures also be incorporated into the Project’s conditions of approval. Additionally, the commenter states the City of Seal Beach reserves the right to provide comments on the MMRP following its release. The City acknowledges that all mitigation measures identified in the Draft EIR will be incorporated into the MMRP and that project design features that reduce environmental impacts will be incorporated as conditions of approval. The MMRP will identify all Project Design Features and Mitigation Measures incorporated into the Project and is incorporated as Attachment O of this Final EIR. Pursuant to CEQA Guidelines Section 15088, the Final EIR will be distributed to the City of Seal Beach a minimum of 10-days prior to the City’s hearing on the Project.

D-46 The commenter states that the Draft EIR should disclose that the proposed water infrastructure is not in place and is contingent upon receiving a Seal Beach City Council-approved agreement with the proposed water purveyor. This comment is duplicative of Comment D-4; refer to Response to Comment D-4.

D-47 The commenter states that the Draft EIR should disclose that Seal Beach sanitary sewer service is contingent upon receiving a Seal Beach City Council-approved agreement for service outside the Seal Beach service area boundaries and discussion of alternatives should be provided should the agreement not be approved. This comment is duplicative of Comment D-5; refer to Response to Comment D-5.

D-48 The commenter states that the Draft EIR should disclose the proposed alternative drains into Seal Beach right-of-way, which is contingent upon approval from the City of Seal Beach. This comment is duplicative of Comment D-6; refer to Response to Comment D-6.

D-49 The commenter requests confirmation of whether Golden State Water Company (GSWC) will be expanding water facilities to serve the Project site under a separate environmental assessment. GSWC has indicated that it has adequate water supply to serve the Project site (see Attachment K, Will-Serve Letters). The expansion of water infrastructure is identified as part

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of the Project and analyzed in the Draft EIR. As described in Section 3.0, Project Description, of the Draft EIR, GSWC would provide water service to the Project. Domestic water lines would be provided as shown in Figure 3-23, Utility Plan, of the Draft EIR, and include a 1,200 feet watermain extension between the eastern driveway and the existing GSWC watermain at the intersection of Lunar and Lampson. The Draft EIR analyzed impacts associated with the connection to GSWC infrastructure and the extension of the 1,200 foot off-site watermain.

Potential impacts related to installation of the off-site water main are addressed under construction-related impacts throughout the Draft EIR, and no significant impacts have been identified. Therefore, a separate environmental assessment is not required or anticipated to provide water service to the Project.

D-50 The commenter makes concluding remarks and the City acknowledges Iris Lee as the contact person for the City of Seal Beach. Thus, no further response is required.

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Comment Letter E

SENT VIA ELECTRONIC MAIL
June 5, 2024
Tom Oliver
Associate Planner
City of Los Alamitos
3191 Katella Avenue
Los Alamitos, CA 90720
[email protected]
RE: DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE 4665 LAMPSON RESIDENTIAL PROJECT DATED APRIL 24, 2024, STATE CLEARINGHOUSE NUMBER 2022090476
Dear Tom Oliver,
The Department of Toxic Substances Control (DTSC) received a Draft Environmental Impact Report (DEIR) for the 4665 Lampson Residential Project (Project). The Project would demolish the existing office building and surface parking lot on the 12.3-acre property and redevelop the Project site with 246 residential units consisting of a variety of different product types. These housing types include 55 single family detached homes, 114 townhomes, and 77 for rent affordable multi-family apartment homes. After reviewing the project, DTSC recommends and requests consideration of the following comments:

1. Based on the Limited Phase II Environmental Site Assessment (ESA), there was no evidence of a significant release of potential chemicals of E-2 E-1

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concern to the subsurface in the area investigated, which included in the diesel above ground storage tank (AST), elevator equipment room, and parking lot. Although low levels of total petroleum hydrocarbons (TPHd), lead and select organochlorine pesticides (OCPs) were detected in Site soils, the concentrations were well below residential screening levels, and thus, are de minimis in nature and do not warrant further investigation or mitigation.

Also, the Phase II ESA states: “Although the detected concentrations of arsenic found at the Site exceed the residential screening level, no levels are less than the DTSC upper bound background concentration of 12 mg/kg. Therefore, the on-site detections of arsenic are de minimis in nature and do not warrant further investigation or mitigation. Based on the results of the assessment activities detailed herein, the potential chemicals of concern detected in soil in the areas assessed (e.g., diesel AST, elevator equipment room, parking lot release area, and Site wide historical agricultural use) are not indicative of a significant subsurface chemical release has occurred. The detected concentrations found during this investigation are considered to be de minimis in nature for the proposed residential redevelopment, and it is EFI Global’s opinion that no further assessment is warranted at this time with respect to the RECs (recognized environmental conditions) identified.”
Since potential chemicals of concerns were found in the Phase II ESA and the detected concentrations of arsenic found at the site exceed the residential screening level and remain in excess of DTSC's upper bound background concentration of 12 mg/kg, DTSC recommends that all constituent concentrations meet screening levels in accordance with DTSC's Preliminary Endangerment Assessment (PEA) Guidance Manual.

If the constituent concentrations do not meet screening levels in accordance with DTSC guidance, the following comments are also recommended:

E-2
(CONT.)

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2. The City of Los Alamitos enter into DTSC’s Standard Voluntary Agreement (SVA) program or seek oversight with your Certified Local Agency - Orange County Health Care Agency - so a proper evaluation of the Project is completed. If entering into an SVA with DTSC, the FLUXX portal link is provided and the page also has a link to the Fluxx User Guide that can help you navigate the system. You will need to create a new profile and once in the system, click “Start a Request for Lead Agency Oversight Application.” DTSC recommends that once the SVA is signed, a Preliminary Endangerment Assessment Report (PEA Report) be submitted for DTSC review. The PEA Report shall summarize all existing data and provide an evaluation of the possible risk to current and future users of the site. If you have any questions about the application portal, please contact the DTSC Brownfield Coordinator Gregory Shaffer or contact the Application Portal Inbox.

3. If buildings or other structures are to be demolished on any project sites included in the proposed project, surveys should be conducted for the presence of lead-based paints or products, mercury, asbestos containing materials, and polychlorinated biphenyl caulk. Removal, demolition, and disposal of any of the above-mentioned chemicals should be conducted in compliance with California environmental regulations and policies. In addition, sampling near current and/or former buildings should be conducted in accordance with DTSC’s Preliminary Endagngerment Assessment (PEA) Guidance Manual.

4. All imported soil and fill material should be tested to ensure any contaminants of concern are within DTSC’s and U.S. Environmental Protection Agency (USEPA) Regional Screen Levels (RSLs) for the intended land use. To minimize the possibility of introducing contaminated soil and fill material there should be documentation of the origins of the soil or fill material and, if applicable, sampling be conducted to ensure that the imported soil and fill material meets screening levels outlined in the PEA for the intended land use.

E-5
E-3
E-4

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The soil sampling should include analysis based on the source of the fill and knowledge of the prior land use. Additional information can be found by visiting DTSC’s Human and Ecological Risk Office (HERO) webpage.

DTSC appreciates the opportunity to comment on the DEIR for the Project. Thank you for your assistance in protecting California’s people and environment from the harmful effects of toxic substances. If you have any questions or would like any clarification on DTSC’s comments, please respond to this letter or via email for additional guidance.

Sincerely,
Tamara Purvis
Associate Environmental Planner
HWMP-Permitting Division – CEQA Unit
Department of Toxic Substances Control
[email protected]
E-5
(CONT.)
E-6

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cc: (via email)
Governor’s Office of Planning and
Research State Clearinghouse
[email protected]
Dave Kereazis
Associate Environmental Planner
HWMP - Permitting Division – CEQA Unit
Department of Toxic Substances Control
[email protected]
Scott Wiley
Associate Governmental Program Analyst
HWMP - Permitting Division – CEQA Unit
Department of Toxic Substances Control
[email protected]

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Responses to Comment E
Department of Toxic Substances Control (DTSC), dated June 5, 2024.

E-1 The commenter provides introductory remarks and summarizes the Project. Responses to comments are provided in responses to Comments E-1 to E-6, below; thus, no further response is required.

E-2 The commenter summarizes results from the Phase II Environmental Site Assessment (ESA; Technical Appendix H2 of the Draft EIR), which stated that there was no evidence of a significant release of potential chemicals of concern to the subsurface in the area investigated.

Although there were low levels of total petroleum hydrocarbon, lead and select organochlorine pesticides detected in the soil, the concentrations were well below residential screening levels, and thus do not warrant further investigation. The commenter recommends that all constituent concentrations meet screening levels in accordance with DTSC's Preliminary Endangerment Assessment (PEA) Guidance Manual since the detected arsenic remains in excess of DTSC's upper bound background concentration of 12 mg/kg.

As to the comment regarding arsenic concentrations, this comment references text in the original Phase II ESA that included a typographical error. The Phase II ESA (see Section 5.0 and Attachment C1 to this Final EIR) has been updated to correct this typographical error and to more accurately reflect the fact that the detected arsenic concentrations found at the Project site are all below the upper bound concentration of 12 mg/kg, and thus, they are trace or background concentrations that do not warrant further investigation or mitigation. The corrected Phase II ESA now reads: “Although the detected concentrations of arsenic found at the site exceed the residential screening level, all levels are less than the DTSC upper bound background concentration of 12 mg/kg.”
E-3 The commenter provides information on procedures related to DTSC’s Standard Voluntary Agreement (SVA) program and PEA Report. Refer to Response to Comment E-2 related to the constituent concentrations meeting screening levels in accordance with DTSC guidance. Due to the change made in the Phase II ESA (see Section 5.0 and Attachment C1 to this Final EIR), all constituent concentrations are lower than the screening levels. As such, the commenter’s recommendation to enter into DTSC’s Standard Voluntary Agreement program or seek oversight with the Certified Local Agency – Orange County Health Care Agency is not required.

E-4 The commenter states that lead-based paints (LBP) or products, mercury, asbestos containing materials (ACM), and polychlorinated biphenyl (PCB) caulk surveys should be conducted if there are buildings or structures that will be demolished. Additionally, removal, demolition, and disposal should be conducted in compliance with California environmental regulations and policies. As discussed in Section 4.8, Hazards and Hazardous Materials, of the Draft EIR, the use of asbestos-containing materials (ACM, a known carcinogen) and lead-based paint (LBP)

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(a known toxic), both of which are considered hazardous materials, was a common building construction method prior to 1978 and may be present in the existing building. All proposed demolition activities would be required to comply with all applicable federal, State, and local hazardous materials regulation, which includes mandatory provisions for the safe removal, transport, and disposal of PCBs, ACMs and LBP. Additionally, the Project is required to comply with South Coast AQMD Rule 1403 (Asbestos Emissions) and Title 17 of the CCR, Division 1, Chapter 8: Accreditation, Certification, and Work Practices for Lead-Based Paint and Lead Hazards applies. Compliance with the above regulatory requirements would ensure that removal of ACMs or LBPs would not result in a significant hazard to the public or the environment through routine transport, use, or disposal of hazardous materials, and impacts would be less than significant (refer to Page 4.8-16 of the Draft EIR).

Moreover, EFI prepared a Phase II ESA for the Project site dated September 22, 2022 based on a geological survey and soil sampling conducted on August 16, 2022. Select soil samples were collected and analyzed for Total Petroleum Hydrocarbons (TPH) as gasoline (TPHg), TPH as diesel (TPHd), TPH as oil (TPHo), volatile organic compounds (VOCs), PCBs, organochlorine pesticides (OCPs), arsenic, and lead (Pb). Analytical results for PCBs indicated concentrations were not detected above the laboratory reporting limits in any of the soil samples analyzed (refer to Page 4.8-5 of the Draft EIR). However, caulk containing PCBs were used in buildings in the 1950s through the 1970s and may be present in the existing building.

Therefore, the Project would be required to comply with all applicable federal, State, and local hazardous materials regulation, which includes mandatory provisions for the safe removal, transport, and disposal of PCBs including Title 40, Code of Federal Regulations, Part 761.

There is also a potential for mercury containing products at the existing buildings. When a mercury-containing product breaks and the mercury is released, the exposed mercury can evaporate and become an invisible, odorless toxic vapor. Mercury-containing products exhibit hazardous characteristics as described in the California Code of Regulations, Title 22, chapter 11 and are classified as a type of hazardous waste called “universal waste.” Universal wastes are hazardous wastes that pose a lower immediate risk to people and the environment when handled properly. Due to this lower risk, universal wastes can be handled and transported under more relaxed rules compared to other hazardous wastes.4 The Project would be required to comply with all applicable federal, State, and local hazardous materials regulations including California Health and Safety Code Section 25214.8.16 to prevent mercury releases. 4 https://dtsc.ca.gov/toxics-in-products/mercury-waste/

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