Los Alamitos City Council
November 18, 2024

“ATTACHMENT X”

4665 Lampson Avenue
Facts and Findings and Statement of Overriding Considerations Page 61

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 detention facilities will be designed to detain 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. (DEIR, p. 4.9-19)
Alternate Storm 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 conveyed to offsite storm drain facilities. DEIR Figure

4.9-5, Proposed Alternate Conditions Hydrology Map illustrates the post-development 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 an 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 25-year storm event in Lampson Avenue. At that point, peak flows would be detained onsite. Once the flows are no longer above the pre-development 25-year storm event in Lampson Avenue, onsite flows would continue pumping to Lampson Avenue normally. (DEIR, p. 4.9-19)
Under the Alternate Storm Drain plan, stormwater will need to be detained and minimized 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 halfstreet per the OC Local Drainage Manual. Approximately 33,106 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. (DEIR, p.

4.9-19, as revised in Section 4.0 of the FEIR)

“ATTACHMENT X”

4665 Lampson Avenue
Facts and Findings and Statement of Overriding Considerations Page 62

Storm Drain Facilities Considered but Determined Infeasible As part of the Project’s hydrology analysis, the following drainage designs with different outlet locations were reviewed but found to be infeasible:

1. Construct storm drain pipe under Lampson Avenue to west: The proposed installation of approximately 2,400 feet of 30-inch underground gravity storm drain pipe in Lampson Avenue to directly connect to the closest downstream existing 36-inch storm drain pipe (north of Guava Avenue extended) was found to be infeasible due to conflicts with existing utilities; including existing 16-inch water, 8-inch sewer, and 34-inch gas main. Installing 2,400 feet of force main, as opposed to gravity main, may also create long-term maintenance concerns. In addition, the installation of 2,400 feet of force main is not desirable due to head losses (pressure loss causing a reduction in flow) created by such a long length of pipe.

2. Construct storm drain pipe under Heather Street, Hazelnut Avenue, and Guava Avenue to south and west: Since there is no existing underground storm drain to connect to within Heather Street or Hazelnut Avenue, a new storm drain pipe would need to be extended 3,000 feet through these streets to connect to the existing 36-inch storm drain pipe in Guava Avenue. The existing storm drain system is undersized according to the City of Seal Beach Master Plan of Drainage Update dated August 2008. Future City of Seal Beach capital improvements to the downstream storm drain system are recommended in the Master Plan of Drainage Update at this location, but there is no current timeline to install any capital improvements. Without the capital improvements in place, redirecting stormwater runoff flows from the site to the currently undersized storm drain system in Guava Avenue is infeasible since it would exacerbate the existing flooding condition at this location adjacent to single family homes.

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 to the Bolsa Chica Channel. Discharing 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 potentially cause downstream flooding. In addition, the golf course and Bolsa Chica Channel are upstream from the site, therefore not feasible due to elevation differences.

“ATTACHMENT X”

4665 Lampson Avenue
Facts and Findings and Statement of Overriding Considerations Page 63

5. Construct storm drain pipe under Lampson Avenue to east: Discharging 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. (DEIR, p. 4.9- 21, as revised in Section 4.0 of the FEIR)
The following analysis evaluates the potential for Project-related development activities to adversely affect water quality or cause or exacerbate local flooding.

Erosion or Siltation On- or Off-site
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 result in substantial erosion or siltation on- or off-site. As discussed in Threshold a, compliance with the NPDES permit and the Santa Ana River Basin Water Quality Control Program involves the preparation and implementation of a SWPPP for construction-related activities.

The SWPPP will specify the BMPs that would be required to be implemented during construction activities to ensure that waterborne pollution – including erosion/siltation – is prevented, minimized, and/or otherwise appropriately treated prior to surface runoff being discharged from the subject property. (DEIR, p. 4.9-22)
Mandatory compliance with the SWPPP would ensure that the Project’s construction does not violate any water quality standards or waste discharge requirements. Based on the foregoing information, erosion and sedimentation impacts associated with Project construction activities would be less than significant. No mitigation is required. (DEIR, p. 4.9-22) As discussed under Threshold a, during operation of the Project, the Project Applicant would be required to prepare and implement a WQMP, which is a site-specific post-construction water quality management program that will be implemented to minimize erosion and siltation, pursuant to LAMC Chapter 8.44, Stormwater and Urban Runoff Pollution Controls. The WQMP is required to identify an effective combination of erosion control and sediment control measures (i.e., BMPs) to reduce or eliminate sediment discharge to surface water from storm water and non-storm water discharges. The WQMP also is required to establish a post-construction implementation and maintenance plan to ensure on-going, long-term erosion protection. Compliance with the WQMP is required as a condition of approval for the Project, as will the long-term maintenance of erosion and sediment control features.

Because the Project Applicant would be required to utilize erosion and sediment control measures to preclude substantial, long-term soil erosion and loss of topsoil, Project operation would result in less than significant impacts related to soil erosion and sedimentation. No mitigation is required. (DEIR, p.

4.9-22)

“ATTACHMENT X”

4665 Lampson Avenue
Facts and Findings and Statement of Overriding Considerations Page 64

Runoff and Flooding On- or Off-site
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 substantially increase the rate or amount of surface runoff resulting in flooding on- or offsite. (DEIR, p. 4.9-22)
On-Site Storm 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. (DEIR, p. 4.9-23)
Alternate 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 higher 100- year storm event peak runoff flowrate than the existing condition of the site due to an increase in impervious area and change 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. (DEIR, p. 4.9-23, as revised in Section 4.0 of the FEIR) Based on the foregoing information, the Project would not substantially increase the rate or amount of surface runoff in a manner that would result in flooding on- or off-site. Impacts would be less than significant, and no mitigation is required. (DEIR, p. 4.9-23) Stormwater Drainage System Capacity & Polluted Runoff
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. (DEIR, p. 4.9-23)
As discussed under Threshold a, the Project Applicant would be required to comply with a SWPPP and the Project’s WQMP (DEIR Technical Appendix I2; FEIR Attachment E) which identify required

“ATTACHMENT X”

4665 Lampson Avenue
Facts and Findings and Statement of Overriding Considerations Page 65

BMPs to be incorporated into the Project’s design and operation to ensure that near-term construction activities and long-term post-development activities of the proposed Project would not result in substantial amounts of polluted runoff. Therefore, with mandatory compliance with the Project’s SWPPP and WQMP, the proposed Project would not create or contribute substantial additional sources of polluted runoff, and impacts would be less than significant. No mitigation is required. (DEIR, p.

4.9-23)
Flood Flows
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 impede or redirect flood flows. Federal Emergency Management Agency (FEMA) Flood Insurance Rate Maps identify flood zones and areas that are susceptible to 100-year (1% annual chance of occurrence) and 500-year floods (0.2% annual chance of occurrence). These areas are referred to as Special Flood Hazard Areas and Moderate Flood Hazard Areas respectively.

According to 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 areas with a possible risk of flooding, but the probability has not been determined. Additionally, the City’s General Plan identifies the Project site as an undetermined risk area. It should be noted that the Project site is not in proximity to an area within a flood zone. (DEIR, p. 4.9-24) On-Site Storm Drain Facilities
According to the Hydrology Report, 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. (DEIR, p. 4.9-24)
Alternate Storm Drain Facilities
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. (DEIR, p. 4.9-24) Moreover, as previously discussed, the Project was designed to maintain the approximate existing drainage pattern to the extent feasible. Accordingly, the Project is not expected to impede flood flows.

Impacts would be less than significant, and no mitigation is required. (DEIR, p. 4.9-24)

“ATTACHMENT X”

4665 Lampson Avenue
Facts and Findings and Statement of Overriding Considerations Page 66

3.10.4THRESHOLD D
Impact Statement: The Project would not result in flood hazard, tsunami, or seiche zones, risk release of pollutants due to inundation.
 Findings
Potential impacts of the Project related to Threshold d are discussed in Section 4.9.6 of the DEIR. The City finds that the development of the proposed Project would not result in significant impacts related to Threshold d; therefore, no mitigation is required.
 Substantial Evidence
The Project site is located approximately 4.22 miles northeast of the Pacific Ocean; therefore, there is minimal potential for the Project site to be impacted by a tsunami. A seiche occurs when a wave oscillates in lakes, bays, or gulfs as a result of seismic disturbances. The Project site is also not subject to flooding hazards associated with a seiche because there are no large bodies of water within the vicinity of the Project site. Furthermore, as stated above under Threshold c, 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 anticipated to risk the release of pollutants due to inundation. Impacts would be less than significant and no mitigation is required. (DEIR, pp.

4.9-24 to 4.9-25)

3.10.5THRESHOLD E
Impact Statement: The Project would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.  Findings
Potential impacts of the Project related to Threshold e are discussed in detail in Section 4.9.6 of the DEIR. The City finds that the development of the proposed Project will not result in significant impacts related to Threshold e; therefore, no mitigation is required.  Substantial Evidence
The Project site is located within the jurisdiction of the Santa Ana RWQCB. Project-related construction and operational activities would be required to comply with the Santa Ana RWQCB’s Santa Ana River Basin Water Quality Control Plan by preparing and adhering to a SWPPP and WQMP.

As also discussed in Threshold a above, implementation of the Project would not conflict with or obstruct the Santa Ana River Basin Water Quality Control Plan and impacts would be less than significant. (DEIR, p. 4.9-25)
The Project site is within the Coastal Plain or Orange County Groundwater Basin (Basin 8-1). The Department of Water Resources (DWR) classifies this basin as a medium-priority basin. Under the

“ATTACHMENT X”

4665 Lampson Avenue
Facts and Findings and Statement of Overriding Considerations Page 67

Sustainable Groundwater Management Act (SGMA), local agencies are required to form Groundwater Sustainability Agencies (GSAs) for the high and medium priority basins. GSAs develop and implement GSPs to avoid undesirable results and mitigate overdraft within 20 years. The GSA for Basin 8-1 is comprised of OCWD, city of La Habra, and Irvine Ranch Water District. These agencies collaborated and submitted an Alternative to a GSP titled Basin 8-1 Alternative 2022 Update on January 1, 2022, to the DWR (Alternative). This Alternative documents the basin conditions; basin management is based on measurable objectives and minimum thresholds defined to prevent significant and unreasonable impacts on the sustainability indicators defined in the Alternative. (DEIR, p. 4.9-25) According to the Project’s Geotechnical Evaluation, groundwater was encountered at depths of approximately 11 to 13 feet below existing grade. Additionally, historic high groundwater is estimated to be about 10 feet below existing grade. The Project Applicant does not propose the use of any wells or other groundwater extraction activities. The Project’s potable water would by supplied by Golden State Water Company (GSWC), which relies on the Orange County Groundwater Basin and imported water from the Municipal Water District of Orange County. (DEIR, p. 4.9-25) The 2021-2029 Housing Element includes the Project site in its housing opportunity sites. The Housing Element concluded that based on the 2020 Municipal Water District of Orange County (MWDOC) Urban Water Management Plan (UWMP) analysis and discussion with the City’s water service provider, sufficient water capacity is available to provide water service for additional units constructed to meet the City’s Regional Housing Needs Allocation (RHNA) allocation for the planning period.

Therefore, the Project would not have the potential to conflict with or obstruct implementation of the Basin 8-1 Alternative. Refer also to DEIR Section 4.17, Utilities and Service Systems, for a detailed discussion related to water supply. Impacts would be less than significant and no mitigation is required. (DEIR, p. 4.9-25)

3.10.6CUMULATIVE IMPACTS
Impact Statement: The Project would not result in cumulatively considerable impacts related to hydrology and water quality.
 Findings
Potential cumulative impacts of the Project related to hydrology and water quality are discussed in detail in Section 4.9.7 of the DEIR. The City finds that the development of the proposed Project would not result in significant cumulative impacts related to hydrology and water quality; therefore, no mitigation is required.
 Substantial Evidence
This cumulative impact analysis considers development of the proposed Project in conjunction with other development projects in the vicinity of the Project site and projects located in San Gabriel-Coyote Creek Watershed and the Orange County Groundwater Basin. (DEIR, p. 4.9-26)

“ATTACHMENT X”

4665 Lampson Avenue
Facts and Findings and Statement of Overriding Considerations Page 68

Water Quality
Project construction and the construction of other projects in the cumulative study area would have the potential to contribute waterborne pollution, including erosion and siltation, to the San Gabriel-Coyote Creek Watershed. Pursuant to the requirements of the State Water Resources Control Board and the Santa Ana RWQCB, all construction projects that disturb one (1) or more acres of land area are required to obtain coverage for construction activities under the State’s General Construction NPDES Permit. In order to obtain coverage, an effective site-specific SWPPP is required to be developed and implemented. The SWPPP must identify potential on-site pollutants and identify an effective combination of erosion control and sediment control measures to reduce or eliminate discharge of pollutants to surface waters. In addition, the Project Applicant and all cumulative developments in the Santa Ana River Basin would be required to comply with the Santa Ana RWQCB’s Santa Ana River Basin Water Quality Control Program, which establishes water quality standards for ground and surface waters of the region. Compliance with these mandatory regulatory requirements, would ensure that development projects within the San Gabriel-Coyote Creek Watershed, including the proposed Project, would not contribute substantially to water quality impairments during construction. (DEIR, p. 4.9-26)
Operational activities on the Project site would be required to comply with the Project’s WQMP to minimize the amount of waterborne pollution, including erosion and sediment, discharged from the site. Other development projects within the watershed would similarly be required by law to prepare and implement site-specific WQMPs to ensure that runoff does not substantially contribute to water quality violations. Accordingly, operation of the Project would not contribute to cumulativelyconsiderable water quality effects. (DEIR, p. 4.9-26) Groundwater Supplies and Management
The Project site does not support infiltration and the Project site is not within and is not a part of a recharge facility for the Orange County Groundwater Basin. Also, as previously noted, implementation of the Project would not result in substantial adverse effects to local groundwater supplies or groundwater recharge. Thus, no component of the Project would obstruct or prevent implementation of the management plan for the Orange County Groundwater Basin and other development projects within the Orange County Groundwater Basin would be prohibited from any activity that would endanger the health and sustainability of the groundwater basin. Based on the lack of impacts to groundwater and compliance with the applicable Orange County Groundwater Basin management plan, cumulative development would not result in a considerable, adverse effect to local groundwater supplies and not conflict with any water quality control plans or sustainable groundwater management plans. (DEIR, p. 4.9-26)
Flooding
Construction of the Project and other development projects within the San Gabriel-Coyote Creek Watershed 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

“ATTACHMENT X”

4665 Lampson Avenue
Facts and Findings and Statement of Overriding Considerations Page 69

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 GabrielCoyote 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. (DEIR, p. 4.9-27)

3.11 LAND USE AND PLANNING
Project impacts for Land Use and Planning Thresholds a and b do not result in significant impacts.

Findings are discussed below.

3.11.1THRESHOLD A
Impact Statement: The Project would not physically divide an established community.  Findings
Potential impacts of the Project related to Threshold a are discussed in Section 4.10.5 of the DEIR.

The City finds that the development of the proposed Project will not result in significant impacts related to Threshold a; therefore, no mitigation is required.
 Substantial Evidence
The Project involves the redevelopment of a 12.3-acre site with a residential development of 246 units.

The Project is consistent with the City’s General Plan land use designations and zoning. The Project site is surrounded by Arbor Park to the north, the Navy Golf Course to the east, residential development to the south, and the Los Alamitos JFTB to the west. The proposed residential development is consistent with the surrounding land uses in the area and would not introduce a new use that potentially would separate existing communities through incompatible development (e.g., by limiting access to surrounding areas). For example, the Project would facilitate connections between the existing residential neighborhoods to the south and Arbor Park by providing additional parking for the park, improved sidewalks, signalized pedestrian intersections, and other circulation improvements.

Additionally, the proposed Project would be developed within the confines of the Project site and would not introduce new major roadways or other infrastructure improvements that would bisect or transect the surrounding communities. For example, off-site improvements, including the replacement of the existing median curb/landscape and water line extension along Lampson Avenue would all occur within existing right-of-way. Therefore, redevelopment of the Project site would not physically divide an established community. No impact would occur and no mitigation is required. (DEIR, pp. 4.10-9 to

4.10-10)

“ATTACHMENT X”

4665 Lampson Avenue
Facts and Findings and Statement of Overriding Considerations Page 70

3.11.2THRESHOLD B
Impact Statement: The Project would not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.
 Findings
Potential impacts of the Project related to Threshold b are discussed in Section 4.10.5 of the DEIR.

The City finds that the development of the proposed Project will not result in significant impacts related to Threshold b; therefore, no mitigation is required.
 Substantial Evidence
The Project’s consistency with land use plans, policies, and regulations adopted for the purpose of avoiding or mitigating an environmental effect is discussed below. DEIR Section 4.10.5 includes an analysis of consistency with Southern California Association of Governments (SCAG)’s Connect SoCal, the AELUP for the Los Alamitos JFTB, and the City’s General Plan. The Project’s consistency with the General Plan Mobility and Circulation Element is also discussed in DEIR Section 4.15, Transportation, of the DEIR. (DEIR, p. 4.10-10)
SCAG Connect SoCal
SCAG’s Connect SoCal is the SCAG planning document that applies to the Project. Connect SoCal identifies voluntary best practices to approach growth and infrastructure challenges in an integrated and comprehensive way. The Connect SoCal goals are meant to provide guidance for considering proposed projects for municipalities throughout the SCAG jurisdictional area. As shown in DEIR Table

4.10-1, SCAG Connect SoCal Goal Consistency Analysis, the Project would not conflict with the Connect SoCal goals. Accordingly, the Project would have a less than significant impact and no mitigation is required. (DEIR, p. 4.10-10)
Airport Environs Land Use Plan (AELUP) for Joint Forces Training Base (JFTB) Los Alamitos The City and the Project site are within the airport planning area of the Los Alamitos JFTB. Land uses within the airport planning-area boundaries are required to conform to four key areas of military airport compatibility including: 1) aviation safety; 2) aircraft noise; 3) aircraft overflight; and 4) airspace protection/height zoning. Section 2.1 of the AELUP describes the standards and criteria adopted by the Airport Land Use Commission for Orange County for establishing planning boundaries. (DEIR, p.

4.10-14)
Safety
As discussed in DEIR Section 4.8, Hazards and Hazardous Materials, of the DEIR, the Project site is not located within the clear zones (CZs) or APZ (refer to DEIR Figure 4.8-1, JFTB Impact Zones) for the JFTB. Therefore, the Project does not concentrate people in areas susceptible to aircraft accidents.

Therefore, the Project would not result in a safety hazard for people residing at the Project site. As such, the Project would not conflict with the safety restrictions established in the AELUP for the JFTB.

“ATTACHMENT X”

4665 Lampson Avenue
Facts and Findings and Statement of Overriding Considerations Page 71

Height
The Project site is located within the FAR Part 77 Notification Area and Horizontal Imaginary Surface for the Los Alamitos JFTB. Based on the FAA’s Determination of No Hazard to Air Navigation (Technical Appendix J2 of the DEIR), the Project would not penetrate FAR Part 77 Imaginary Obstruction Surfaces for JFTB. Determination of No Hazard further determined that the location and height of the Project’s proposed buildings would not interfere with the established, or planned, airport flight procedures, patterns, or navigational systems. The FAA further found that the Project would not raise the ceiling or visibility minimums for any existing or planned instrument procedure at the Base.

The FAA found that the Project would not result in a loss of airport utility, operational efficiency and capacity and would not reduce the usable length of either Base runway. Further, the Project would not conflict with the visual flight rules (VFR) airspace used for traffic patterns or arrival/departure airspace areas. The FAA Determination of No Hazard stated that marking and lighting of Project structures is not necessary for aviation safety. As such, the Project would not conflict with the height restrictions established in the AELUP for the JFTB. (DEIR, pp. 4.10-15 to 4.10-16) Noise Standards
The AELUP relies on the 1994 California Army National Guard Installation Compatible Use Zone Study (AICUZ) for noise contours surrounding JFTB. The 1994 AICUZ depicts the Project site outside of the 65 dB CNEL noise contour and between the 60 and 65 CNEL noise contours. The AELUP considers residential land uses “conditionally consistent” with the 60 decibels (dB) CNEL noise contour and recommends sound attenuation to ensure interior CNEL does not exceed 45 dB CNEL and outdoor signage “informing the public of the presence of operating aircraft.” The City enforces California Building Code standards for residential construction practices and building materials to ensure that interior noise levels do not exceed 45 dBA. (DEIR, p. 4.10-16) Although the AELUP considers the Project conditionally consistent with the 60 dB CNEL contour, the CNEL noise contours depicted in the 1994 AICUZ and used by the AELUP are outdated and do not reflect updated noise contour information set forth in the most recent 2020 Noise Assessment completed for the Base. Further, the ALUC estimated the 60 dB CNEL contour in the AELUP using the 1994 AICUZ by extrapolating from the outdated 65 dB CNEL contour “using a logarithmic scaling method and professional acoustical-engineering judgment”. This method of extrapolation is both outdated and contrary to the US Department of Defense (DOD) aircraft noise analysis requirements.

The US DOD requires the use of the aircraft noise model NOISEMAP to predict community noise exposure. As required by US DOD, the 2020 Noise Assessment for the Base used NOISEMAP to predict community noise exposure. (DEIR, p. 4.10-16)
The 2020 Noise Assessment included a noise analysis of the then-current aircraft operations as the “Baseline” and provided a forecast of additional operations by the California Air National Guard projected over a 10-year period (“Projected” operations). As shown in DEIR Figure 4.11-4, a small portion of the northwest corner of the Project site is within the 60 dB CNEL Projected Noise Contour (based on the 10-year operations forecast) but the remainder of the site remains outside of the 60 dB CNEL noise contour. DEIR Figure 4.11-4 depicts the Project site in relation to the Baseline and

“ATTACHMENT X”

4665 Lampson Avenue
Facts and Findings and Statement of Overriding Considerations Page 72

Projected noise contours under the 2020 Noise Assessment for the base. (DEIR, pp. 4.10-16 to 4.10- 17)
Relative to the 2020 Baseline and Projected noise contours, the entire Project site is located outside of the 65 dB CNEL noise contour, and only a small portion of the Project site would be located within the 60 to 65 CNEL contour. The remainder of the Project site would be outside the 60 dB CNEL contour. The AELUP considers residential land uses consistent in areas outside the 60 dB CNEL contour and indicates that there are “no special noise reduction requirements.” For the small portion of the site within the 60 to 65 CNEL contour, the AELUP indicates that it would be conditionally consistent and recommends sound attenuation to ensure interior CNEL does not exceed 45 dB and outdoor signage. The Project would comply with these recommendations. As stated above, the City enforces California Building Code standards for residential construction practices and building materials to ensure that interior noise levels do not exceed 45 dBA. Indeed, current building codes require construction materials and construction techniques that generally provide a minimum of 20 dB of sound attenuation. 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.” (DEIR, p. 4.10-17)
Thus, interior noise for the small portion of the Project site within the 60 to 65 CNEL contour would be less than 45 dB CNEL with 20 dB of noise attenuation from standard construction practices. Interior noise within the rest of the Project site, which is located outside the 60 CNEL contour, would be even lower. Therefore, both the exterior and interior noise levels associated with the Project are consistent with the AELUP, and the Project would not expose people residing or working in the Project area to excessive noise levels from airport or aircraft operations. Impacts would be less than significant and no mitigation is required. (DEIR, p. 4.10-17)
Aircraft Overflight
Arrival and departure corridors used by inbound and outbound aircraft avoid direct overflight of residential areas as much as possible and avoid the Project site (see Figure 11 of Technical Appendix J1). These corridors follow the major highways and streets to blend the majority of overflight noise with the background traffic noise. Navy Golf Course, Old Ranch Country Club and the Base’s landside facilities, such as aircraft parking aprons, hangars, offices and roadways, also provide overflight setbacks from residential land uses. The objective is to reduce annoyance and minimize the number of people exposed to excessive noise levels from overflying aircraft. (DEIR, p. 4.10-17) As noted in the Handbook, “very little guidance exists for limiting people’s exposure to overflight.” Nonetheless, regular updates to the AICUZ noise and overflight analysis are prepared and provided to members of the community as changes are made over time to the diverse mix of aircraft making use of the Base in its unique role as a “Joint Forces Training” facility. These operations, noise and overflight updates are required by the Department of Defense guidance for Base planning personnel and for dissemination to the public through the AICUZ program. (DEIR, p. 4.10-18)

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AELUP Section 2.1.4 provides the ALUC guidance specific to overflight compatibility. The AELUP overflight policies follow State law and the California Airport Land Use Planning Handbook methods of achieving compatibility through buyer awareness and overflight information. The ALUC mandates the State’s real estate disclosure provisions requiring 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. (DEIR, p. 4.10-18)
As identified in the Handbook, the primary overflight strategy is to ensure buyer awareness as opposed to any specific land use restrictions. This 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 below:

NOTICE OF AIRPORT. This property is presently located in the vicinity of an airport, within what is known as an airport influence area. For that reason, the property may be subject to some of the annoyances or inconveniences associated with proximity to airport operations (for example: noise, vibration, or odors). Individual sensitivities to those annoyances can vary from person to person. You may wish to consider what airport annoyances, if any, are associated with the property before you complete your purchase and determine whether they are acceptable to you. (DEIR, p. 4.10-18) With this required notification, the Project is consistent with overflight notification requirements as required by State law provided by the Handbook, State law, the AICUZ and AELUP. (DEIR, p. 4.10- 18)
Summary
The Project would not conflict with JFTB AELUP’s safety, height, noise, or aircraft overflight criteria, and impacts would be less than significant. No mitigation is required. (DEIR, p. 4.10-18) City of Los Alamitos General Plan
DEIR Table 4.10-2, 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 DEIR Table 4.10-2, 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. (DEIR, p. 4.10-19)

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City of Seal Beach General Plan
DEIR 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 DEIR 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. (DEIR, p. 4.10-33, as revised in Section 4.0 of the FEIR)

3.11.3CUMULATIVE IMPACTS
Impact Statement: The Project would not result in cumulatively considerable impacts related to land use and planning.
 Findings
Potential cumulative impacts of the Project related to land use and planning are discussed in detail in Section 4.10.6 of the DEIR. The City finds that the development of the proposed Project would not result in significant cumulative impacts related to land use and planning; therefore, no mitigation is required.
 Substantial Evidence
This Project, in conjunction with other cumulative related projects would not physically divide an established community. As discussed under Threshold a, the Project would not physically divide an established community because the Project site is currently developed, in an urbanized area and would not introduce new major roadways or other infrastructure improvements that would bisect or transect the surrounding communities. Similarly, the City is primarily built out and there are no cumulative related projects that could combine with the Project that would physically divide an established community. (DEIR, p. 4.10-33)
The Project, in conjunction with other cumulative development in accordance with the City’s General Plan, would not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. As discussed under Threshold b, the Project is consistent with SCAG’s Connect SoCal, the City’s land use and zoning designations for the Project site and would not conflict with any aspects of the City’s General Plan or any other applicable land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating adverse environmental effects. Cumulative development would also be subject to site-specific environmental and planning reviews to ensure consistency with applicable regional and local plans reviewed in this section. Therefore, cumulatively considerable impacts from cumulative projects related to policy consistency would be less than significant. (DEIR, p. 4.10-33)

3.12 MINERAL RESOURCES
Project impacts for Mineral Resources Thresholds a and b do not result in significant impacts and findings are discussed below.

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3.12.1THRESHOLD A
Impact Statement: The Project would not result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state.  Findings
Potential impacts of the Project related to Threshold a are discussed in Section 5.4.2 of the DEIR. The City finds that the development of the proposed Project would not result in significant impacts related to Threshold a; therefore, no mitigation is required.
 Substantial Evidence
The Project does not conflict with California Legislature’s 1975 Surface Mining and Reclamation Act (SMARA), which provides guidelines of the classification and designation of mineral lands. The City of Los Alamitos and its sphere of influence fall within the Mineral Resource Zone-1 (MRZ) and MRZ4. MRZ-1 represents areas where adequate geologic information indicates that no significant mineral deposits are present, or where it is judged that little likelihood exists for their presence. MRZ-4 indicates areas where available information is inadequate for assignment to any other MRZ zone.

Specifically, the Project is within MRZ-1. Accordingly, no impact would occur. (DEIR, p. 5-8)

3.12.2THRESHOLD B
Impact Statement: The Project would not result in the loss of availability of a locally-important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan.  Findings
Potential impacts of the Project related to Threshold b are discussed in Section 5.4.2 of the DEIR. The City finds that the development of the proposed Project would not result in significant impacts related to Threshold b; therefore, no mitigation is required.
 Substantial Evidence
There are no locally important mineral resource recovery sites in the City of Los Alamitos or its sphere of influence. As discussed above, no known valuable mineral resources exist on or near the Project site and no mineral resource extraction activities occur on the site. Thus, the proposed Project would not result in the loss of availability of locally-important mineral resources. Accordingly, no impact would occur. (DEIR, pp. 5.8 to 5-9)

3.13 NOISE
Except as indicated, Project impacts for CEQA Noise Thresholds a, b and c do not result in significant impacts and findings are discussed below.

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3.13.1THRESHOLD A
Impact Statement: The Project would not generate a substantial temporary or permanent increase in ambient noise levels during construction or on-site operation, in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies.  Findings
Potential impacts of the Project related to Threshold a are discussed in detail in Section 4.11.7 of the DEIR. The City finds that the development of the proposed Project would not result in significant impacts related to Threshold a, for construction or on-site operation; therefore, no mitigation is required for these.
 Substantial Evidence
The analysis presented on the following pages summarizes the Project’s potential construction noise levels and operational noise levels, including off-site noise that would be generated by Project-related traffic.

Construction Noise
Construction activities on the Project site would proceed in six stages: 1) demolition, 2) site preparation, 3) grading, 4) building construction, 5) paving, and 6) application of architectural coating.

Noise generated by the Project construction equipment would include a combination of trucks, power tools, concrete mixers, and portable generators that when combined could reach high noise levels and would cause a short-term increase in ambient noise levels. The Project’s potential construction noise levels at nearby receiver locations are summarized in DEIR Table 4.11-5, Construction Equipment Noise Level Summary. (DEIR, p. 4.11-23)
To evaluate whether the Project will generate potentially significant short-term noise levels at nearest receiver locations, a construction-related daytime noise level threshold of 80 dBA Leq is used to assess the daytime construction noise level impacts based on the FTA’s Transit Noise and Vibration Impact Assessment Manual. Due to the lack of standardized construction noise thresholds, the FTA provides guidelines that can be considered reasonable criteria for construction noise assessment. This threshold takes into account the existing noise environment, the absolute noise levels during construction activities, the duration of the construction, and the adjacent land uses. The construction noise analysis shows that noise impacts at the nearest receiver locations will be less than the daytime 80 dBA Leq significance threshold during Project construction activities. Because the highest construction related noise level is 63.31 dBA Leq at the nearest sensitive receiver, the noise impacts due to Project construction noise are considered less than significant and no mitigation is required. (DEIR, p. 4.11- 24)
Operational Noise – Stationary Noise
On-site Project-only operational noise sources are expected to include: roof-top and ground-mounted air conditioning units, parking lot vehicle movements, outdoor activity, and trash enclosure activities.

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The daytime and nighttime Project operational noise levels at nearby sensitive receptor locations are summarized on DEIR Table 4.11-6, Project Daytime and Nighttime Operational Noise Levels. (DEIR, p. 4.11-24)
As shown in DEIR Table 4.11-6, operational noise levels associated with the Project will be less than the City of Los Alamitos’s 55 dBA Leq daytime and 50 dBA Leq nighttime exterior noise level standards at the nearest receiver locations. Therefore, operational noise impacts would be less than significant at the nearest noise-sensitive receiver locations and no mitigation is required. (DEIR, p. 4.11-25) To describe the Project operational noise level increases, the Project operational noise levels are combined with the existing ambient noise levels measurements for the nearest receiver locations potentially impacted by Project operational noise sources. As indicated on Tables 10-5 and 10-6 of the Project’s Noise Report (Technical Appendix K to this EIR), the Project would generate an unmitigated daytime and nighttime operational noise level increases ranging from less than 0.0 to 1.2 dBA Leq at the nearest receiver locations. Project-related operational noise level increases would be less than significant, and no mitigation is required. (DEIR, p. 4.11-25) Operational – Off-site Transportation
To assess the off-site traffic CNEL noise level impacts associated with development of the proposed Project, noise level contours were developed based on 4665 Lampson Avenue Traffic Analysis. Noise level contour boundaries represent the equal levels of noise exposure and are measured in CNEL from the center of the roadway. Noise level contours were developed for six traffic scenarios based on the Traffic Analysis (DEIR Technical Appendix N1): Existing, Existing Plus Project, Opening Year Without and With Project, and General Plan Buildout Without and With Project conditions. (DEIR, p.

4.11-25)
The noise contours were used to assess the Project's incremental 24-hour dBA CNEL traffic-related noise impacts at land uses adjacent to roadways conveying Project traffic. The noise contours represent the distance to noise levels of a constant value and are measured from the center of the roadway for the 70, 65, and 60 dBA CNEL noise levels. The noise contours do not consider the effect of any existing noise barriers or topography that may attenuate ambient noise levels, which represents worst case conditions. (DEIR, pp. 4.11-25 to 4.11-26)
As shown on FEIR Table 4.11-7, Existing Off-Site Project-Related Traffic Noise Impacts, the Existing 2023 with Project will generate a noise level increase of up to 0.3 dBA CNEL on the study area roadway segments. Based on the significance criteria for off-site traffic noise impacts, the Projectrelated noise level increases are considered less than significant under Existing plus Project conditions at the land uses adjacent to roadways conveying Project traffic. (DEIR, p. 4.11-26, as revised in Section

4.0 of the FEIR)
FEIR Table 4.11-8, Opening Year Off-Site Project-Related Traffic Noise Impacts, shows that the Opening Year Project off-site traffic noise level increases of up to 0.2 dBA CNEL. Based on the significance criteria for off-site traffic noise presented for off-site traffic noise impacts, land uses

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adjacent to the study area roadway segments would experience less than significant noise level increases due to unmitigated Opening Year Project-related traffic noise levels. (DEIR, p. 4.11-26, as revised in Section 4.0 of the FEIR)
FEIR Table 4.11-9, General Plan Buildout Off-Site Project-Related Traffic Noise Impacts, shows that the General Plan Buildout Project off-site traffic noise level with Project increases of up to 0.2 dBA CNEL. Based on the significance criteria for off-site traffic noise presented for off-site traffic noise impacts, land uses adjacent to the study area roadway segments would experience less than significant noise level increases due to unmitigated General Plan Buildout Project-related traffic noise levels with the Project. (DEIR, p. 4.11-26, as revised in Section 4.0 of the FEIR) Based on the significance criteria for off-site traffic noise impacts, land uses adjacent to the study area roadway segments would not experience substantial noise level increases due to Project-related traffic noise level increases and off-site traffic related noise impacts would less than significant. No mitigation is required. (DEIR, p. 4.11-26)
The Project includes the following PDFs that will result in a reduction of the Project’s impacts.

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 25 dBA;
 Earthen berm; or,
 Any combination of these construction materials
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:

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 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 well-fitted, well-weatherstripped assemblies with minimum sound transmission class (STC) ratings of

29.  Doors (Non-Glass): All exterior doors shall be well weather-stripped and have Well-sealed 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).

3.13.2THRESHOLD B
Impact Statement: The Project would not generate excessive groundborne vibration or groundborne noise levels.
 Findings
Potential impacts of the Project related to Threshold b are discussed in detail in Section 4.11.7 of the DEIR. The City finds that the development of the proposed Project would not result in significant impacts related to Threshold b; therefore, no mitigation is required.  Substantial Evidence
Construction Analysis
Construction activities on the Project site would utilize equipment that has the potential to generate vibration, such as small bulldozers, large bulldozers, jackhammers, and loaded trucks. Vibration levels

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at sensitive receptors near the Project site during Project construction are summarized on DEIR Table

4.11-10, Project Construction Vibration Levels. At distances ranging from 51 to 5,046 feet from the Project construction activities, construction vibration velocity levels are estimated to range from less than 0.00 to 0.03 in/sec PPV. Based on maximum acceptable continuous vibration threshold of 0.30 PPV (in/sec), the typical Project construction vibration levels would be below the building damage thresholds at all receiver locations. Therefore, the Project-related vibration impacts are considered less than significant during the construction activities at the Project site and no mitigation is required. (DEIR, p. 4.11-30)
Operational Analysis
Under long-term conditions, the Project would not include or require equipment or activities that would result in perceptible groundborne vibration at or beyond the Project site. The Project would not result in the exposure of persons to excessive groundborne vibration or noise levels during long-term operation. Impacts would be less than significant, and no mitigation is required. (DEIR, p. 4.11-30)

3.13.3THRESHOLD C
Impact Statement: The Project would not expose people residing or working in the Project area to excessive noise levels due to airport noise.
 Findings
Potential impacts of the Project related to Threshold c are discussed in Section 4.11.7 of the DEIR.

The City finds that the development of the proposed Project would not result in significant impacts related to Threshold c; therefore, no mitigation is required.  Substantial Evidence
The Project site is located within the AELUP for JFTB Los Alamitos. 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. (DEIR, p. 4.11-31) The JFTB Los Alamitos is located adjacent to, and northwest of the Project. DEIR Figure 4.11-4, APHC 2020 Airport Noise Level Contour Boundaries 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 DEIR 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 are considered “conditionally consistent” with AELUP Noise limitations, so long as sound attenuation as required by the California Noise Insulation Standards, Title 25, California Code of Regulations is implemented to ensure that the interior CNEL does not exceed 45 dB. (DEIR, p. 4.11-31)

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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. (DEIR, p. 4.11-31)
The Project will provide mechanical ventilation (e.g. air conditioning) in all units. 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 noise levels from airport or aircraft operations, and impacts would be less than significant. No mitigation is required. (DEIR, p. 4.11-31)

3.13.4CUMULATIVE IMPACTS
Impact Statement: The Project would not result in cumulatively considerable impacts related to noise (construction-related or on-site operational noise).
 Findings
Potential cumulative noise impacts of the Project related to construction and on-site operation are discussed in detail in Section 4.11.8 of the DEIR. The City finds that the development of the proposed Project would not result in significant cumulative impacts related to noise; therefore, no mitigation is required.
 Substantial Evidence
Construction Noise
Construction activities associated with the proposed Project, especially activities involving heavy equipment, could create intermittent periods of noise when construction equipment is in operation and could cause a short-term increase in ambient noise levels. The list of cumulative projects that have the potential to collectively increase noise is provided in Table 4.0-1 and the locations are shown in Figure

4.0-1 in Section 4.0, Environmental Analysis, of the DEIR. As shown, there are no on-going or imminent construction projects in the immediate vicinity of the proposed Project site with construction periods that are expected to overlap with the Project. Accordingly, there is no potential for Projectrelated construction activities to contribute to cumulatively-considerable impacts to sensitive receptor locations. (DEIR, p. 4.11-34)

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Operational Noise
The analysis presented under Threshold a addresses the Project’s contribution of noise to existing cumulative noise sources (i.e., ambient noise) in the Project area. As described above, the Project would not result in an increase in the cumulative noise levels at sensitive receiver locations. (DEIR, p.

4.11-24)
DEIR Table 4.11-11, Cumulative Project Traffic Noise Increases, shows that the Project’s potential off-site contribution to cumulative traffic noise levels ranges from 0.7 to 1.0 dBA CNEL. Based on the significance criteria for off-site traffic noise presented for off-site traffic noise impacts, land uses adjacent to the study area roadway segments would not experience cumulatively considerable noise level increases due to Project-related traffic noise level increases and cumulative impacts would be less than significant. (DEIR, p. 4.11-34)
Groundborne Vibration and Noise
During construction, the Project’s peak vibration impacts would occur during the grading phase when large pieces of equipment, like bulldozers, are operating on-site. (During the non-grading phases of Project construction, when smaller pieces of equipment are used on-site, the Project’s vibration would be minimal.) Vibration effects diminish rapidly from the source; therefore, the only sources of cumulative vibration in the vicinity of the Project site could occur on properties abutting these sites.

As described above, there are no known active or pending construction projects abutting the Project site that would overlap with the Project’s proposed construction schedule. Accordingly, there is no potential for the Project to contribute to the exposure of persons to substantial temporary groundborne vibration or noise. (DEIR, p. 4.11-34)
Under long-term conditions, the Project would not include or require equipment or activities that would result in perceptible groundborne vibration beyond the Project site. Therefore, Project vibration would not combine with vibration sources from other related projects. The Project would not cumulativelycontribute to the exposure of persons to excessive groundborne vibration or noise levels during longterm operation. (DEIR, p. 4.11-34) Airport Noise
There are no conditions associated with implementation of the Project that would contribute to airport noise or exposure of additional people to unacceptable levels of airport noise. DEIR Figure 4.11-4, APHC 2020 Airport Noise Level Contour Boundaries 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 DEIR 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. As discussed in Threshold c based on the Project’s design, 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.

The Project would not, when combined with related projects, affect airport-related military operations and related noise impacts. Therefore, the Project would not cumulatively-contribute to the exposure of

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persons residing or working in the Project area to excessive airport-related noise levels. All other development projects within the AELUP for JFTB Los Alamitos would be subject to the compatibility criteria and would be required to comply with statutory and regulatory noise requirements.

3.14 POPULATION AND HOUSING
Project impacts for Populations and Housing Thresholds a and b do not result in significant impacts and findings are discussed below.

3.14.1THRESHOLD A
Impact Statement: The Project would not induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure).
 Findings
Potential impacts of the Project related to Threshold a are discussed in Section 4.12.5 of the DEIR.

The City finds that the development of the proposed Project would not result in significant impacts related to Threshold a; therefore, no mitigation is required.  Substantial Evidence
The Project would redevelop the Project site, which currently includes a vacant office building, with a residential development consisting of a variety of different product types, including single family detached homes, townhomes, and apartments. The unit mix would include 55 single family detached homes, 114 townhomes, and 76 for rent affordable multi-family apartment units, as well as one market rate manager’s apartment unit totaling 246 residential units. The overall density for the Project would be 20 dwelling units per acre. This analysis assesses whether the construction and operation of the Project would induce direct or indirect substantial unplanned population growth. (DEIR, p. 4.12-8) Construction
The Project would be developed over an approximately 39.5-month construction period. Project construction activities would require contractors and laborers. It is anticipated that general construction labor would be available from the local and regional labor pool and would not result in substantial population growth because the construction workers would commute from their respective homes.

Additionally, each construction phase (e.g., demolition, grading, paving, electrical etc.) requires different skills and specialties, which would be needed for the length of time of that phase. Because of that, the Project’s construction phases would not result in a long-term increase in employment which could induce substantial unplanned population growth from short-term construction activities.

Therefore, the Project would not directly or indirectly induce substantial population growth in the City during construction. Impacts would be less than significant, and no mitigation is required. (DEIR, p.

4.12-8)

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Operation
The Project would result in the development of 246 dwelling units. Assuming an average household size of 2.63, consistent with the household size reported in the City’s 2021-2029 Housing Element, the Project would generate approximately 647 new residents in the City. (DEIR, p. 4.12-9) As shown in DEIR Table 4.12-5, Estimated Population and Housing in Los Alamitos with Project, the Project’s proposed 246 households and 647 residents were assumed in the growth projections of the City’s General Plan. (DEIR, p. 4.12-9)
On February 21, 2023, the City adopted its General Plan Housing Element to reflect the 2021-2029 cycle. As shown in DEIR Table 4.12-4, City of Los Alamitos Regional Housing Needs Allocation, the City’s RHNA allocation is 769 housing units based on SCAG 6th Cycle Final RHNA Allocation Plan.

The Project site is identified within the City’s Housing Element as a housing element site with an estimate of 246 units. Development of the Project with a total of 246 units would be consistent with the City’s 2021–2029 Housing Element. (DEIR, p. 4.12-9) The City’s General Plan designates the Project site for “Multiple Family Residential-25” land use and the Project site is zoned as “Multi-Family Residential (R-3).” The R-3 zone applies to lots intended to provide multi-family housing. The maximum permitted density is 25 dwelling units per net acre. As discussed above, the Project would include a total of 246 units with an overall density of 20 dwelling units per acre, which is less than the 25 dwelling units per acre allowed by the underlying General Plan and zoning designations. Therefore, the Project would be consistent with the General Plan land use and zoning designation and the associated growth anticipated for the Project site pursuant to the General Plan as amended. (DEIR, p. 4.12-9)
The jobs-housing ratio is a general measure of the number of jobs versus housing in a defined geographical area and the recommended target is 1.0. As shown in DEIR Table 4.12-5, the City is “jobs-rich” and at a ratio of 3.4 jobs/housing, it is currently well above the target ratio. At Project buildout, the Project’s addition of 246 units would be expected to beneficially affect the City’s jobshousing balance, by increasing more housing to the City and reducing the jobs-housing ratio from 3.33 to 3.17 at Project buildout (see DEIR Table 4.12-5). (DEIR, p. 4.12-10) The Project would not result in substantial unplanned growth in the area because: 1) the Project is within the growth projections of the City’s General Plan, 2) the planned housing is a requirement of State Housing Law and in response to an existing unmet need for housing, 3) the Project is consistent with the existing General Plan land use and zoning designations, and 4) the Project improves the City’s job-housing balance by developing housing in a currently jobs-rich and housing-poor area. Therefore, implementation of the Project would not result in substantial unplanned population growth, and impacts would be less than significant. No mitigation is required. (DEIR, p. 4.12-10) Indirect Impacts
Implementation of the Project could result in a substantial and unplanned level of growth if it would result in the extension of new roads or other infrastructure that could induce population growth. As detailed in DEIR Section 3.0, Project Description, of the DEIR, the Project would not require

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construction of new roadways but would require connection of utility infrastructure to serve the development. (DEIR, p. 4.12-10)
The Project would not result in the alteration of the segment of Lampson Avenue that abuts the Project site except for the replacement of the existing median curb and construction of the two proposed driveways shown in DEIR Figure 3-27, Physical Disturbance Area. Additionally, it should be noted that a restricted emergency vehicle access point at Lampson Avenue would be provided at the eastern end of the site. Domestic water lanes would be provided as shown in DEIR Figure 3-23, Utility Plan.

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. A lift station and force main are proposed at the southeast corner of the Project site (refer to DEIR Figure 3-23). 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 would be constructed in accordance with City standards. The Project also would involve utility connections to existing facilities to provide electric power and telecommunications services to serve the Project site. (DEIR, p. 4.12-10) Because all proposed utility infrastructure would connect to existing facilities and would exclusively serve the proposed development and would not increase capacity for other related projects in the area, this Project infrastructure would not indirectly induce substantial unplanned population growth. (DEIR, p. 4.12-10)
Summary
Based on the foregoing analysis, the Project is not expected to be a catalyst for any substantial, unplanned population increases. Based on the foregoing analysis, neither the Project nor any Projectrelated component would directly or indirectly result in substantial unplanned population growth that would cause a significant impact to the environment. Impacts would be less than significant, and no mitigation is required. (DEIR, pp. 4.12-10 to 4.12-11)

3.14.2THRESHOLD B
Impact Statement: The Project would not displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere.  Findings
Potential impacts of the Project related to Threshold b are discussed in Section 4.12.5 of the DEIR.

The City finds that the development of the proposed Project would not result in significant impacts related to Threshold b; therefore, no mitigation is required.  Substantial Evidence
Under existing conditions, the Project site is developed with a vacant two-story, 88,000 sf commercial office building and parking lot. The Project site does not contain any existing residential structures.

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Therefore, implementation of the Project would not displace a substantial number of existing people or housing, but, in fact, would provide additional housing opportunities for the community. As such, the implementation of the Project would not necessitate construction of replacement housing elsewhere. No impacts would occur, and no mitigation is required. (DEIR, p. 4.12-11)

3.14.3CUMULATIVE IMPACTS
Impact Statement: The Project would not result in cumulatively considerable impacts related to population and housing.
 Findings
Potential cumulative population and housing impacts of the Project are discussed in detail in Section

4.12.6 of the DEIR. The City finds that the development of the proposed Project would not result in significant cumulative impacts related to population and housing; therefore, no mitigation is required.  Substantial Evidence
The Project would provide 246 dwelling units, of which 76 would be affordable multi-family for rent apartment units, as well as one market rate manager’s apartment unit, in the City of Los Alamitos. The related projects (see DEIR Section 4.0, Environmental Analysis, for the related projects list), would result in an increase of 107 residential units, 2,724 square feet of commercial uses, and 5,200 square feet of office uses. As shown in DEIR Table 4.12-6, Cumulative Projects Population, Housing, and Employment Growth Trends in Los Alamitos, the related projects’ residential uses would generate approximately 281 residents, which when combined with the Project, results in 928 residents. As shown, the Project and related projects would be within the growth projections of the City’s General Plan and would improve the City’s job-housing balance by developing housing in a currently jobs-rich and housing-poor area. Therefore, the Project with related projects contribution to unplanned housing and population growth would not be cumulatively considerable. Cumulative impacts would be less than significant. (DEIR, pp. 4.12-11 to 4.12-12)
Under existing conditions, there are no existing people or housing located on-site. As such, the Project has no potential to contribute to a cumulatively significant impact associated with the need to construct unplanned housing units. (DEIR, p. 4.12-12)

3.15 PUBLIC SERVICES
Project impacts for Public Services Threshold a does not result in significant impacts and findings are discussed below.

3.15.1THRESHOLD A
Impact Statement: The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered government facilities or the need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives

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for any of the public services: Fire Protection; Police Protection; Schools; Parks; or Other Public Facilities.
 Findings
Potential impacts of the Project related to Threshold a are discussed in Section 4.13.5 of the DEIR.

The City finds that the development of the proposed Project will not result in significant impacts related to Threshold a; therefore, no mitigation is required.
 Substantial Evidence
Fire Protection Services
Implementation of the Project would increase the overall demand on fire protection and emergency services in the City. Project buildout would result in an increase of 246 dwelling units and approximately 647 residents. This Project related growth is expected to create the typical range of fire and emergency service calls, and would increase call volumes, which may affect response times for emergency and non-emergency services. (DEIR, p. 4.13-9) However, 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.

Additionally, response times would not decrease to necessitate the construction of a new fire station.

In order to maintain acceptable service ratios, OCFA uses a fair share approach to mitigate fire service response impacts and facility/equipment needs. 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. (DEIR, p. 4.13-9)
Further, 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 requirement based upon the tenant type, building size, and building type. Access to and around structures would meet OCFA and CFC requirements. DEIR Figure 4.8-3, Fire Master Plan, demonstrates compliance with all codes and other regulations governing water availability for firefighting and emergency access to the Project site and structures. Compliance with OCFA requirements would ensure adequate provision of resources such as access, water mains, fire flows, and fire hydrants. (DEIR, p. 4.13-9)
In order to ensure adequate levels of fire protection service within the City of Alamitos, OCFA typically enters into a Secured Fire Protection Agreement with private developers. As a condition of approval, the Project Applicant is required to enter into a Secured Fire Protection Agreement to provide for fair-share funding of capital improvements necessary to establish adequate fire protection facilities

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and equipment, and/or personnel. OCFA has not indicated the need for a new fire station or expansion of existing facilities due to the Project. The Secured Fire Protection Agreement 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. (DEIR, p. 4.13-9) Because the Project does not include construction of new fire station facilities and does not generate a need for additional facilities, Project-related impacts to fire protection services would be less than significant and no mitigation is required. (DEIR, p. 4.13-9) Police Protection Services
Buildout of the Project would increase demands for police protection services in the City. 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. (DEIR, p. 4.13-10)
The 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. Implementation of the Project would result in an increase in calls for service; however, Los Alamitos Police Department has indicated that this increase would not adversely impact Los Alamitos Police Department’s existing resources. 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. (DEIR, p. 4.13-10)
Moreover, Project development would result in increased property 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. (DEIR, p. 4.13-10)
School Services
Project buildout would allow for up to 246 dwelling units, which would result in a population increase of approximately 647 residents. The population would lead to an increase in student population, which in turn may create additional demand for Los Alamitos Unified School District (LAUSD) service and facilities. (DEIR, p. 4.13-10)

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Schools serving the Project site include Rossmoor Elementary School, McAuliffe Middle School, and Los Alamitos High School. Student generation rates are used by school districts to estimate the number of students generated by new development in order to determine whether or not existing school facilities would be adequate for future students. As shown in DEIR Table 4.13-4, Projected Student Populations, the Project would generate a total of 135 students (51 students in K-5, 33 students in grades 6-8, and 51 students in grades 9-12). (DEIR, p. 4.13-10) As shown in DEIR Table 4.13-5, Projected School Capacity at Project Buildout, there is adequate capacity to serve the students from the 6-8 and 9-12 grade levels. Based on current enrollment, there is a deficiency of 45 students at the K-5 grade level at Project buildout. However, the District currently has open enrollment which allows students to attend schools other than the school assigned based upon their area of residence. As shown in DEIR Table 4.13-5 there are four other K-5 elementary schools within a 2.5-mile radius of the Project site with a total excess capacity of 62 students and enough excess capacity to serve the Project generated 51 K-5 students. The projected student population is conservative because it represents a snapshot in time. It is unlikely that all students generated by the Project would occur at Project buildout but rather would fluctuate over the life of the Project. (DEIR, p. 4.13-11)
The Project would be required to pay development impact fees to LAUSD under SB 50 for the construction of new schools, which provides full and complete mitigation to school facilities.

Development impact fees currently charged by LAUSD for residential uses are $4.79 per sf. Although Project buildout would result in an increase of 135 students, the availability of schools in the area and the payment of impact fees in compliance with SB 50 would address any potential impacts. Therefore, based on the preceding, impacts from implementation of the Project on school services would be less than significant. No mitigation is required. (DEIR, pp. 4.13-11 to 4.13-12) Parks
As discussed in DEIR Section 4.14, Recreation, the additional dwelling units would result in an increase in the number of residents in the City, which could lead to an increase in demand for existing City parks and recreational facilities. Using a conservative figure, the City currently has a total of 58.44 acres of parkland. (DEIR, p. 4.13-12)
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). Additionally, as shown in DEIR Table 4.14-1, Existing Parks and Recreation Facilities, there are a total of 317.49 acres of parks, recreational facilities, and community centers throughout the City that would serve future Project residents. (DEIR, p. 4.13-12)
Development of the on-site open space and amenities have been evaluated throughout the DEIR as part of the Project. The Project would result in an increase in residents; however, the Project is not anticipated to increase the use of the existing parks such that substantial additional use or physical

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deterioration of the existing parks would occur or be accelerated. Based on the Project’s Parks Impact Analysis (Technical Appendix M of the DEIR), there is sufficient capacity at existing neighborhood parks to accommodate the Project residents. Moreover, the Project Applicant would be required pay in-lieu fees in accordance with the City’s park dedication requirements under LAMC Chapter 16.18, Dedication of Land for Park Facilities and Payment of In Lieu Fees. Therefore, impacts would be less than significant. Refer to DEIR Section 4.14, Recreation, for further discussion. (DEIR, p. 4.13-12) Other Public Facilities
Project buildout would increase population onsite by an estimated 647 residents, thus increasing demand for other public facilities, such as library services. Increased demands are expected to most affect the library facilities closest to the Project site – that is the Los Alamitos-Rossmoor Library.

According to the administrative manager of the Orange County Public Libraries (OCPL), it is anticipated that the increase in residents may impact service. With the current renovations at the library, however, OCPL does not expect Project buildout to require construction of new or expanded physical library facilities, the construction of which could cause a substantial adverse impact. Although future Project residents would be mainly served by the Los Alamitos-Rossmoor Library, they would have access to all libraries within OCPL’s system. Therefore, impacts to library services would be less than significant and no mitigation is required. (DEIR, p. 4.13-12)

3.15.2CUMULATIVE IMPACTS
Impact Statement: The Project would not result in cumulatively considerable impacts related to public services.
 Findings
Potential cumulative public services impacts of the Project are discussed in detail in Section 4.13.6 of the DEIR. The City finds that the development of the proposed Project would not result in significant cumulative impacts related to public services; therefore, no mitigation is required.  Substantial Evidence
This cumulative impact analysis considers development of the Project in conjunction with other development projects and planned development within the providers respective service areas.

Residential and employment population increases and associated increases in the demand for public services have been taken into account in long-range planning efforts on behalf of the City and the agencies providing public services to the area. (DEIR, pp. 4.13-12 to 4.13-13) Fire Protection Services
Future development projects within OCFA’s service area would be required to comply with CFC and OCFA regulations and standards to maintain adequate access within the Project site, which further ensures an adequate level of service for fire protection and emergency services to residents, workers, and visitors in the Project site. Future development projects are reviewed by the City and OCFA to ensure compliance with all applicable building code and other code requirements in effect at the time

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building permits are issued. Additionally, OCFA requires new development (over 50 units) to enter into a Secured Fire Protection Agreement to provide for fair-share funding of capital improvements, including facilities, equipment, and radio/communications systems. In order to maintain acceptable service ratios, OCFA uses a fair share approach to mitigate fire service response impacts and facility/equipment needs. Secured Fire Protection Agreements with future development would ensure that responses times and service ratios are met due to the implementation of cumulative development within its service area and facilities are upgraded as needed. Similar to the Project, future cumulative development projects would result in increased property and sales tax revenue, which would provide additional funding for any capital improvements necessary to maintain adequate fire protection facilities, equipment, and/or personnel. By maintaining a consistent level of service through expansion of facility improvements, OCFA would be able to ensure that its performance objectives are consistently met. The Project’s increased demand for fire protection services, in conjunction with the increased demand for cumulative development pursuant to the City’s General Plan, would not result in significant cumulative impacts. (DEIR, p. 4.13-13)
Police Protection Services
Local population growth would result in an increased demand for public services and facilities, including law enforcement. Service providers would continue to evaluate levels of service and potential funding sources to meet demand. The City performs long-range planning for the provisions of public services and facilities based on its growth projections, which are revised over time and includes areas within the City’s sphere of influence. Through assessments of the City’s capital improvement needs and annual budget review process, police department needs are assessed, and budget allocations are revised accordingly to ensure that adequate levels of police services, including police protection facilities, equipment, and/or personnel, are maintained throughout the City. (DEIR, p. 4.13-13) The existing resources would be adequate to meet the additional demands generated by any known cumulative developments in addition to the Project (Claborn, 2024). Responses times and service ratios would be met and would not require the construction of new facilities. Increased property and sales tax from future new developments would provide funding for any capital improvements necessary to maintain adequate police protection facilities, equipment, and/or personnel. By maintaining a consistent level of service through expansion or facility improvements, Los Alamitos Police Department would be able to ensure that its performance objectives are consistently met. Furthermore, individual development projects pursuant to the City’s General Plan would be reviewed by the City and would be required to comply with the requirements in effect at the time building permits are issued.

Therefore, the demand for police services would not be adversely affected by the Project in conjunction with cumulative development pursuant to the City’s General Plan. No significant cumulative impacts related to police services are anticipated. (DEIR, pp. 4.13-13 to 4.13-14) School Services
Cumulative development in the LAUSD service area would increase the student population in LAUSD schools. As shown in DEIR Table 4.12-6, Cumulative Projects Population, Housing, and Employment Growth Trends in Los Alamitos, the projected population of the City at Project buildout, combined

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with related projects in the City, would be 12,922 by 2027, an increase of 1,049 residents over existing.

Based on an average student generation factor of 0.7 student per dwelling unit, the cumulative development, including the Project, would generate a total of approximately 734 students. Based on student enrollment of LAUSD schools, enrollment has decreased by approximately 970 students from 2016 to 2023 (see DEIR Table 4.13-2). Therefore, there is sufficient capacity within LAUSD schools to serve the Project and cumulative development. (DEIR, p. 4.13-14) The related projects (see DEIR Section 4.0, Environmental Analysis, for the related projects list), would result in an increase of 107 multifamily residential units. Based on the student rates in DEIR Table

4.13-4, the related projects would generate a total of 21 students. When combined with the Project’s projected 135 students, a total of 156 students would be generated. As shown in DEIR Table 4.13-6, Projected Cumulative Student Populations, there is adequate capacity to serve the students at all grade levels. Per discussion with LAUSD, capital improvements, including upgrades or the replacement of existing facilities with new facilities for their continued long-term use, are necessary to adequately serve future enrollment growth at all school levels. With proper planning and appropriate resources, LAUSD will be able to serve all students generated from future cumulative development. (DEIR, p.

4.13-14)
While there is currently available capacity at all grade levels, the cumulative effect of additional projects may increase enrollment beyond capacity. However, the capacity would be mitigated by applying SB 50 developer fees to accommodate new growth. In accordance with SB 50, the State Legislature provided authority for school districts to assess impact fees for both residential and nonresidential development projects to provide these resources. The fees, as authorized under Education Code Section 17620(a) and Government Code Section 65995(b), are collected by municipalities at the time building permits are issued and conveyed to the affected school district in accordance with a defined fee structure, and the payment of these fees constitutes full mitigation for the impacts generated by new development, per Government Code Section 65995. The Project and cumulative development must pay appropriate impact fees. Implementation of the Project in conjunction with other cumulative development would not result in a cumulative impact to school services. (DEIR, pp. 4.13-14 to 4.13-15)
Parks
As discussed in DEIR Section 4.14, Recreation, cumulative development will increase the demand in parks and recreational facilities. Recreational needs of future residents of the Project would add to citywide and regional demand for park and recreational facilities. As discussed in DEIR Section 4.14, Recreation, Project impacts to recreation would be less than significant. As shown in DEIR Table 4.14- 1, there is a total of 317.49 acres of park and recreation facilities in Los Alamitos and 35.05 acres of park and recreational facilities in Rossmoor, for a total of 389.02 acres of park and recreational facilities in the City and its Sphere of Influence (SOI). Pursuant to the City’s General Plan Update EIR, buildout of the General Plan (14,204 residents in the City and 10,540 residents in Rossmoor) would be accommodated by the existing parkland in the City and its SOI and no significant impacts would occur related to the physical deterioration of recreational facilities. Therefore, with the increase of projected population in 2027 at Project buildout, there is sufficient parkland and recreational facilities to serve

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City residents. The Project would not cumulatively contribute to deterioration of recreational facilities or the construction of recreational facilities which might have an adverse physical effect on the environment. (DEIR, p. 4.13-15)
Cumulative development projects would be required to comply with all applicable existing regulations, procedures, and policies that are intended to address impacts to park and recreation facilities. For example, per the City’s park dedication requirements under LAMC Chapter 16.18, Dedication of Land for Park Facilities and Payment of In Lieu Fees, all new residential development is required either to dedicate parkland or pay park facilities impact fees to offset the cost to expand or construct new park and recreational space and facilities to adequately serve the City’s growing population. Therefore, cumulative impacts related to park and recreational space and facilities would be less than significant. (DEIR, p. 4.13-15)
Other Public Facilities
Cumulative population growth within the service area as a result of the cumulative projects will likely increase the demand on other public facilities, such as library services. Similar to the Project, future residents of development projects within the City may visit the Los Alamitos-Rossmoor Library.

However, future residents would have access to all 32 OCPL branch libraries, online resources, and interlibrary loans. Therefore, library capacity would not be significantly impacted, and cumulative Project impacts would be less than significant. (DEIR, p. 4.13-15)

3.16 RECREATION
Project impacts for Recreation Thresholds a and b do not result in significant impacts and findings are discussed below.

3.16.1THRESHOLD A
Impact Statement: The Project would not increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated.
 Findings
Potential impacts of the Project related to Threshold a are discussed in Section 4.14.5 of the DEIR.

The City finds that the development of the proposed Project will not result in significant impacts related to Threshold a; therefore, no mitigation is required.
 Substantial Evidence
The Project includes a 246-unit residential development on an approximately 12.3-acre lot, which would increase housing capacity and increase population growth in the City of Los Alamitos. The increase of 246 dwelling units would result in a population growth of approximately 647 residents. (DEIR, p. 4.14-8)

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There is a total of 316.83 acres of park and recreation facilities in Los Alamitos and 35.05 acres of park and recreational facilities in Rossmoor, for a total of 351.8 acres to meet the recreational needs of the City’s residents. (DEIR, p. 4.14-8)
As shown in DEIR Figure 3-12, Open Space Plan, the Project would provide a total of 58,027 square feet (sf) or 1.33 acres of open space in the Project site, including 16,508 sf of usable common open space, 41,519 sf of private open space (homeowner maintained). The usable common open space areas would include amenities such as a tot-lot with rubberized play surface, shade surface with BBQ Island and dining furniture, lawn area with cornhole, ping pong table, and lounge seating with fire-pit. There are also 4,620 sf of multifamily private decks and 5,181 sf of townhomes private decks that would be provided onsite. The Project has been designed with these enhanced recreational amenities to meet the needs of its future residents. (DEIR, p. 4.14-8)
Although the designed neighborhood open space areas are anticipated to meet many of the park and recreation needs of Project residents, Project residents are also anticipated to utilize existing off-site park and recreation facilities in the City of Los Alamitos and nearby Rossmoor and City of Seal Beach Park system. Future residents of the Project site would also have access to (within walking distance) the following public park and recreational facilities, which comprise just over 14 acres of usable parkland and open space:
• Arbor Park, located directly north of the Project site, includes baseball fields leased by LAYB within its approximately 9.60-acre site.
• Arbor Dog Park, located directly north of the Project site, includes a dog park that is currently leased by the City of Seal Beach from the JFTB for its residents within its approximately 1.40-acre site.
• Orville Lewis Park, located approximately 1 mile northwest of the Project site, includes a grass area, baseball backstop, basketball court, play area, barbecue, picnic shelter and tables, and drinking fountain within its approximately 1.65-acre site. (DEIR, pp. 4.14-8 to

4.14-9)
• Heather Park, located approximately 350 feet southwest of the Project site, includes two lit tennis courts, one tot lot/play structure, one swing set, and four picnic tables within its approximately 1.6-acre site. (DEIR, p. 4.14-9)
The Project also includes a dedication or easement for the northerly 10 feet strip of land abutting Arbor Park and Arbor Dog Park, which comprises an area of approximately 10,000 sf of the Project site. (DEIR, p. 4.14-9)
If the Project were to generate park visitors that exceed its carrying capacity, it could result in additional maintenance requirements or physical deterioration of existing parks. Based on the Project’s Parks Impact Analysis (Technical Appendix M of the DEIR), it is anticipated that a negligible amount of

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Project residents will regularly visit parks in close proximity to the Project site specifically, Arbor Park, Arbor Dog Park, and Heather Park. Specifically, a total of 178 Project residents would visit the designed neighborhood open spaces within the Project site and 131 Project residents would visit the Arbor Park, Arbor Dog Park, and Heather Park as the parks they visit most often (Technical Appendix M of the DEIR). Project residents would 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 the DEIR). Project residents would visit (frequent) Arbor Dog Park at least 147 times at least once per week. (see Table 4, Technical Appendix M of the DEIR). (DEIR, p. 4.14-9) The carrying capacity of the Arbor Park and Heather Park would be 337 visitors and there is no calculation for carrying capacity for Arbor Dog Park since dog parks do not have a calculation for carrying capacity unlike parks. Because the projected number of Project visitors to these parks are well within the carrying capacity, 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 capacity and existing maintenance and usage of existing parks, and the estimated 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. (DEIR, p. 4.14-9) The Project Applicant would be required pay in-lieu fees in accordance with the City’s park dedication requirements under Chapter 16.18 (Dedication of Land for Park Facilities and Payment of In Lieu Fees) of the City of Los Alamitos Municipal Code. Therefore, implementation of the Project would not result in significant impacts relating to the physical deterioration of recreational facilities and impacts would be less than significant. (DEIR, pp. 4.14-9 to 4.14-10)

3.16.2THRESHOLD B
Impact Statement: The Project would not include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment.  Findings
Potential impacts of the Project related to Threshold b are discussed in Section 4.14.5 of the DEIR.

The City finds that the development of the proposed Project will not result in significant impacts related to Threshold b; therefore, no mitigation is required.
 Substantial Evidence
The Project would include a variety of common open space amenities and private open space areas.

The construction of these recreational facilities would occur within the boundaries of the Project site and would be constructed as part of the proposed Project. The Project’s construction impacts are analyzed throughout the DEIR and mitigation is incorporated where necessary. As concluded in the DEIR, the Project’s construction impacts would be less than significant, in some cases with the

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implementation of mitigation. Therefore, impacts associated with the Project’s on-site recreational facilities would be less than significant. (DEIR, p. 4.14-10) Furthermore, per the analysis provided above under Threshold a, development that would be accommodated under the Project would not require the construction of new or the expansion of existing City parks and recreational facilities. Additionally, the Project does not propose to expand any existing recreational facilities. Therefore, implementation of the Project would not result in significant impacts relating to new and/or expanded park and recreational facilities. No mitigation is required. (DEIR, p.

4.14-10)

3.16.3CUMULATIVE IMPACTS
Impact Statement: The Project would not result in cumulatively considerable impacts related to recreation.
 Findings
Potential cumulative recreation impacts of the Project are discussed in detail in Section 4.14.6 of the DEIR. The City finds that the development of the proposed Project would not result in significant cumulative impacts related to recreation; therefore, no mitigation is required.  Substantial Evidence
This cumulative impact analysis considers development of the proposed Project in conjunction with other development projects and planned development in the City. (DEIR, p. 4.14-10) The recreational needs of future residents of the proposed Project would add to citywide and regional demand for park and recreational facilities, which could contribute to a deterioration of recreational facilities. As shown in DEIR Table 4.14-1, there is a total of 316.83 acres of park and recreation facilities in Los Alamitos and 35.05 acres of park and recreational facilities in Rossmoor, for a total of 351.88 acres of park and recreational facilities in the City and its SOI available to meet the needs of City residents. To determine the cumulative public park and recreational impacts, citywide growth forecasts were considered. As shown in DEIR Table 4.12-6, Cumulative Projects Population, Housing, and Employment Growth Trends in Los Alamitos, the projected population at Project buildout, combined with related projects in the City, would be 13,806 by 2027. Pursuant to the City’s General Plan Update EIR, Table 5.10-2, the buildout of the General Plan (14,204 residents in the City and 10,540 residents in Rossmoor) would be accommodated by the existing parkland in the City and its SOI and no significant impacts would occur related to the physical deterioration of recreational facilities. Therefore, with the increase of projected population in at Project buildout, there is sufficient parkland and recreational facilities to service city residents. The Project would not cumulatively contribute to deterioration of recreational facilities or the construction of recreational facilities which might have an adverse physical effect on the environment. (DEIR, p. 4.14-10) Cumulative development projects would be required to comply with all applicable existing regulations, procedures, and policies that are intended to address impacts to park and recreation facilities. For

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example, per the City’s park dedication requirements under Chapter 16.18 (Dedication of Land for Park Facilities and Payment of In Lieu Fees) of the City of Los Alamitos Municipal Code, all new residential development is required either to dedicate parkland or pay park facilities impact fees to offset the cost to expand or construct new park and recreational space and facilities to adequately serve the City’s growing population. Therefore, cumulative impacts related to park and recreational space and facilities would be less than significant. (DEIR, p. 4.14-11)

3.17 TRANSPORTATION
Project impacts for CEQA Transportation Thresholds a, c, and d do not result in significant impacts and findings are discussed below.

3.17.1THRESHOLD A
Impact Statement: The Project would not conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities.  Findings
Potential impacts of the Project related to Threshold a are discussed in detail in Section 4.15.5 of the DEIR. The City finds that the development of the proposed Project will not result in significant impacts related to Threshold a; therefore, no mitigation is required.  Substantial Evidence
The Project’s consistency with the City’s General Plan Mobility and Circulation is discussed in DEIR Table 4.15-1, Consistency with the General Plan Mobility and Circulation Element. As presented therein, the Project would not conflict with applicable General Plan goals and policies. In addition, the Project’s consistency with the SCAG’s Connect SoCal is discussed in DEIR Section 4.10, Land Use and Planning and no conflicts were identified. The Project would not conflict with any programs, plans, ordinances, or policies addressing the circulation system including transit, roadway, bicycle, and pedestrian facilities. Impacts would be less than significant, and no mitigation is required. (DEIR, p.

4.15-9)

3.17.2THRESHOLD C
Impact Statement: The Project would not substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment).  Findings
Potential impacts of the Project related to Threshold c are discussed in detail in Section 4.15.5 of the DEIR. The City finds that the development of the proposed Project will not result in significant impacts related to Threshold c; therefore, no mitigation is required.

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 Substantial Evidence
During construction, frontage improvements including median improvements, sidewalks, driveway modifications needed to accommodate site access, and landscaping improvements would be constructed in accordance with City standards. Lane closures that may be required for median improvements would be temporary and require a permit and compliance with Los Alamitos Municipal Code (LAMC) 12.08.200, Safety precautions–Obstruction of traffic. This would ensure safe crossing and access for all vehicle and pedestrians at all times. Therefore, the Project would not substantially increase hazards due to a geometric design feature during construction activities. (DEIR, p. 4.15-16) There are no incompatible uses such as farm equipment existing or proposed on the Project site.

Vehicular access to the Project site would be provided via two driveways along the site’s southern boundary on Lampson Avenue. One driveway would be located at the west side which would be the primary apartment entry. The second driveway, which would be the primary neighborhood entry, would be located in the central portion of the site along Lampson Avenue. In addition, the Project would include replacement of the existing median curb/landscape on Lampson Avenue with new median and landscape. (DEIR, p. 4.15-16)
A queuing analysis was performed for the Project driveways on Lampson Avenue under General Plan Buildout with Project traffic conditions in order to ensure that there is adequate and available stacking distance at peak hours and the Project would not create a safety hazard. Table 1-4 of the Project’s Traffic Analysis (DEIR Technical Appendix N1) presents the queuing analysis summary for the General Plan Buildout with Project traffic conditions. The traffic modeling and signal timing optimization software package SimTraffic has been utilized to assess the queues. SimTraffic is designed to model networks of signalized and unsignalized intersections, with the primary purpose of checking and finetuning signal operations. SimTraffic uses the input parameters from Synchro to generate random simulations. These random simulations generated by SimTraffic have been utilized to determine the 95th percentile queue lengths observed for each applicable turn lane. The SimTraffic simulation has been recorded 5 times, during the weekday AM and PM peak hours, and has been seeded for 15- minute periods with 60-minute recording intervals. As a result, no site adjacent queues are anticipated at both driveways under these traffic conditions. The proposed eastbound left turn lane with a minimum of 150-feet of storage at the second driveway (primary neighborhood entry) would sufficiently accommodate the 95th percentile peak hour queues. (DEIR, pp. 4.15-16 to 4.15-17) Additionally, there are no sharp curves or dangerous intersections proposed that would increase hazards due to geometric design features. The Project would not substantially increase hazards due to a geometric design feature or incompatible uses. Impacts would be less than significant, and no mitigation is required. (DEIR, p. 4.15-17)
A. Safey Evaluation
A Safety Evaluation was prepared for the Project (see Attachment H of the Final EIR) which analyzed collision data, pedestrian and bicycle safety, and site access management (e.g. driveway sight distance,

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driveway spacing, project access and queuing, multimodal conflict points, and pedestrian/bicycle connections).

The Project’s Traffic Analysis (see Attachment G of the 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. 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.

Collision
As discussed in the Safety Evaluation (see Attachment H of the 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.

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 collisions 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

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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, 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.

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 the 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 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.

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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.

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 along Lampson Avenue.

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.

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 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.

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

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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.

3.17.3THRESHOLD D
Impact Statement: The Project would not result in inadequate emergency access.  Findings
Potential impacts of the Project related to Threshold d are discussed in Section 4.15.5 of the DEIR.

The City finds that the development of the proposed Project will not result in significant impacts related to Threshold d; therefore, no mitigation is required.
 Substantial Evidence
As discussed in DEIR Section 3.0, Project Description, the Project includes a fire master plan 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 Project would also 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 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 DEIR Figure 4.8-3, Fire Master Plan). The Fire Master Plan demonstrates the Project’s compliance with the California Fire and Building Codes and other regulations emergency access to the Project site, including but not limited to 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 requirement based upon the tenant type, building size, and building type. Access to and around structures would meet OCFA and

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CFC requirements. Furthermore, OCFA submitted conditions of approval that the Project must comply with, ensuring implementation of OCFA standard conditions. 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. (DEIR, p. 4.15-17)
Therefore, the Project would not result in inadequate emergency access and impacts would be less than significant. No mitigation is required. (DEIR, p. 4.15-18)

3.17.4CUMULATIVE IMPACTS
Impact Statement: The Project would not result in a cumulatively considerable impact related to transportation (conflict with a program, plan, ordinance or policy addressing the circulation system; increase hazards; inadequate emergency access).
 Findings
Potential cumulative transportation impacts of the Project related to conflicts with a program, plan, ordinance or policy addressing the circulation system; increase in hazards; and inadequate emergency access are discussed in detail in Section 4.15.6 of the DEIR. The City finds that the development of the proposed Project would not result in significant cumulative impacts related to these topics; therefore, no mitigation is required.
 Substantial Evidence
This cumulative impact analysis considers development of the proposed Project in conjunction with other development projects and planned development. The analysis under Threshold a indicates that the Project would not conflict with relevant programs, plans, and policies addressing the circulation system. Each related project would also be required to comply with all applicable relevant programs, plans, and policies. Therefore, no cumulative impact would occur. (DEIR, p. 4.15-18) As discussed under Threshold c and d, implementation of the Project would not result in hazardous conditions or result in inadequate emergency access. Impacts on a cumulative level would also be less than significant. (DEIR, p. 4.15-18)

3.18 TRIBAL CULTURAL RESOURCES
Project impacts for Tribal Cultural Resources Cumulative Impacts do not result in significant impacts and findings are discussed below.

3.18.1CUMULATIVE IMPACT
Impact Statement: The Project does not have the potential to result in cumulative impacts to tribal cultural resources.

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 Finding
Potential cumulative impacts of the Project related to tribal cultural resources are discussed in detail in Section 4.16.6 of the DEIR. The City finds that the development of the proposed Project would not result in significant cumulative impacts related to tribal cultural resources; therefore, no mitigation is required.
 Substantial Evidence
The potential for Project construction to result in cumulatively-considerable impacts to tribal, religious, and cultural resources were analyzed in conjunction with other projects other projects located in the immediate vicinity of the Project site. Impacts to previously undiscovered subsurface tribal cultural resources are typically site specific from ground disturbing activities and generally do not combine to result in cumulative impacts unless resources are identified immediately adjacent to the Project site.

Nonetheless, the potential exists that a significant tribal cultural resource could be discovered during grading into native soils. However, there are no related projects in the vicinity that would affect tribal cultural resources in combination with Project implementation. Therefore, cumulative impacts to archaeological resources would be less than significant. (DEIR, p. 4.16-8)

3.19 UTILITIES AND SERVICE SYSTEMS
Project impacts for Utilities and Service Systems Thresholds a through e do not result in significant impacts and findings are discussed below.

3.19.1THRESHOLD A
Impact Statement: The Project would not require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects.
 Findings
Potential impacts of the Project related to Threshold a are discussed in Section 4.17.5 of the DEIR.

The City finds that the development of the proposed Project will not result in significant impacts related to Threshold a; therefore, no mitigation is required.
 Substantial Evidence
Water Facilities
Water service to the Project site would be provided by Golden State Water Company (GSWC). Water demand associated with the Project would consist of interior plumbing devices (i.e., showers, sinks, toilets, faucets), outdoor landscape irrigation, washers, and other uses similar to that of a residential development. Water supply is discussed in detail under Threshold b, below. Based on the water supplies available and the estimated water demand, there are sufficient water supplies available to serve the Project during average, single dry, and multiple dry years. The Project would not require the

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construction of new or expanded water facilities. The Project would not require the relocation of water facilities. The Project would include the installation of new water lines within the Project site, connecting to existing facilities within Lampson Avenue. The Project would include a 1,200-foot 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. These connections would be part of the Project’s construction phase, the impacts of which are evaluated throughout the DEIR. As that evaluation demonstrates, the construction of the Project’s water lines necessary to serve the Project would not result in any significant physical effects on the environment. Impacts would be less-than-significant, and no mitigation is required. (DEIR, p.

4.17-13)
Wastewater and Wastewater Treatment Facilities
Although the Project site is located in the City of Los Alamitos, wastewater service would be served by the City of Seal Beach. Discussion of the sewer system and its capacity is discussed under Threshold c, below. The Project generated wastewater would be well within the capacity of Reclamation Plant No. 2. and would not require Orange County Sanitation District (OCSD) to build new or expanded wastewater treatment facilities. (DEIR, p. 4.17-13)
The Project would include the installation of an on-site lift station and force main at the southeast corner of the Project site. The Project would include sewer lines within the Project site, connecting to existing facilities within Lampson Avenue. These connections would be part of the Project’s construction phase, the impacts of which are evaluated throughout the DEIR. As that evaluation demonstrates, the construction of the Project’s sewer lines necessary to serve the Project would not result in any significant physical effects on the environment. Impacts would be less than significant and no mitigation is required. (DEIR, pp. 4.17-13 to 4.17-14) Stormwater Drainage Facilities
As discussed in DEIR Section 4.9, Hydrology and Water Quality, the Project would increase the amount of impervious surface within the Project site. Two stormwater drainage facility plans have been proposed to accommodate stormwater runoff associated with the increase in this amount of impervious surface: an on-site storm drain facilities and an alternate off-site storm drain facilities. (DEIR, p. 4.17-14)
On-Site Storm Drain Facilities
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 bio-filtration devices or catch basin inlets on-site for water quality treatment. The bio-filtration devices 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 would convey flows into the existing storm drain pipe at the southwest corner of the site to match the existing flow pattern. The combined, total 100-year peak flow rate for the Project site is approximately 44.31 cfs under the proposed conditions, which would be a higher

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peak runoff flowrate than the existing condition of the site of 40.28 cfs. DEIR 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 headwall on the southwest corner of the Project site. (DEIR, p. 4.17-14)
Alternate Off-Site Storm Drain Facilities
In the event the proposed route described above is not available, an alternate treatment of stormwater runoff for the Project would be conveyance to offsite storm drain facilities. DEIR Figure 4.9-5, Proposed Alternate Conditions Hydrology Map illustrates the post-development drainage conditions for this drainage and detention alternate. From the detention system, a stormwater sump pump located in the southwest corner of the site will convey flows onto Lampson Avenue through 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 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 would continue pumping to Lampson Avenue normally. (DEIR, p. 4.17-14)
With respect to both of these facility designs, no new or expanded off-site storm drain facilities beyond those proposed as part of the Project are required to accommodate stormwater runoff from the Project site. The impacts of these designs are evaluated throughout the DEIR. As that evaluation demonstrates, the construction of the Project’s storm drain facilities necessary to serve the Project would not result in any significant physical effects on the environment. Impacts would be less-than-significant, and no mitigation is required. (DEIR, pp. 4.17-14 to 4.17-15)
Dry Utilities
The Project also would involve utility connections to provide electric power and telecommunications services to the Project site. No natural gas would be used as a result of the Project (PDF GHG-2), and as such, use of natural gas is not considered in the EIR analysis. The Project would be served in accordance with the CPUC and Federal Energy Regulatory Commission tariffs. As discussed in DEIR Section 4.5, Energy, Project operational energy demands are estimated to be 98,388 kWh/year of electricity which would be supplied by SCE. The Project does not propose uses that are inherently energy intensive and the energy demands in total would be comparable to other residential uses of similar scale and configuration. No new or expanded off-site dry utilities are required to serve the Project, and therefore there would be no impact associated with any such facilities that could cause significant environmental effects. (DEIR, p. 4.17-15)
The installation of the proposed on-site infrastructure improvements would result in physical environmental impacts; however, these impacts have been included in the analyses of constructionrelated effects presented throughout the DEIR, (e.g., air quality impacts, impacts to biological and cultural resources, water quality impacts, and noise and vibration impacts, etc.). Any applicable Project-specific mitigation measures for construction identified for each topical issue would address potential significant impacts associated with construction and installation of utilities. Therefore,

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through consistent implementation of a variety of measures related to construction impacts, no additional impacts related to construction and operation of utility systems would occur. No mitigation is required. (DEIR, p. 4.17-15)

3.19.2THRESHOLD B
Impact Statement: The Project would have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years.  Findings
Potential impacts of the Project related to Threshold b are discussed in Section 4.17.5 of the DEIR.

The City finds that the development of the proposed Project will not result in significant impacts related to Threshold b; therefore, no mitigation is required.
 Substantial Evidence
As previously discussed, GSWC would provide potable water service to the Project site. According to GSWC’s 2020 UWMP, the 2016-2020 average unit demand factors for single family and multi-family are 0.26 and 2.23 acre-feet of water per year (AFY)/Connection, respectively (GSWC, 2021). The Project includes 55 single family detached homes, 114 townhomes, and 76 for rent affordable multifamily apartment units (as well as one market rate manager’s apartment unit) within three 3-story structures. The total water demand for the Project would be 50.63 AFY, which is comprised of 43.94 AFY for single family and 6.69 AFY for multi-family. (DEIR, p. 4.17-15) DEIR Table 4.17-1, Total Supplies Available to GSWC West Orange through 2045 (AFY), presents the supplies available to the West Orange service area through 2045 according to the most recent UWMP from GSWC (adopted July 15, 2021). DEIR Table 4.17-2, GSWC West Orange Projected Water Demands through 2045, presents the projected water use through 2045 for the West Orange service area. DEIR Table 4.17-3, GSWC West Orange Projected Water Supply and Demand through 2024, presents the projected water supply and demand through 2045 for the West Orange service area. GSWC West Orange service area will only access enough water to meet its needs in any given year.

Accordingly, although some of the supplies available to GSWC West Orange service area are shared among three GSWC service areas, GSWC West Orange will not acquire the additional supplies unless they are needed as part of GSWC’s regional water management among the three service areas. As such, GSWC West Orange will acquire the total projected supplies as shown in DEIR Table 4.17-2. (DEIR, p. 4.17-16)
Given the difference between GSWC’s projected water demand through 2045 and the total water supplies available through 2045, GSWC West Orange’s waters supplies would be sufficient for the Project’s estimated water demand of 50.63 AFY in normal, single dry years, and five consecutive dry year conditions through 2045. GSWC West Orange service area will only access enough water to meet its needs in any given year. The GSWC 2020 UWMP concluded that it has reliable supplies to meet its retail customer demands in normal, single dry years, and five consecutive dry year conditions through 2045. Groundwater, imported water from MWDOC, and the small amount of recycled water delivered within the service area by the City of Cerritos are all resilient during dry conditions and

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GSWC West Orange is therefore not faced with shortages during normal or dry years. (DEIR, p. 4.17- 17)
Based on the water supplies available and the estimated water demand, there are sufficient water supplies available to serve the Project during average, single dry, and multiple dry years. Additionally, 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). Accordingly, there would be sufficient water supplies available to serve the Project and impacts would be less than significant. No mitigation is required. (DEIR, p. 4.17-17)

3.19.3THRESHOLD C
Impact Statement: The Project would result in a determination by the wastewater treatment provider which serves or may serve the Project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments.  Findings
Potential impacts of the Project related to Threshold c are discussed in Section 4.17.5 of the DEIR.

The City finds that the development of the proposed Project will not result in significant impacts related to Threshold c; therefore, no mitigation is required.
 Substantial Evidence
Wastewater Facilities
Although the Project site is in the City of Los Alamitos, sanitary sewer services are currently provided by and will be provided by the City of Seal Beach. Per the City of Seal Beach Sewer Master Plan 2018, the City provides sewer service throughout the City in a service area that collects and conveys wastewater from the service area for treatment by the OCSD. (DEIR, p. 4.17-17) A Sanitary Sewer Analysis (Technical Appendix O of the DEIR) was prepared for the Project and investigates the sewer discharge route for the proposed development to the existing sewer mains of three manholes: 1) Basswood and Aster Street (Manhole A-16); 2) Candleberry Avenue and Aster Street (Manhole A-21); and 3) Elder Avenue (Manhole A-25). (DEIR, p. 4.17-17)

1. Basswood and Aster Street (Manhole A-16)
The existing sewer pipes were analyzed per City of Seal Beach Sewer Master Plan 2018 Table ES-1 for a maximum design depth at half-full for pipe sized at 15” or under. Based on the monitoring data collected, existing peak flow for Manhole A-16 at the northern inlet was measured at 0.391 million gallons per day (MGD) (0.6050 cfs), with a max peak depth flow of 4.52 inches (Flow depth to pipe diameter ratio (d/D) = 0.3013). The data shows that the 15” sewer pipe system capacity is capable of maintaining an adequate flow well below 50% of its flow depth capacity with the additional flow from the proposed development. According to the City of Seal Beach Sewer Master Plan 2018, the design

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and analysis of collection system pipes is typically based upon the depth of flow to diameter ratio. All new pipe should be designed with a flow depth to pipe diameter ratio less than or equal to 0.5 for 15” and smaller pipes and 0.64 for 18” and larger pipes. The remaining pipeline capacity is reserved for wet weather related inflow and infiltration into the system. Additionally, the area above the water surface helps to keep the sewage aerated, preventing septic conditions, and resulting odors. The peak wet weather depth of flow to pipe diameter ratio should not exceed 0.80. (DEIR, pp. 4.17-17 – 4.17- 18)
Based on the proposed development, the Project is estimated to result in a total peak flow output of 49,468 gallons per day (GPD) (0.0765 cfs) of effluent. After applying peak dry and wet weather factors, it was determined there would be 0.2348 cfs of effluent generated by the Project. The Project site would contribute an additional 0.0824 cfs to the trunk main. This would increase the flow depth-to-pipe diameter ratio to become 0.3216, an approximately 6.30 percent increase, which remains below the flow depth to pipe diameter ratio criteria and indicates that the proposed development would not have a significant impact on wastewater capacity. (DEIR, p. 4.17-18)

2. Candleberry Avenue and Aster Street (Manhole A-21)
The existing sewer pipes were analyzed per City of Seal Beach Sewer Master Plan 2018 Table ES-1, for a maximum design depth at half-full for pipe sized at 15” or under and pipes measured 18” or over with a d/D of 0.64. Since this is an elliptical sewer main sized at 17.88” x 17” (H x W), it was treated with the flow depth to pipe diameter ratio design criteria of 0.5 (half full). Based on the monitoring data collected, existing peak flow for Manhole A-21 at the northern inlet was measured at 0.377 MGD (0.5833 cfs), with a max peak depth flow of 5.84 inches (flow depth to pipe diameter ratio (d/D) =

0.3266). The data shows that the sewer pipe system capacity is capable of maintaining an adequate flow well below 50% of its flow depth capacity with the additional flow from the proposed development. The Project is estimated to be a total peak flow output of 49,468 GPD (0.0765 cfs) of effluent. After applying peak dry and wet weather factors, it was determined there would be 0.2348 cfs of effluent from the Project site. The Project is estimated to be a total peak flow output of 49,468 GPD (0.0765 cfs) of effluent. After applying peak dry and wet weather factors, it was determined there would be 0.2348 cfs of effluent from the Project site. The Project site would contribute an additional

0.0824 cfs to the trunk main. This would increase the d/D to become 0.3684, approximately 11.34 percent increase, which remains below the flow depth to pipe diameter ratio criteria and indicates that the proposed development would not have a significant impact on capacity. (DEIR, p. 4.17-18)

3. Elder Avenue (Manhole A-25)
The existing sewer pipes were analyzed per City of Seal Beach Sewer Master Plan 2018 Table ES-1, for a maximum design depth at half-full for pipe sized at 15” or under. Based on the monitoring data collected, existing peak flow for Manhole A-25 at the northern inlet was measured at 0.249 MGD (0.3853 cfs), with a max peak depth flow of 4.75 inches (flow depth to pipe diameter ratio (d/D) =

0.3958). The data shows that the 12” sewer pipe system capacity is capable of maintaining an adequate flow well below 50% of its flow depth capacity with the additional flow from the proposed development. The Project is estimated to be a total peak flow output of 49,468 GPD (0.0765 cfs) of

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effluent. After applying peak dry and wet weather factors, it was determined there would be 0.2348 cfs of effluent from the project site. The Project site would contribute an additional 0.0824 cfs to the trunk main. This would increase the d/D to become 0.441, approximately 10.24 increase, which remains below the flow depth to pipe diameter ratio criteria and indicates that the proposed development would not have a significant impact on capacity. (DEIR, pp. 4.17-18 – 4.17-19) In summary, the results from the Sanitary Sewer Analysis (refer to Technical Appendix O of the DEIR) 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 significantly impact or exceed the existing sewer capacity in the public system, and that the existing sewer system has adequate capacity for the proposed development. Accordingly, impacts would be less than significant and no mitigation is required. (DEIR, p. 4.17-19)

4. Sanitary Sewer Update
A revised Sanitary Sewer Analysis (Attachment M of the FEIR) was prepared in response to comment from the City of Seal Beach. A Sewer Demand Memorandum (Attachment L of the FEIR) was prepared to address the updates in the sanitary sewer analysis and respond to comments on the DEIR related to the Old Ranch Country Club.

The City of Seal Beach’s updated Sewer Master Plan (September 2022) identified the sewer loads for potential development areas within the City of Seal Beach. Those sewer loads are summarized in Table 1 of that Sewer Master Plan. The Old Ranch Country Club is listed as Site B-5, and it is identified as comprising 150 acres, five of which are indicated as “redevelopment area,” with a potential for 120 dwelling units and a sewer load of 19,200 gallons per day (gpd).

Since 2022, the proposed development of the Old Ranch Country Club Project has been further refined, and as of January 2023 now includes more than the residential component identified in Table 1 of the Sewer Master Plan. Per the Initial Study dated February 7, 2023, prepared to support the Old Ranch Country Club Specific Plan, the anticipated redevelopment area has increased from 5 acres to approximately 35 acres over the existing site, and includes a 116-unit multi-family housing development, a 51-unit senior housing complex including an approximately 25,340 square foot medical office facility on the ground floor, a 150-key overnight accommodation, an approximately 2,650 square foot relocated maintenance facility, a parking structure, and a new clubhouse pool and associated structures (21,000 square feet) abutting the existing clubhouse.

This more refined development proposal for the Old Ranch Country Club project would result in an increase in the sewer demand by approximately 32,246 gpd, totaling 51,626 gpd (see Attachment L of the FEIR).

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The revised Sanitary Sewer Analysis, prepared in March 2024 (Attachment M of the FEIR), used sewer system model data provided by the City of Seal Beach (AKM’s City wide sewer study). The data was based on an area calculation method which indicated there are 16 sewer segments shown to have a d/D level above 0.5. Because the area calculation is used to calculate flows for large areas and is not necessarily representative of actual flows, actual monitored flows were determined and evaluated.

Using the actual monitored flows indicated that there are only 7 segments estimated to exceed the City's peak dry weather flows (PDWF) d/D criteria after the proposed project is implemented. The remaining capacity above a PDWF d/D of 0.50 is reserved for wet weather flows. Flows over the d/D criteria range from 0.51 to 0.55 and represent approximately 56% of the pipe’s flow capacity, which is well within the capacity of the downstream sewer lines.

No additional pipe segments in the AKM study were found to be undersized. The nine (9) segments that were found to be undersized in AKM’s study were determined to be acceptable after analysis using the actual monitored flows. The d/D levels are shown to be higher because the existing segments have flat slopes, ranging from 0.16% - 0.22%. However, the pipe size can handle proposed flow levels, and sewer pipe upgrades are not required.

To evaluate a potential increase in the flow depth to pipe diameter ratio (d/D) based on the increase in total demand associated with the further refined Old Ranch Country Club project and after taking into consideration the amount of sewer discharge associated with the Project, C&V Consulting, Inc. applied the increase in total demand from the further refined Old Ranch Country Club Project to manhole (MH) IDs B03-A14 and B01-A13 through B01-A02A, as shown in Attachment L of the FEIR. These manholes and their associated pipeline segments are located downstream of the three manholes that were monitored for the Project and as such include the upstream sewer flows anticipated by the Project and currently existing development. As shown in Attachment L of the FEIR, the overall d/D is anticipated to be less than 0.5 for the identified segments with the increased demand added to the system. This means that when the sewer flows from the further refined Old Ranch Country Club Project are added to the sewer flows from the Project based on the downstream monitored manhole flows, the depth of flow to pipe diameter ratio is less than 50%. This in turn means that even with the Old Ranch Country Club Project, the sewer pipe system capacity remains capable of maintaining an adequate flow well below 50% of its flow depth capacity. As such, adequate capacity exists to serve the Project’s projected demand in addition to the sewer pipe systems existing commitments, even after taking into account the further refined Old Ranch Country Club project. The anticipated d/D increase determined from the 4665 Lampson Avenue Project plus the Old Ranch Country Club Project is approximately

2.6-3.4%, which is considered negligible.

As a result, the proposed flows from the Project, in addition to the observed flows, create a proposed depth of flow that would not impact the existing surrounding sanitary sewer systems, and that the existing sewer system has adequate capacity for the proposed development. Accordingly, impacts would be less than significant and no mitigation is required.

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Wastewater Treatment
The existing residual capacity at OCSD Reclamation Plant No. 2, is approximately 105 mgd.

Conservatively assuming that Project generated wastewater would be 100 percent of total water demand, the Project would generate 45,200 gallons per day, which is well within the capacity of Reclamation Plant No. 2. Therefore, the Project would not require OCSD to build new or expanded wastewater treatment facilities, and impacts would be less than significant. No mitigation is required.

Moreover, Project generated wastewater would ultimately be treated at one or more of the OCSD wastewater treatment plants. Additionally, 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). This would result in a less than significant impact. (DEIR, p. 4.17-19)

3.19.4THRESHOLD D
Impact Statement: The Project would not generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals.
 Findings
Potential impacts of the Project related to Threshold d are discussed in Section 4.17.5 of the DEIR.

The City finds that the development of the proposed Project will not result in significant impacts related to Threshold d; therefore, no mitigation is required.
 Substantial Evidence
Solid waste from the City is transported to Frank R. Bowerman Sanitary Landfill in the City of Irvine and the Olinda Alpha Sanitary Landfill near the City of Brea. Both facilities are operated by Orange County Waste and Recycling. The Frank R. Bowerman Sanitary Landfill has a permitted disposal capacity of 11,500 tons per day with a remaining capacity of 205,000,000 cubic yards. The Olinda Alpha Landfill has a permitted disposal capacity of 8,000 tons per day with a remaining capacity of 17,500,000 cubic yards. (DEIR, p. 4.17-19)
Construction-Related Impacts
Waste generated during the construction phase of the Project would primarily consist of discarded materials from the construction of structures, common areas, infrastructure installation, and other Project-related construction activities. Based on the anticipated building square footage of 397,381 s.f. and the US EPA’s construction waste generation factor of 4.39 pounds (lbs) per sf for residential-uses, approximately 872 tons of waste would be generated during the building construction phase. The Project’s building construction is reasonably expected to occur over a period of approximately 1,031 days (see DEIR Table 3-4, Estimated Construction Schedule), which corresponds to approximately

0.85 tons of construction waste generated per day during the building construction phase. Additional waste would be expected from infrastructure installation and other Project-related construction activities. (DEIR, pp. 4.17-19 to 4.17-20)

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The two landfills that serve the Project site have a total remaining capacity of 222,500,000 cubic yards and a combined permitted disposal capacity of 19,500 tons per day. The estimated closing date of operation for the Frank R. Bowerman Landfill and the Olinda Alpha Landfill are 2053 and 2036, respectively. Based on the approximate construction waste generated per day, demolition and construction waste generated by the Project is not anticipated to cause these landfills to exceed their maximum permitted daily disposal volume. Furthermore, none of these regional landfill facilities are expected to reach their total maximum permitted disposal capacities during the Project’s construction period. In addition, the Project would be required to comply with LAMC Chapter 8.13, Construction and Demolition Waste, which requires the Project Applicant to divert a minimum of 50 percent of the construction and demolition debris resulting from the proposed development in compliance with State and local statutory goals and policies. (DEIR, p. 4.17-20) Operational-Related Impacts
The Project includes 55 single family detached homes, 114 townhomes, and 76 for rent affordable multi-family apartment units, as well as one market rate manager’s apartment unit.. Based on the single-family generation rate of 11.4 pounds per dwelling unit per day, the single family and townhome portion of the Project would generate approximately 1,926.6 pounds of solid waste per day (~0.96 tons per day). Based on the multifamily generation rate of 8.6 pounds per dwelling units per day, the multifamily portion of the Project would generate approximately 662.2 pounds of solid waste per day (~0.33 tons per day). The total solid waste generation of the Project is approximately 1.29 tons per day. (DEIR, p. 4.17-20)
As previously stated, the two landfills have a combined permitted disposal capacity of 19,500 tons per day. The Project’s estimated solid waste generation represents approximately 0.007% of the two landfills’ capacity and therefore, would not contribute significantly to both of the landfills’ daily capacity. Additionally, 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). Accordingly, impacts would be less than significant, and no mitigation is required. (DEIR, p. 4.17-20)

3.19.5THRESHOLD E
Impact Statement: The Project would comply with federal, State, and local management and reduction statutes and regulations related to solid waste.  Findings
Potential impacts of the Project related to Threshold e are discussed in detail in Section 4.17.5 of the DEIR. The City finds that the development of the proposed Project will not result in significant impacts related to Threshold e; therefore, no mitigation is required.  Substantial Evidence
Federal, State, and local statues and regulations regarding solid waste generation, transport, and disposal are intended to decrease solid waste generation through mandatory reductions in solid waste

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quantities (e.g., through recycling and composting of green waste) and the safe and efficient transport of solid waste. The Project would be required to coordinate with the City’s solid waste service provider, Universal Waste Systems Inc., to develop a collection program for recyclables, such as paper, plastics, glass, and aluminum, in accordance with local and State programs, including Assembly Bill (AB) 341, Mandatory Commercial Recycling, and the California Solid Waste Reuse and Recycling Act of 1991. (DEIR, p. 4.17-21)
The California Integrated Waste Management Act (AB 939), signed into law in 1989, established an integrated waste management system that focused on source reduction, recycling, composting, and land disposal of waste. In addition, the bill established a 50% waste reduction requirement for cities and counties by the year 2000, along with a process to ensure environmentally safe disposal of waste that could not be diverted. LAMC Chapter 8.12, Integrated Waste Management, regulates solid waste handling and meets the City’s obligations under AB 939. The Project would be required to comply with Chapter 8.12 – Integrated Waste Management and other federal, State, or local regulations related to solid waste management. Therefore, the Project would not conflict with federal, State, or local regulations related to solid waste management. The Project would not have a significant impact related to compliance with regulations addressing the reduction of solid waste generation and disposal.

Impacts would be less than significant, and no mitigation is required. (DEIR, p. 4.17-21)

3.19.6CUMULATIVE IMPACT
Impact Statement: The Project does not have the potential to result in cumulative impacts to utilities and service systems.
 Finding
Potential cumulative impacts of the Project related to utilities and service systems are discussed in detail in Section 4.17.6 of the DEIR. The City finds that the development of the proposed Project would not result in significant cumulative impacts related to utilities and service systems; therefore, no mitigation is required.
 Substantial Evidence
This cumulative impact analysis considers development of the proposed Project in conjunction with other development projects and planned development within the service area for the respective utility providers or the service area for specific facilities. (DEIR, p. 4.17-21) As with the Project, individual development projects would require the construction of necessary infrastructure (water and wastewater lines, storm drain facilities, dry utilities, and others) to serve the projects. Each individual development project is subject to review for utility capacity to avoid unanticipated interruption of service or inadequate supplies. Coordination with the utility providers would allow for the provision of utility services to the Project and other developments. The Project and cumulative development is subject to connection and service fees to offset increased demand and assist in facility expansion and service (at the time of need). The infrastructure needed for the Project would be to the identified construction impact area, and no new or expanded off-site infrastructure is

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required for the Project. The environmental impacts associated with the construction of these facilities are addressed throughout the DEIR and would be less than significant. Therefore, the Project would not have a cumulatively considerable contribution to a significant cumulative impact associated with construction of utility infrastructure. (DEIR, p. 4.17-21) The cumulative area considered for water supply is the GSWC West Orange service area. The 2020 UWMP details current and future water supply in the service area. GSWC West Orange has reliable supplies to meet its retail customer demands in normal, single dry years, and five consecutive dry year conditions through 2045. Its contract water from the Municipal Water District of Orange County coupled with groundwater supplies derived from the Orange County Groundwater Basin are resilient during dry conditions. As such, GSWC West Orange is not faced with shortages during normal or dry years through 2045. Because GSWC West Orange extracts only as much groundwater as is necessary to meet customer demands and has a reliable water purchase agreement with Municipal Water District of Orange County, it is anticipated that supplies and demands are congruent across all the scenarios examined. Because the demand for water services can be met through 2045 with anticipated growth in its service area, cumulative impacts to water supply would be less than significant. (DEIR, pp. 4.17- 21 to 4.17-22)
As discussed, 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 significantly impact or exceed the existing sewer capacity in the public system, and that the existing sewer system has adequate capacity for the proposed development. As such, the Project would not result in a cumulatively considerable contribution to a significant cumulative impact on wastewater facilities. (DEIR, p. 4.17- 22)
The existing residual capacity at OCSD Reclamation Plant No. 2, is approximately 105 mgd. The City of Los Alamitos General Plan Update EIR forecasted that General Plan Buildout would generate approximately 2.4 mgd, well within Reclamation Plant No. 2 treatment capacity. Wastewater generation by the General Plan Update buildout would not require OCSD to build new or expanded wastewater treatment facilities, and cumulative impacts would be less than significant. (DEIR, p. 4.17- 22)
AB 341 mandates the reduction of solid waste disposal in landfills (Public Resources Code Section 42649). The solid waste generated by construction and operation of the Project would represent nominal portion of daily disposal capacities at existing landfill facilities. The existing landfill facilities have sufficient daily capacity to handle solid waste during the Project’s construction and operation and would not directly result in the need for expanded solid waste disposal facilities. Other cumulative development would be required to comply with applicable local, State, and federal regulations during both construction and long-term operation to reduce solid waste generation. Cumulative impacts associated with solid waste disposal would be considered less than significant. (DEIR, p. 4.17-22)

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Other individual development projects would be required to comply with local and State regulations during both construction and long-term operation to reduce solid waste generation. Therefore, the Project would not have a significant cumulative impact related to compliance with regulations addressing the reduction of solid waste generation and disposal. (DEIR, p. 4.17-22)

3.20 WILDFIRE
Project impacts for Wildfire Thresholds a through d do not result in significant impacts and findings are discussed below.

3.20.1THRESHOLDS A THROUGH D
Impact Statement: The Project would not substantially impair an adopted emergency response plan or emergency evacuation plan; the Project would not, due to slope, prevailing winds, and other factors, exacerbate wildlife risks, and thereby expose Project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire; the Project would not require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines, or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment; and the Project would not expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire instability, or drainage changes.
 Findings
Potential impacts of the Project related to Thresholds a through d are discussed in Section 5.4.3 of the DEIR. The City finds that the development of the proposed Project will not result in significant impacts related to Thresholds a through d; therefore, no mitigation is required.  Substantial Evidence
According to the California Department of Forestry and Fire Protection’s (Cal Fire) Fire and Resources Assessment Program (FRAP), the Project site is not located in a Very High Fire Hazard Severity Zone (VHFHSZ) and is not within proximity to lands classified as VHFHSZ. There are no lands classified as VHFHSZ within the City. The nearest VHFHSZ is located in the City of Fullerton, approximately

8.8 miles to the northeast. The Project site is located within the limits of the City of Los Alamitos and is not within a State Responsibility Area (SRA), which is the land where the State of California is financially responsible for the prevention and suppression of wildfires. Accordingly, no impact would occur. (DEIR, p. 5-9)

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4.0 ENVIRONMENTAL IMPACTS MITIGATED TO A LEVEL OF LESS-THANSIGNIFICANT

4.1 BIOLOGICAL RESOURCES

4.1.1 THRESHOLD A
Impact Statement: The Project could have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service.
 Findings
Potential impacts of the Project related to Threshold a are discussed in detail in DEIR Section 4.3.6.

The Project does provide limited suitable habitat for nesting birds and common raptor species.

Construction activities have the potential to adversely impact nesting birds and raptors and roosting bats. Potentially significant impacts could occur. Implementation of Mitigation Measures MM 4.3-1 through MM 4.3-3 would ensure that pre-construction surveys are conducted for nesting birds, nesting raptors, and bat roosts prior to site disturbance. If nesting birds or raptors are present on the Project site, mitigation requires avoidance of active nests. With implementation of the required mitigation, potential impacts to nesting birds and common raptors would be reduced to below a level of significance. If roosting bats are detected on site outside of the bat maternity season, the roost tree will be removed in a manner to avoid and/or minimize injury to roosting bats. If roosting bats are detected onsite during the maternity season, the Project will 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. With implementation of the required mitigation, potential direct and cumulatively considerable impacts to bats would be reduced to below a level of significance. The City has determined that changes or alterations have been required in, or incorporated into, the Project which avoid or substantially lessen the significant environmental effect as identified in the DEIR.
 Substantial Evidence
Direct Impacts to Special-Status Plants
No special-status plants were determined to have potential to occur on the Project site. Therefore, Project temporary-construction related activities would not impact special-status plants. No mitigation is required. Additionally, long-term operation would not impact special-status plants. No mitigation is required. (DEIR, p. 4.3-29)
Direct Impacts to Special-Status Animals
Two special-status animals (State watch list) and Cooper’s hawk and merlin (fly over only) were detected on the Project site during the general and focused biological studies. In addition, although the vermilion flycatcher was not detected onsite (foraging or nesting) during the biological studies, the

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Project site does provide some suitable habitat for nesting (trees). Should vermilion flycatchers nest on the site during construction, construction activities could adversely impact nesting vermilion flycatchers in the absence of measures to protect the nesting individuals. Conservatively, this impact would be potentially significant before implementation of mitigation. (DEIR, pp. 4.3-29 to 4.3-30) The Project site is estimated to provide approximately four acres of marginal foraging habitat for sensitive raptor species including the Cooper’s hawk, northern harrier, wintering merlin, peregrine falcon, Swainson’s hawk, and white-tailed kite as well as other common raptor species that are not identified as special status species. Raptor nesting was not documented during the biological surveys, but the Project site would be expected to support nesting by common raptor species. The Project is not expected to provide suitable nesting raptor habitat for the above-mentioned special-status raptor species due to species specific nesting habitat requirements, and level of existing anthropogenic disturbance from vehicles and people within and immediately adjacent to the Project site. (DEIR, p.

4.3-30)
Moreover, one merlin was observed briefly in March 2022 flying over the southwest corner of the parking lot to the JFTB. However, since the species is a winter resident, no impact is expected. (DEIR, p. 4.3-30)
Given the limited area (approximately four acres) of marginal foraging area, the Project would not result in significant impacts on raptor foraging, including for the special-status raptors noted above.

The Project does not exhibit suitable nesting habitat for special-status raptors and there would thus be no significant impacts to nesting habitat for special-status raptors. However, there is a limited potential for nesting common raptor species on the Project site; impacts are potentially significant. (DEIR, p.

4.3-30)
Two sensitive bat species, the western red bat and the western yellow bat were detected foraging offsite within the adjacent Navy golf course. However, no evidence of roosting by any bat species was detected onsite during the four focused bat surveys performed for this analysis. As shown in DEIR Figure 3-18, Landscape Plan, (project design feature PDF B-1), the Project will incorporate larger sized box tree species (including the western sycamore) along the fringes of the development, adjacent to open space areas. The planting of trees preferred by bats adjacent to open space areas would minimize potential impacts to roosting bats because it would provide habitat for potential roosting. (DEIR, p. 4.3-30)
Nonetheless, because sensitive bat species were detected adjacent to the Project site and have the limited potential to establish a maternity roost onsite (specifically, the western yellow bat in suitable palm trees), conservatively, this impact would be potentially significant before implementation of mitigation. (DEIR, p. 4.3-30)
Direct Impacts to Critical Habitat
Temporary construction-related activities would not impact lands designated as critical habitat by the USFWS. No impact would occur and no mitigation is required. Long-term operation would not impact

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lands designated as critical habitat by the USFWS. No impact would occur, and no mitigation is required. (DEIR, pp. 4.3-30 to 4.3-31)
Indirect Impacts to Biological Resources
The Project site is not surrounded by or is adjacent to natural open space; rather, adjacent facilities include Arbor Dog park, Arbor Park and the Navy Golf Course which are recreational facilities subject to regular human uses and associated disturbances. The Project is not expected to result in indirect effects to biological resources as the Project site is currently predominantly developed with existing outdoor lighting in place and the proposed Project would incorporate measures to minimize indirect light spillover into the adjacent areas including Arbor Park, Navy Golf Course, and JFTB. The Project would comply with any applicable lighting plan requirements of the Los Alamitos Municipal Code to ensure that light spillage is reduced to the maximum extent possible. Additionally, the Project’s landscaping plan excludes invasive exotic species as listed on the California Invasive Plant Council (Cal-IPC) website. Impacts would be less than significant, and no mitigation is required. (DEIR, p.

4.3-31)
The Project includes the following Project Design Features (PDFs) that have the effect of minimizing and avoiding environmental impacts.

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.

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) Inventory species will be planted and a list of approved species to planted shall be reviewed by a qualified biologist prior to planting.

The following mitigation measures have been incorporated into the Project:

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

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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.

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 by a qualified biologist. 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.

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 removal or for palm trees and other species, to defrond or de-branch the tree using a mechanical lift and gently lower the cut fronds or 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.

Implementation of Mitigation Measures MM 4.3-1 through MM 4.3-3 would ensure that preconstruction surveys are conducted for nesting birds, nesting raptors, and bat roosts prior to site disturbance. If nesting birds or raptors are present on the Project site, mitigation requires avoidance of active nests. With implementation of the required mitigation, potential impacts to nesting birds and common raptors would be reduced to below a level of significance. (DEIR, p. 4.3-38)

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If roosting bats are detected on site outside of the bat maternity season, the roost tree will be removed in a manner to avoid and/or minimize injury to roosting bats. If roosting bats are detected onsite during the maternity season, the Project will 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. With implementation of the required mitigation, potential direct and cumulatively considerable impacts to bats would be reduced to below a level of significance. (DEIR, pp. 4.3-38 to 4.3-39)

4.1.2 THRESHOLD D
Impact Statement: The Project could potentially interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors or impede the use of native wildlife nursery sites.  Findings
Potential impacts of the Project related to Threshold d are discussed in detail in Section 4.3.6 of the DEIR. The Project has the potential to impact active bird nests if vegetation is removed during the nesting season (February 1 to August 31) and roosting bats including the western red bat and the western yellow bat. Implementation of Mitigation Measure MM 4.3-1 would ensure that preconstruction surveys are conducted for nesting birds protected by State and federal regulations if vegetation is removed from the Project site during the breeding season. If nesting birds are present on the Project site, the mitigation requires avoidance of active bird nests in conformance with accepted protocols and regulatory requirements. With implementation of the required mitigation, potential impacts to nesting birds protected by State and federal regulations would be reduced to below a level of significance. The City has determined that changes or alterations have been required in, or incorporated into, the Project which avoid or substantially lessen the significant environmental effect as identified in the DEIR.
 Substantial Evidence
Temporary Construction-Related Activities
The Project requires removal of existing ornamental trees that have the potential to provide suitable nesting opportunities for nesting birds. Therefore, the Project has the potential to impact active bird nests during construction activities, if vegetation is removed during the nesting season (February 1 to August 31). Construction activities could adversely impact nesting birds in the absence of measures to protect the nesting individuals. Moreover, as discussed above, two sensitive bat species, the western red bat and the western yellow bat were detected foraging offsite within the adjacent Navy golf course.

Since sensitive bat species were detected adjacent to the Project site and have the limited potential to establish a maternity roost onsite (specifically, the western yellow bat in suitable palm trees), impacts are potentially significant during breeding season. Therefore, construction-related impacts to nesting birds and roosting bats are considered potentially significant before implementation of mitigation. (DEIR, p. 4.3-33)

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Long-Term Operation
The Project site is not located within or part of a wildlife movement corridor. The site is located within the Pacific flyway; however, given the small area of the site, lack of native habitats and levels of disturbance, there is no potential for significant impacts to the Pacific flyaway. The Project site is developed and is adjacent to developed areas that do not contribute to wildlife movement. Therefore, the Project would not substantially interfere with an established migratory wildlife corridor.

Additionally, MBTA makes it unlawful to take, possess, buy, sell, purchase, or barter any migratory bird listed in Code of Federal Regulations Title 50 Part 10, including feathers or other parts, nests, eggs, or products, except as allowed by implementing regulations. Moreover, California Department of Fish and Game Code Sections 3505, 3503.5, and 3800 prohibit the take, possession, or destruction of birds, their nests or eggs. The Project would be required to comply with existing laws including but not limited to MBTA and California Department of Fish and Game Code Sections 3505, 3503.5, and 3800. Therefore, no impact would occur, and mitigation is not required. (DEIR, pp. 4.3-33 to 4.3-34) The Project has no area designated or recognized as wildlife nurseries, rookeries, or maternal bat roosts.

Therefore, the Project would not impede the use of native wildlife nursery sites. No impact would occur, and mitigation is not required. (DEIR, p. 4.3-34) Mitigation Measure 4.3-1 (provided above) has been incorporated into the Project.

Implementation of Mitigation Measure MM 4.3-1 would ensure that pre-construction surveys are conducted for nesting birds protected by State and federal regulations if vegetation is removed from the Project site during the breeding season. If nesting birds are present on the Project site, the mitigation requires avoidance of active bird nests in conformance with accepted protocols and regulatory requirements. With implementation of the required mitigation, potential impacts to nesting birds protected by State and federal regulations would be reduced to below a level of significance. (DEIR, p. 4.3-39)

4.2 CULTURAL RESOURCES

4.2.1 THRESHOLD B
Impact Statement: The Project has the potential to cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5.  Findings
Potential impacts of the Project related to Threshold b (historical resources) are discussed in detail in Section 4.4.5 of the DEIR. No known archaeological resources are present on the Project site.

Nonetheless, the potential exists for Project-related construction activities to result in a direct impact to significant subsurface archaeological resources should such resources be discovered during Projectrelated construction activities. Impacts would be potentially significant and therefore require mitigation. Implementation of Mitigation Measure MM 4.4-1 would ensure the proper identification and subsequent treatment of any significant archaeological resources that may be encountered during

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ground-disturbing activities associated with implementation of the Project. With implementation of the required mitigation, the Project’s potential impacts to archaeological resources would be reduced to less than significant. The City has determined that changes or alterations have been required in, or incorporated into, the Project which avoid or substantially lessen the significant environmental effect as identified in the DEIR.
 Substantial Evidence
The Project site is currently developed. The site was subject to construction and ground-disturbing activities similar to that which would occur under the Project. (DEIR, p. 4.4-16) BFSA conducted a cultural resources inventory of the Project site, which included a records search through the SCCIC at CSU Fullerton and an intensive pedestrian survey of the site. The survey did not identify any archaeological resources within the property. The Project site is located in an area of Orange County and the City of Los Alamitos that reflects very few recorded cultural resources, due to past agricultural uses and subsequent commercial and residential developments. Most of the recorded resources in the area are associated with historic development of the region. (DEIR, p. 4.4-16) Given the highly disturbed condition of the Project site and its surroundings, the potential for the Project’s construction activities to affect an unidentified archaeological resource is considered low.

However, while unlikely, the presence of previously undiscovered subsurface archaeological resources on the Project site remains possible during grading activities in native soils (e.g. previously undisturbed soils due to deeper excavation). The Project would result in grading to depths of 5 feet below existing grades with deeper excavations (8 to 10 feet) for underground utilities or localized removals. The depth of grading for the existing building and improvements are unknown. Conservatively, this impact would be potentially significant before implementation of mitigation. (DEIR, p. 4.4-16) The following mitigation measure has been incorporated into the Project:

MM 4.4-1 Discovery of Inadvertent Resources. Prior to the issuance of any grading permits, the Project Applicant/Developer 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.

1. 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

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archaeologist, the Lead Agency shall be notified, and additional investigation by the archaeologist would be required. Additional investigation work would include scientific recordation and excavation.

2. 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 prior to the issuance of an occupancy permit.

3. Excavated finds shall be curated at a repository determined by the archaeologist and approved by the City with verification of curation provided to the City prior to the issuance of an occupancy permit.

Implementation of Mitigation Measure MM 4.4-1 would ensure the proper identification and subsequent treatment of any significant archaeological resources that may be encountered during ground-disturbing activities associated with implementation of the Project. With implementation of the required mitigation, the Project’s potential impacts to archaeological resources would be reduced to less than significant. (DEIR, p. 4.4-20)

4.2.2 THRESHOLD C
Impact Statement: The Project has the potential to disturb human remains, including those interred outside of formal cemeteries.
 Findings
Potential impacts of the Project related to Threshold c are discussed in detail in Section 4.4.5 of the DEIR. In the unlikely event that human remains are discovered during Project grading or other ground disturbing activities, disturbance of the remains would result in a significant impact and therefore require mitigation. Mitigation Measure 4.4-2 will ensure mandatory compliance with California Health and Safety Code Section 7050.5 and Public Resources Code Section 5097.98. Mandatory compliance with State law would ensure that any discovered human remains are appropriately treated and any potential impacts to human remains, including human remains of Native American ancestry, that may result from development of the Project would be reduced to less than significant. The City has determined that changes or alterations have been required in, or incorporated into, the Project which avoid or substantially lessen the significant environmental effect as identified in the DEIR.  Substantial Evidence
The Project site does not contain a cemetery and no known formal cemeteries are located within the immediate site vicinity. Nevertheless, the limited potential exists that human remains may be unearthed during grading and excavation activities associated with Project construction. (DEIR, p. 4.4-17) If human remains are unearthed during Project construction, the construction contractor would be required by law to comply with California Health and Safety Code Section 7050.5 “Disturbance of

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Human Remains.” According to Section 7050.5(b) and (c), if human remains are discovered, 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.

Pursuant to California Public Resources Code Section 5097.98, whenever 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 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. (DEIR, p. 4.4-17) Given prior ground disturbances at the site, the likelihood of discovering human remains is low. In the unlikely event that human remains are discovered, disturbance would result in a significant impact.

Conservatively, this impact would be potentially significant before implementation of mitigation. (DEIR, p. 4.4-17)
The following mitigation measure has been incorporated into the Project:

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 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

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relating to the treatment and disposition of Native American human burials, skeletal remains, and items associated with Native American burials.

Mitigation Measure 4.4-2 will ensure mandatory compliance with California Health and Safety Code Section 7050.5 and Public Resources Code Section 5097.98. Mandatory compliance with State law would ensure that any discovered human remains are appropriately treated and any potential impacts to human remains, including human remains of Native American ancestry, that may result from development of the Project would be reduced to less than significant. (DEIR, p. 4.4-20)

4.3 GEOLOGY AND SOILS

4.3.1 THRESHOLD A
Impact Statement: The Project has the potential to directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, and/or death involving:
i. Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other ii. substantial evidence of a known fault? (Refer to Division of Mines and Geology Special Publication 42).
iii. Strong seismic ground shaking.
iv. Seismic-related ground failure, including liquefaction. v. Landslides.
 Findings
Potential impacts of the Project related to Threshold a are discussed in detail in Sections 4.6.5 of the DEIR. The Project is not located on a known earthquake fault but would potentially be subject to strong seismic ground shaking. As structures would be designed to meet or exceed California Building Code (CBC) standards for earthquake resistance, development of the Project would create less than significant impacts related to seismic ground shaking. The Project site is susceptible to liquefaction. A significant impact could occur, and mitigation would be required. Compliance with the recommendations from the Geotechnical Report would reduce the risk of seismic-related ground failure due to liquefaction to less than significant. Mitigation Measure MM 4.6-1 would ensure that that the Project’s design professionals and construction contractors implement the recommendations of the Project’s Geotechnical Investigation (DEIR Technical Appendix F1), which in turn would ensure measures are implemented to address potential impacts due to the exposure of people or structures to adverse effects, including loss, injury, or death as a result of strong seismic ground shaking liquefaction hazards, soil settlement and expansion. Implementation of the required mitigation would ensure that impacts are reduced to less-than-significant levels. The City has determined that changes or alterations have been required in, or incorporated into, the Project which avoid or substantially lessen the significant environmental effect as identified in the DEIR.

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 Substantial Evidence
Rupture of a Known Earthquake Fault
The Project site is not located within the State of California Earthquake Fault Zone (Alquist-Priolo) and no faults were identified on the site during the site evaluation. The possibility of damage due to ground rupture is considered low since no active faults are known to cross the site. Therefore, no impacts related to the rupture of a known earthquake fault would occur and no mitigation is required. (DEIR, p. 4.6-8)
Strong Seismic Ground Shaking
Southern California is a seismically active area and properties in the City of Los Alamitos, including the Project site, are subject to periodic ground shaking and other effects from earthquake activity along nearby regional faults. As indicated in the Geotechnical Report (DEIR Technical Appendix F1), the Project site is not at an increased risk relative to the surrounding areas. The Project would incorporate the construction recommendations contained with the geotechnical report as required by the LAMC Section 15.04.020. Project-related structures and buildings would be required to be designed and constructed in compliance with the CBC (California Code of Regulations, Title 24, Part 2), which contains provisions for earthquake safety based on factors including occupancy type, the types of soil and rock onsite, and the probable strength of ground motion. Therefore, as structures would be designed to meet or exceed CBC standards for earthquake resistance, development of the Project would create less than significant impacts related to seismic ground shaking and no mitigation is required. (DEIR, p. 4.6-8)
Seismic-Related Ground Failure, Including Liquefaction
The subject site is located within a liquefaction hazard zone per the State of California Seismic Hazard Zone for liquefaction potential. Subsurface field data indicates that the site contains isolated sandy layers susceptible to liquefaction interfingered with fine-grained non-liquefiable soils and dense sands.

The recent explored groundwater elevation of 11 feet below existing grade and historic high groundwater elevation of 10 feet below existing grade were both used in the liquefaction analysis.

Liquefaction potential was evaluated using the procedures outlined by Special Publication 117A and the applicable California Building Code seismic criteria. (DEIR, pp. 4.6-8 to 4.6-9) Section 4.0 of the Geotechnical Report (DEIR Technical Appendix F1) identifies design recommendations to reduce liquefaction impacts to an acceptable level. The recommendations include seismic design parameters for the site, prevention of the intentional infiltration of storm water into subsurface soils and require foundations to be constructed based on the expansion index and shear strength of on-site soils. The estimated seismic settlement can be mitigated by performing the recommended remedial grading and constructing the buildings with the recommended post-tensioned slab and interconnecting isolated pad footings with grade beams. (DEIR, p. 4.6-9) The Project would be required to be designed and constructed in accordance with applicable seismic safety guidelines, including the standard requirements of the CBSC. Furthermore, as stated in the LAMC Section 15.04.020, the Project would be required to comply with the grading and construction

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recommendations contained within the geotechnical report for the Project site to further reduce the risk of seismic-related ground failure due to liquefaction. Implementation of the Project would have the potential to directly or indirectly expose people or structures to substantial hazards associated with seismic-related ground failure and/or liquefaction hazards. Conservatively, this impact would be potentially significant before implementation of mitigation. (DEIR, p. 4.6-9) Landslides
Slope failures in the form of landslides are common during strong seismic shaking in areas of steep hills. The Project site and surrounding area are generally flat with no significant slopes. The Project site is not located within a landslides zone. Accordingly, no impact related to landslide hazards would occur and no mitigation is required. (DEIR, p. 4.6-9)
The following mitigation measure has been incorporated into the Project:

MM 4.6-1 Prior to the issuance of grading 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. 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.

Mitigation Measure MM 4.6-1 would ensure that that the Project’s design professionals and construction contractors implement the recommendations of the Project’s Geotechnical Investigation (DEIR Technical Appendix F1), which in turn would ensure measures are implemented to address potential impacts due to the exposure of people or structures to adverse effects, including loss, injury, or death as a result of strong seismic ground shaking liquefaction hazards, soil settlement and expansion. Implementation of the required mitigation would ensure that impacts are reduced to lessthan-significant levels. (DEIR, p. 4.6-16)

4.3.2 THRESHOLD C
Impact Statement: The Project has the potential to be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on-site or off-site landslide, lateral spreading, subsidence, liquefaction or collapse.

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 Findings
Potential impacts of the Project related to Threshold c are discussed in detail in Section 4.6.5 of the DEIR. There is no potential for the Project’s construction or operation to cause, or be impacted by, onor off-site landslides or lateral spreading. Potential hazards associated with unstable soils would be precluded through mandatory adherence to the recommendations contained in the site-specific Geotechnical Report during Project construction. Project-related structures and buildings would be required to be designed and built in compliance with the CBC, which requires the Project to implement the recommendations of the site-specific Geotechnical Report. Conservatively, impacts would be potentially significant and therefore require mitigation. Mitigation Measure MM 4.6-1 would ensure that that the Project’s design professionals and construction contractors implement the recommendations of the Project’s Geotechnical Investigation (DEIR Technical Appendix F1), which in turn would ensure measures are implemented to address potential impacts due to the exposure of people or structures to adverse effects, including loss, injury, or death as a result of strong seismic ground shaking liquefaction hazards, soil settlement and expansion. Implementation of the required mitigation would ensure that impacts are reduced to less-than-significant levels. The City has determined that changes or alterations have been required in, or incorporated into, the Project which avoid or substantially lessen the significant environmental effect as identified in the DEIR.  Substantial Evidence
Liquefaction
The Project site is susceptible to liquefaction. Project-related structures would be required to be designed and constructed in compliance with the CBC and the recommendations of the Geotechnical Report. The recommendations require foundations to be constructed based on the expansion index and shear strength of on-site soils. Conservatively, this impact would be potentially significant before implementation of mitigation. (DEIR, pp. 4.6-10 to 4.6-11) Landslide
The Project site and surrounding area are generally flat with no significant slopes. The Project site is not located within a landslides zone. Accordingly, no impact related to landslide hazards would occur and no mitigation is required. (DEIR, p. 4.6-11)
Lateral Spreading
Due to the lack of a nearby “free face” condition and non-continuous nature of the subsurface layers, the potential for lateral spreading is considered very low. Impacts would be less than significant, and no mitigation is required. (DEIR, p. 4.6-11)
Settlement
The underlying soils were found to be generally stiff to very stiff silts and clays. Based on laboratory test data consisting of in-situ moisture content, consolidation tests, and blow counts, fine-grained soils are considered generally normally consolidated. Based upon in-situ testing, visual examination, lab

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data, geotechnical evaluation and the proposed corrective grading and fill placement recommendations, static settlement induced by raising grades 1 to 3 feet is estimated to be on the order of 1-inch. The Geotechnical Investigation (DEIR Technical Appendix F1) provides standard recommendations for site grading, site preparation, and placement of fill material that would avoid the potential for settlement. The estimated seismic settlement can be mitigated by performing the recommended remedial grading and constructing the buildings with the recommended post-tensioned slab and interconnecting isolated pad footings with grade beams. The recommendations also require isolated pad footings to be interconnected with grade beams. This recommendation would prevent excessive settlement and ensure safety against sliding and overturning. Additionally, the Geotechnical Investigation provides recommendations for soil bearing and lateral resistance which is the amount of load the soil can take without experiencing failure or exceeding the allowable amount of settlement.

Prior to mitigation implementing the geotechnical study recommendations, implementation of the Project would have potential impacts related to settlement. Conservatively, this impact would be potentially significant before implementation of mitigation. (DEIR, p. 4.6-11) Implementation of Mitigation Measure MM 4.6-1 (provided previously) has been incorporated into the Project.

Mitigation Measure MM 4.6-1 would ensure that that the Project’s design professionals and construction contractors implement the recommendations of the Project’s Geotechnical Investigation (DEIR Technical Appendix F1), which in turn would ensure measures are implemented to address potential impacts due to the exposure of people or structures to adverse effects, including loss, injury, or death as a result of strong seismic ground shaking liquefaction hazards, soil settlement and expansion. Implementation of the required mitigation would ensure that impacts are reduced to lessthan-significant levels. (DEIR, p. 4.6-16)

4.3.3 THRESHOLD D
Impact Statement: The Project has the potential to be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994) and would not create substantial direct or indirect risks to life or property.
 Findings
Potential impacts of the Project related to Threshold d are discussed in detail in Section 4.6.5 of the DEIR. The Project site contains soils with low susceptibility to expansion; however, the Geotechnical Report identified recommendations to minimize the impacts of expansive soils. Conservatively, this impact would be potentially significant before implementation of mitigation. The City has determined that changes or alterations have been required in, or incorporated into, the Project which avoid or substantially lessen the significant environmental effect as identified in the DEIR.  Substantial Evidence
Based on the results of the Geotechnical Report (Technical Appendix F1 of the DEIR), site soils are anticipated to have “low” expansion potential. Accordingly, the Project site would not create

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substantial direct or indirect risks to life or property associated with the presence of expansive soils.

Although the Project site has a low expansion potential, the Geotechnical Investigation provides recommendations for foundations and site improvements, such as flatwork and? Pre-soaking of the subgrade for building slabs to minimize the impacts of expansive soils. Conservatively, this impact would be potentially significant before implementation of mitigation. (DEIR, p. 4.6-12) Implementation of Mitigation Measure MM 4.6-1 (provided previously) has been incorporated into the Project.

Mitigation Measure MM 4.6-1 would ensure that that the Project’s design professionals and construction contractors implement the recommendations of the Project’s Geotechnical Investigation (DEIR Technical Appendix F1), which in turn would ensure measures are implemented to address potential impacts due to the exposure of people or structures to adverse effects, including loss, injury, or death as a result of strong seismic ground shaking liquefaction hazards, soil settlement and expansion. Implementation of the required mitigation would ensure that impacts are reduced to lessthan-significant levels. (DEIR, p. 4.6-16)

4.3.4 THRESHOLD F
Impact Statement: The Project has the potential to directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.  Findings
Potential impacts of the Project related to Threshold f are discussed in detail in Section 4.6.5 of the DEIR. The Pleistocene alluvial deposits that underlie the Holocene alluvial deposits have a remote potential to exist at the Project site and have a moderate/undetermined potential to yield paleontological resources. Conservatively, the Project would have the potential to directly or indirectly impact a unique paleontological resource before mitigation. The City has determined that changes or alterations have been required in, or incorporated into, the Project which avoid or substantially lessen the significant environmental effect as identified in the DEIR.
 Substantial Evidence
The Project would result in grading to depths of 5 feet below existing grades with deeper excavations (8 to 10 feet) for underground utilities or localized removals. The depth of grading for the existing building and improvements are unknown. (DEIR, p. 4.6-12) A limited subsurface geotechnical evaluation of the Project site consisting of the excavation of seven small-diameter borings ranging in depth from approximately 5 to 46.5 feet below existing ground surface was performed. Undocumented artificial fill, soils native to or near the site, was encountered at depths ranging from 0 to 2.5 feet below existing grade. Quaternary Young Alluvium (Holocene age) was encountered below the undocumented fill (Technical Appendix F1 of the DEIR). (DEIR, p. 4.6- 12)

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According to the Paleontological Report (Technical Appendix F2 of the DEIR), Holocene and late Pleistocene young alluvial deposits were mapped at the Project site in 2016 and the depth of the geologic age transition from Holocene to Pleistocene within the alluvial deposits is unknown. Within Orange County, Holocene-aged alluvial sedimentary deposits are usually geologically too young to produce fossils. Due to the lack of nearby significant fossil localities and young sedimentary deposits, there is a low potential to uncover paleontological resources. However, Pleistocene alluvial deposits underlie the Holocene alluvial deposits at the Project site and are considered to have a moderate/undetermined paleontological potential. (DEIR, p. 4.6-12) Although the Geotechnical Report did not identify Pleistocene alluvial deposit within any borings on site, the depth to Pleistocene alluvial deposits is unknown. As a result, the Project has a remote potential to encounter paleontological resources during grading activities in native soils. Accordingly, the Project would have the potential to directly or indirectly impact a unique paleontological resource.

Conservatively, this impact would be potentially significant before implementation of mitigation. (DEIR, pp. 4.6-12 to 4.613)
The following mitigation measure has been incorporated into the Project:

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 based on the Society of Vertebrate Paleontology guidelines, a monitoring and recovery plan shall be initiated, which will include notification of appropriate personnel involved and monitoring of earth disturbance activities. The monitoring and recovery plan shall include the following requirements.
a. Monitoring of mass grading and excavation activities shall be performed by a qualified paleontologist. 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 collected and placed in cardboard flats or plastic buckets and identified by field

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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, including screen-washing sediments to recover small invertebrates and vertebrates.
e. Recovered specimens shall be identified and curated into a professional, accredited public museum / repository with a commitment to archival conservation and permanent retrievable storage (e.g., Orange County [OC] Parks). The paleontological curation 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 Planning Division) 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.

Mitigation Measure MM 4.6-2 would ensure the proper identification and subsequent treatment of any significant paleontological resources that may be encountered during ground-disturbing activities associated with implementation of the proposed Project. With implementation of the required mitigation, the Project’s potential impacts to important paleontological resources would be reduced to less than significant. The Project’s contribution to cumulative impacts would likewise be reduced to less than significant. (DEIR, p. 4.6-17)

4.4 TRIBAL CULTURAL RESOURCES

4.4.1 THRESHOLD A
Impact Statement: The Project has the potential to cause a substantial adverse change in the significance of a tribal cultural resource.

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 Findings
Potential impacts of the Project related to Threshold a are discussed in detail in Section 4.16.5 of the DEIR. There is evidence indicating that tribal cultural resources are present on the Project site or have been found previously on the Project site. Project construction activities have the potential to unearth and adversely impact tribal cultural resources that may be buried in native soils at the Project site.

Impacts would be potentially significant, and mitigation is required. Implementation of Mitigation Measures MM 4.16-1 through 4.16-3 would ensure the proper identification and subsequent treatment of any significant tribal cultural resources that may be encountered during ground-disturbing activities associated with Project development. With implementation of the required mitigation, the Project’s potential impact to significant tribal cultural resources would be reduced to less than significant. The City has determined that changes or alterations have been required in, or incorporated into, the Project which avoid or substantially lessen the significant environmental effect as identified in the DEIR.  Substantial Evidence
As discussed in DEIR Section 4.4, Cultural Resources, there are no historical resources identified within the Project site. Additionally, there are no known tribal cultural resources on the Project site.

Because the site is currently developed, due to past grading activities and historic agricultural uses, the potential for the Project’s construction activities to affect an unidentified tribal cultural resource is considered low. However, while unlikely, the presence of previously undiscovered subsurface tribal cultural resources on the Project site remains possible during grading activities in native soils (e.g., previously undisturbed soils due to deeper excavation). (DEIR, p. 4.16-7) As part of the mandatory AB 52 consultation process required by State law, the City sent notification of the Project to Native American tribes with possible traditional or cultural affiliation to the Project area. The City sent notification letters of the proposed Project to the following 14 Native American tribes:
• Gabrielino-Tongva Tribe;
• Juaneno Band of Mission Indians Acjachemen Nation;
• Gabrielino Tongva Indians of California Tribal Council; • Ewiiaapaayp Band of Kumeyaay;
• Pala Band of Mission Indians;
• Gabrielino/Tongva Nation;
• Campo Band of Diegueno;
• Mesa Grande Band of Diegueno;
• La Posta Band of Diegueno Mission Indians;
• Gabrieleno/Tongva San Gabriel Band of Mission Indians; • Santa Rosa Band of Cahuilla Indians;
• Gabrieleno Band of Mission Indians – Kizh Nation;
• Manzanita Band of Kumeyaay Nation; and
• Soboba Band of Luiseno Indians. (DEIR, pp. 4.16-7 to 4.16-8)

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During the course of the tribal consultation process, the Gabrieleno Band of Mission Indians – Kizh Nation responded to the City’s invitation for consultation and provided the City with tribal archive information indicating that tribal cultural resources, as defined in Public Resources Code § 21074, have the potential to exist in the Project area have explained their concerns with specific subsurface ground disturbance activities that have impacted and destroyed their tribal cultural resources in the past.

Accordingly, there is potential for significant impacts to occur if tribal cultural resources are inadvertently discovered during grading activities in native soils and mitigation is required.

Conservatively, this impact would be potentially significant before implementation of mitigation. (DEIR, p. 4.16-8)
The Project would be required to comply with the following Mitigation Measures:

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

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 grounddisturbing 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

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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.

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).

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

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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.

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 project applicant/developer and/or landowner, 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 cultural patrimony will be removed to a secure container on site if possible. These items should be retained and reburied within six

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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.

Implementation of Mitigation Measures MM 4.16-1 through 4.16-3 would ensure the proper identification and subsequent treatment of any significant tribal cultural resources that may be encountered during ground-disturbing activities associated with Project development. With implementation of the required mitigation, the Project’s potential impact to significant tribal cultural resources would be reduced to less than significant. (DEIR, p. 4.16-12)

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5.0 ENVIRONMENTAL IMPACTS THAT REMAIN SIGNIFICANT AND UNAVOIDABLE

AFTER MITIGATION
The City finds the Project would result in significant and unavoidable impacts in the following impact categories after implementation of all feasible mitigation measures: Transportation. In accordance with CEQA Guidelines Section 15092(b)(2), the City cannot approve the Project unless it first finds (1) under Public Resources Code Section 21081(a)(3), and CEQA Guidelines Section 15091(a)(3), that specific economic, legal, social technological, or other considerations, including provisions of employment opportunities to highly trained workers, make infeasible the mitigation measures or alternatives identified in the EIR; and (2) under CEQA Guidelines Section 15092(b), that the remaining significant effects are acceptable under CEQA Guidelines Section 15093 because the economic, legal, social, technological or other benefits of the proposed Project outweigh its unavoidable adverse environmental effects. Therefore, a statement of overriding considerations has been prepared (see Section 9.0, herein).

5.4 TRANSPORTATION

5.4.1 THRESHOLD B
Impact Statement: The Project would conflict with CEQA Guidelines Section 15064.3, subdivision (b).
 Findings
Potential impacts of the Project related to Threshold b are discussed in detail in Section 4.15.5 of the DEIR. The Project would generate VMT per capita exceeding the City’s adopted VMT impact threshold of 14.8 by 31.8% in the baseline condition and 27.7% in the cumulative condition. Impacts would be potentially significant and cumulatively considerable. As such, these impacts will require mitigation. Project components and mitigation measures available to reduce VMT include developing pedestrian network improvements and implementing transportation demand management (TDM) measures such as those listed in Mitigation Measure MM 4.15-1. Even where the TDM measures are implemented to their maximum effectiveness of 10%, 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 Project is found to have a significant and unavoidable VMT impact on a direct and cumulatively considerable basis. To ensure that all feasible mitigation measures were incorporated to reduce VMT impacts, measures identified in the 2021 California Air Pollution Control Officers Association (CAPCOA) Handbook were considered. As discussed above, the 2021 CAPCOA Handbook describes methods to reduce VMT. As discussed in Attachment C, VMT Reduction Matrix, of the VMT Report (DEIR Technical Appendix N2), all applicable transportation mitigation measures were evaluated to reduce VMT impacts. Even with incorporation of all feasible mitigation measures, impacts would remain significant and unavoidable. As discussed in DEIR Section 4.12, Population and Housing, the Project would place housing within a job-rich area. Although there would be a significant and unavoidable impact related to VMT, this is due to the fact that the Project site does not currently have transit or alternative

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transportation opportunities and has a higher VMT per capita compared to the County’s regional average. Nevertheless, co-locating housing near jobs reduces vehicle travel lengths and associated greenhouse gas emissions caused by long commute distances.

Pursuant to Section 21081(a)(3) of the California Public Resources Code the City has determined that specific economic, legal, social, technological, or other considerations make infeasible the mitigation measures and alternatives identified in the EIR.
 Substantial Evidence
Vehicle Miles Traveled
Small Project Screening
The Governor’s OPR Technical Advisory on Evaluating Transportation Impacts in CEQA (December of 2018) (Technical Advisory) indicates that projects generating fewer than 110 daily vehicle trips may be presumed to have a less than significant impact. Trips generated by the Project’s proposed land uses have been estimated based on trip generation rates collected by the Institute of Transportation Engineers (ITE) Trip Generation Manual, 11th Edition, 2021. The proposed Project is anticipated to generate 1,658 vehicle trip-ends per day, which exceeds the 110 vehicle trips per day threshold. (DEIR, p. 4.15-13)
Map Based Screening
As noted in the Technical Advisory, “residential and office projects that locate in areas with low VMT and that incorporate similar features (density, mix of uses, and transit accessibility) will tend to exhibit similarly low VMT.” The Orange County Transportation Model (OCTAM) was utilized to obtain the Project’s transportation analysis zone (TAZ) existing VMT information. The Project site is in TAZ 634. TAZ 634 has an existing VMT per capita of 22.71. Per the OCTAM model, the County of Orange regional average VMT per capita is 17.42. The Project is not located in a low VMT area because the existing VMT per capita of 22.71 in TAZ 634 is higher than the regional VMT per capita of 17.42. (DEIR, p. 4.15-13)
TPA Screening
The Technical Advisory states that projects located within a Transit Priority Area (TPA), ½ mile of an existing “major transit stop,” or an existing stop along a “high-quality transit corridor” will have a less than significant impact on VMT. (DEIR, p. 4.15-13)
Once a project is determined to be within a TPA, the Technical Advisory also recommends consideration of secondary screening checks. For example, a proposed land use project is not eligible for TPA screening if the project meets any of the following sub-criteria:
1) Has a Floor Area Ratio (FAR) of less than 0.75;
2) Includes more parking for use by residents, customers, or employees of the project than required by the jurisdiction (if the jurisdiction requires the project to supply parking);

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3) Is inconsistent with the applicable Sustainable Communities Strategy (as determined by the lead agency, with input from the Metropolitan Planning Organization); or 4) Replaces affordable residential units with a smaller number of moderate- or high-income residential units. (DEIR, p. 4.15-14)
Utilizing Graphical Information System (GIS) data obtained from SCAG, the Project’s location relative to its proximity to TPA area was mapped. The Project is not located within a TPA. (DEIR, p.

4.15-14)
Affordable Residential Development Screening
The Technical Advisory states that “Adding affordable housing to infill locations generally improves jobs-housing match, in turn shortening commutes and reducing VMT.” The Technical Advisory also identifies projects consisting of 100% affordable housing units as eligible for screening. Furthermore “low-wage workers in particular would be more likely to choose a residential location close to their workplace, if one is available.” In areas where existing jobs-housing match is closer to optimal, lowincome housing nevertheless generates less VMT than market-rate housing. Therefore, a project consisting of a high percentage of affordable housing may be a basis for the lead agency to find a lessthan-significant impact on VMT. The Project is proposing 77 affordable housing units or 31% of the total 246 dwelling units. As previously discussed, the City of Los Alamitos has not formally adopted thresholds to determine the amount of affordable housing applicable to screening within the City, and in the absence of those thresholds, an affordable housing screening qualification cannot be made. (DEIR, p. 4.15-14)
Local Community Serving Retail Screening
The Technical Advisory identifies local serving retail uses are presumed to have a less than significant impact absent substantial evidence to the contrary. By adding retail opportunities into the urban fabric and thereby improving retail destination proximity, local-serving retail development tends to shorten trips and reduce VMT. The Project does not propose to develop any local serving retail uses, and therefore the Project is not eligible for screening as a local serving retail use. (DEIR, p. 4.15-14) Model Based Project Generated VMT
Since the Project does not meet any of the screening criteria used to determine that a land use project is presumed to have less than significant VMT impacts, VMT modeling and analysis was performed.

DEIR Table 4.15-2, Project-Generated VMT Results, presents the Project’s potential VMT. As discussed previously, a VMT impact is considered significant if a residential project generates more than 15% below the existing regional residential VMT per capita. Consistent with the Technical Advisory, project level VMT analysis should evaluate home-based (HB) VMT divided by a project’s population. HB VMT is calculated from OCTAM’s Production/Attraction (PA) trip matrices and then divided by a project’s population to derive the VMT efficiency metric VMT per capita. Productions are land use types that generate trips (residences) and attractions are land use types that attract trips (employment). Productions and attractions are converted from person trips to vehicle trips for the purposes of calculating VMT. (DEIR, p. 4.15-15)

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The Project includes 77 affordable housing units, which generate vehicle trips at a lower rate per unit as compared to market rate housing. As the reduction in trips and associated VMT could not be accurately accounted for by the calculations conducted using the OCTAM model, these adjustments are made through calculations as described in the Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity. Specifically, “Land Use – T-4. Integrate Affordable and Below Market Rate Housing”; requires multifamily residential units to be permanently dedicated as affordable for lower income families. The Project’s affordable units would reduce its Project generated VMT by 8.87% or 1,226 VMT. Additionally, the Project’s parking supply will be limited to 577 parking spaces, which is 12 parking spaces below the 589 parking spaces required by the lead agency. This would reduce project-generated VMT by 0.28% or 39 VMT.

This results in a Project generated VMT of 12,559 in the baseline condition and 12,174 in the cumulative condition as shown in DEIR Table 4.15-2. (DEIR, p. 4.15-15, as revised in Section 4.0 of the FEIR)
The Project would generate VMT per capita exceeding the City’s adopted VMT impact threshold by

30.1% in the baseline (2022) conditions and 27.0% for long range (2045) conditions. As a result, the Project would result in a significant VMT impact. Mitigation is required. (DEIR, p. 4.15-15) Transportation demand management (TDM) strategies have been evaluated for the purpose of reducing VMT impacts determined to be potentially significant. The effectiveness of TDM strategies to reduce VMT has been determined based on the 2021 California Air Pollution Control Officers Association (CAPCOA) Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity. In addition to specific tenancy considerations, which may affect the effectiveness of TDM measures, land use context is a major factor relevant to the potential application and effectiveness of TDM measures. More specifically, the land use context of the Project is characteristically suburban. The Project’s suburban context acts to reduce the range of feasible TDM measures and moderates their potential effectiveness. According to the 2021 CAPCOA Handbook, the maximum effectiveness for the TDM measures under the neighborhood design features is 10%.

Consistent with VMT reduction measures described within CAPCOA, reductions to VMT shall include the strategies identified in Mitigation Measure MM 4.15-1. In addition to Mitigation Measure MM

4.15-1, the Project would provide pedestrian improvements within the development connecting to existing off-site facilities.

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 the DEIR.

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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.

4. Require the HOA to create an online community forum where future residents can coordinate ridesharing.

Project components and mitigation measures available to reduce VMT include developing pedestrian network improvements and implementing TDM measures such as those listed in Mitigation Measure MM 4.15-1. Even where the TDM measures are implemented to their maximum effectiveness of 10%, 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 Project is found to have a significant and unavoidable VMT impact on a direct and cumulatively considerable basis. (DEIR, p. 4.15-20)
To ensure that all feasible mitigation measures were incorporated to reduce VMT impacts, in addition to the TDM measures identified above, all measures identified in the 2021 CAPCOA Handbook were considered. As discussed above, the 2021 CAPCOA Handbook describes methods to reduce VMT. As discussed in Attachment C, VMT Reduction Matrix, of the VMT Report (DEIR Technical Appendix N2), all applicable transportation mitigation measures were evaluated to reduce VMT impacts. Even with incorporation of all feasible mitigation measures, impacts would remain significant and unavoidable. (DEIR, p. 4.15-20)
As discussed in DEIR Section 4.12, Population and Housing, the Project would place housing within a job-rich area. Although there would be a significant and unavoidable impact related to VMT, this is due to the fact that the Project site does not currently have transit or alternative transportation opportunities and has a higher VMT per capita compared to the County’s regional average.

Nevertheless, co-locating housing near jobs reduces vehicle travel lengths and associated greenhouse gas emissions caused by long commute distances. (DEIR, p. 4.15-20)

5.4.2 CUMULATIVE IMPACTS
Impact Statement: The Project would result in a cumulative VMT impact since the Project was found to have a significant and unavoidable impact at the project level. The Project would generate VMT per capita exceeding the City’s adopted VMT impact threshold of 14.8 by 31.8% in the baseline condition and 27.7% in the cumulative condition.
 Findings
Potential cumulative impacts of the Project related to transportation are discussed in detail in Section

4.15-6 of the DEIR. The Project would result in a significant cumulative VMT impact. The Project is

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required to comply with Mitigation Measure MM 4.15-1, which would reduce impacts to the extent feasible; however, impacts would remain significant and unavoidable. The City finds that the above mitigation measures are feasible, are adopted, and will reduce some of the proposed Project transportation impacts attributable to trips generated by the proposed Project. However, even where the TDM measures are implemented to their maximum effectiveness of 10%, 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 Project is found to have a significant and unavoidable VMT impact on a direct and cumulatively considerable basis. Pursuant to Section 21081(a)(3) of the California Public Resources Code, as described below, the City has determined that specific economic, legal, social, technological, or other considerations make infeasible the alternatives and mitigation measures identified in the EIR.  Substantial Evidence
Pursuant to the City’s cumulative VMT threshold, a significant cumulative impact would occur if the Project increased the total regional VMT compared to the cumulative no project condition. The Project is not proposing a general plan amendment nor a change of zone. Since the Project is consistent with the underlaying land use assumptions of the General Plan and Zoning the cumulative no project would be the same as the cumulative with project. Therefore, the cumulative impact would be less than significant. (DEIR, p. 4.15-18).

However, the Project would generate VMT per capita exceeding the regional VMT per capita threshold (15% below the regional average) by 27.0% under long range (2045) conditions. Therefore, although the Project would not exceed the City’s adopted cumulative VMT threshold, it would not achieve 15% below the regional VMT per capita threshold under long range (2045) conditions. That said, as noted in the Technical Advisory, “A project that falls below an efficiency-based threshold that is aligned with long-term environmental goals and relevant plans would have no cumulative impact distinct from the project impact. Accordingly, a finding of a less-than-significant project impact would imply a less than significant cumulative impact, and vice versa.”
Nonetheless, to be conservative given that the Project would not achieve 15% below the regional VMT per capita threshold under long range (2045) conditions, this analysis assumes the Project would result in cumulatively considerable VMT impacts. (DEIR, p. 4.15-18)

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6.0 OTHER CEQA CONSIDERATIONS

6.1 SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL CHANGES
The State CEQA Guidelines require EIRs to address any significant irreversible environmental changes that would be involved with the proposed action should it be implemented (CEQA Guidelines § 15126.2[d]). An environmental change would fall into this category if: a) the project would involve a large commitment of non-renewable resources; b) the primary and secondary impacts of the project would generally commit future generations to similar uses; c) the project involves uses in which irreversible damage could result from any potential environment accidents; or d) the proposed consumption of resources is not justified (e.g., the project results in the wasteful use of energy).  Finding
The Project’s potential to result in significant irreversible environmental changes are discussed in detail in Subsection 5.2 of the DEIR. The Project would not result in significant irreversible environmental changes, as described below. Construction and long-term operation of the Project would be compatible with the existing and planned land uses that surround the Project site and would not result in significant physical environmental effects to nearby properties. Although the Project would cause unavoidable impacts to the environment associated with transportation (VMT), the Project’s impact related to VMT would not result in significant irreversible environmental changes. (DEIR, p. 5-2)  Substantial Evidence
One factor in determining whether the Project may result in significant irreversible environmental changes requires a determination of whether key non-renewable resources would be degraded or destroyed in such a way that there would be little possibility of restoring them. (DEIR, p. 5-2) Natural resources, in the form of construction materials and energy resources would be used in the construction of the Project. The consumption of these natural resources would represent an irreversible change to the environment. However, the development of the Project site as proposed would have no measurable adverse effect on the availability of such resources, including resources that may be nonrenewable (e.g., fossil fuels). Additionally, the Project is required by law to comply with the California Building Standards Code (CALGreen), which would minimize the Project’s demand for energy, including energy produced from non-renewable sources. A detailed discussion of energy consumption is provided in DEIR Subsection 4.5, Energy, which determined impacts to be less than significant. (DEIR, p. 5-2)
Implementation of the Project would commit the Project site to residential uses for the lifespan of the Project. As demonstrated in the analysis presented throughout DEIR Section 4.0, Environmental Analysis, construction and long-term operation of the Project would be compatible with the existing and planned land uses that surround the Project site and would not result in significant physical environmental effects to nearby properties. Although the Project would cause unavoidable impacts to the environment associated with VMT, these effects would not commit surrounding properties to land uses other than those that are present under existing conditions. (DEIR, p. 5-2)

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DEIR Subsection 4.8, Hazards and Hazardous Materials, provides an analysis of the Project’s potential to transport or handle hazardous materials which, if released into the environment, could result in irreversible damage to the environment. As concluded in the analysis, compliance with federal, State, and local regulations related to hazardous materials would be required of all contractors working on the property during the Project’s construction and of all users that occupy the Project’s buildings.

As such, construction and long-term operation of the Project would not have the potential to cause significant irreversible damage to the environment, including damage that may result from upset or accident conditions. (DEIR, p. 5-2)
As discussed under DEIR Subsection 4.5, Energy, the Project would not result in a wasteful consumption of energy or the consumption of resources that is not justified. The Project’s energy requirements during construction and operation were analyzed in DEIR Section 4.5, Energy. As discussed, construction energy use would be typical for the type of construction proposed because there are no aspects of the Project’s proposed construction process that are unusual or energy-intensive, and Project construction equipment would conform to the applicable CARB emissions standards.

Construction contractors would be required to comply with applicable CARB regulation regarding retrofitting, repowering, or replacement of diesel off-road construction equipment. The Project is located on an infill site that is surrounded by existing urban uses; the existing transportation facilities and infrastructure would provide future residents, visitors, and employees associated with the Project access to a mix of land uses near the Project, thus further reducing fuel consumption and energy demand. Additionally, the Project will be providing a community electric vehicle for use by residents of the affordable housing component (PDF-GHG-3) as well as providing parking and EV infrastructure (PDF-GHG-4) that would further promote fuel efficient vehicles. In compliance with the California Green Building Standards Code and City requirements, the Project would promote the use of bicycles as an alternative means of transportation by providing short-term and/or long-term bicycle parking accommodations. (DEIR, pp. 5-2 to 5-3)
Because no significant non-renewable resources occur within the Project site, the Project would also not reduce the availability of non-renewable resources associated with long-term operational activities.

Accordingly, the Project would not result in a significant, irreversible change to the environment related to energy use. (DEIR, p. 5-3)

6.2 GROWTH-INDUCING IMPACTS
CEQA requires a discussion of the ways in which the Project could be growth-inducing. The State CEQA Guidelines identify a project as growth-inducing if it would foster economic or population growth or the construction of additional housing, either directly or indirectly, in the surrounding environment (CEQA Guidelines § 15126.2 [e]).
 Finding
The Project’s potential to result in growth-inducing impacts is discussed in detail in Subsection 5.3 of the DEIR. For the reasons described in detail below, the Project will not 1) remove obstacles to growth because the Project’s proposed utility infrastructure, on- and off-site, are designed to accommodate

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only the proposed development as opposed to widespread, new development; 2) result in the need to expand one or more public services (see Public Services of the DEIR); 3) encourage or facilitate economic effects that could result in other activities that could significantly affect the environment; and 4) involve a precedent setting action that could encourage and facilitate other activities that could significantly affect the environment because there are no proposed changes to the type or location of uses allowed by the General Plan and zoning ordinance. Based on the entire record, the City finds that the Project would not directly or indirectly induce growth in the surrounding area which could result in a significant adverse effect to the environment.
 Substantial Evidence
Would this project remove obstacles to growth (e.g., a major expansion of a wastewater treatment plan that may allow for more construction in service areas)? No. Due to the developed nature of the Project site, the existing structures are currently connected to the existing utility infrastructure beneath Lampson Avenue and generate a demand for utility services.

The Project involves the redevelopment of the Project site with residential uses, consistent with the existing land use designation and zone classification for the Project site. The proposed residential uses would be developed in accordance with the City’s development standards. Furthermore, the Project accommodates the growth and development anticipated in the City’s 2021-2029 Housing Element and would not change existing regulations pertaining to land development. (DEIR, p. 5-4) The Project does not require the construction or extension of roadways; however, the Project would include the installation of new on-site utility connections to existing utility infrastructure and the construction of approximately 1,200 linear feet of water line off-site within Lampson Avenue to serve the development. The Project would not create major new infrastructure that could result in substantial, unplanned growth because the Project’s proposed utility infrastructure, on- and off-site, are designed to accommodate only the proposed development as opposed to widespread, new development.

Therefore, the Project is not considered to be growth inducing with respect to the removal of obstacles to growth. (DEIR, p. 5-4)
Would this project tax existing community service facilities, requiring construction of new facilities that could cause significant environmental effects? No. As discussed in DEIR Subsection 4.13, Public Services, and 4.14, Recreation, the Project would increase the demand for public services (police, fire, schools, libraries, and parks and recreational facilities). The proposed residential use would create the typical range of service calls for police and fire services that occur with this type of use. However, per correspondence with Orange County Fire Authority, Los Alamitos Police Department, Los Alamitos Unified School District, and Orange County Public Libraries (DEIR Technical Appendix L), the Project would not necessitate the unplanned construction of new, or the expansion of existing, public service facilities in order to maintain desired levels of service. Secured Fire Protection Agreements would ensure that response times and service ratios are met within its service area and facilities are upgraded as needed. The existing police services and resources would be adequate to meet the additional demands generated by the Project.

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Additionally, funding mechanisms such as a Secured Fire Agreement, the City’s General Fund revenue, development impact fees, and in-lieu fees are in place through existing regulations and standard practices to accommodate growth in the City, including the Project. As discussed in DEIR Subsection 4.17, Utilities and Service Systems, there is adequate water, wastewater, and storm drain infrastructure and capacity to serve the Project site. This Project would not, therefore, have significant growth-inducing consequences with respect to public services or utilities and service systems. (DEIR, pp. 5-4 to 5-5)
Are there characteristics of the project that encourage and facilitate other activities that could significantly affect the environment, either individually or cumulatively? For example, would this project encourage or facilitate economic effects that could result in other activities that could significantly affect the environment?
No. A project could indirectly induce growth at the local level by increasing the demand for additional goods and services associated with the increase in project population and thus reducing or removing barriers to growth. This occurs in suburban or rural areas where population growth results in increased demand for service and commodity markets responding to the new population. This type of growth is, however, a regional phenomenon resulting from the introduction of a major employment center or regionally significant housing project. For example, additional commercial uses may be drawn to the area by the increased number of residents in the area. (DEIR, p. 5-5) Construction jobs from Project implementation would result in economic growth. During Project construction, a number of design, engineering, and construction-related jobs would be created.

However, this would be temporary in nature and would only last until Project construction is completed. Construction impacts including construction worker commute trips and associated impacts were analyzed throughout the DEIR, specifically in Subsections 4.2, Air Quality, 4.7, Greenhouse Gas Emissions, and 4.11, Noise; the Project’s impacts analyzed under these environmental topics were determined to be less than significant. (DEIR, p. 5-5)
As further described in DEIR Section 3.0, Project Description, the Project is proposing the development of up to 246 new residential units. The Project’s proposed 246 households and 647 residents were anticipated by the City’s General Plan projections. The City’s Housing Element projected an increase of 2,023 people in the next eight years based on the RHNA allocation. The Project site is identified within the City’s Housing Element as a housing element site with an estimate of 246 units. Development of the Project with a total of 246 units would be consistent with the City’s 2021– 2029 Housing Element. Additionally, the City’s General Plan designates the Project site for “MultiFamily Residential-25” land use and the Project site is zoned as “Multi-Family Residential (R-3).” The maximum permitted density is 25 dwelling units per net acre and Project’s proposed overall density is 20 dwelling units per acre. Therefore, the Project would be consistent with the General Plan land use and zoning designations and anticipated growth. Therefore, implementation of the Project’s proposed residential use would support existing uses in the area and would facilitate the growth envisioned in the City’s 2021-2029 Housing Element. (DEIR, p. 5-5)

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As development occurs onsite, Project residents would seek shopping, entertainment, employment, home improvement, auto maintenance, and other economic opportunities in the surrounding area.

Additional commercial uses may be drawn to the area by the increased number of residents in the area.

The Project is located near existing employment centers and retail areas, which would help serve the employment and shopping needs of the future residents. According to the General Plan Housing Element, the City is an employment hub and its principal employers, as of 2021 (most current data available) include hospitals, aerospace manufacturers, business services, and restaurant/wholesale trade. DEIR Table 5-1, City of Los Alamitos Top Employers, lists the top employers in the City in 2021 and their distances from the Project site. (DEIR, p. 5-6) There are several existing retail areas near the Project site within the City and surrounding cities (Cypress, Seal Beach, and Garden Grove). The nearest retail areas to the Project site include Old Ranch Town Center located at 12320-12430 Seal Beach Boulevard in the city of Seal Beach approximately

1.04 miles west and The Shops at Rossmoor located at 12501 Seal Beach Boulevard in the city of Seal Beach approximately 1.3 miles west. The Project site is already served by nearby commercial uses.

Therefore, the Project’s introduction of residents on the Project site would not induce substantial growth in the area. (DEIR, p. 5-6)
Are there characteristics of the project that encourage and facilitate other activities that could significantly affect the environment, either individually or cumulatively? For example, would approval of this project involve some precedent setting action that could encourage and facilitate other activities that could significantly affect the environment? No. As identified above, there are no proposed changes to the type or location of uses allowed by the General Plan and zoning ordinance. Further, no changes to any of the City’s building safety standards (i.e., building, grading, plumbing, mechanical, electrical, fire codes) are proposed or required to implement this Project. As identified in EIR Sections 4.1 through 4.17, the Project would be implemented in accordance with applicable regulations and identified mitigation measures, which would ensure there are no conflicts with adopted land development regulations and environmental impacts are minimized to the extent feasible. The Project does not propose any precedent-setting actions that, if approved, would specifically allow, or encourage other projects and resultant growth to occur. Furthermore, the Project is not extending any infrastructure that would facilitate further development. In the event that another property owner were to propose development or redevelopment of a property in the Project vicinity or in any part of the City, that project would require evaluation under CEQA based on its own merits, including an analysis of direct and cumulatively considerable effects. Therefore, approval of the Project would not involve some precedent setting action that could encourage and facilitate other activities that could significantly affect the environment. (DEIR, pp. 5- 6 to 5-7)

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7.0 ALTERNATIVES

7.4.1 ALTERNATIVES CONSIDERED AND REJECTED
An EIR is required to identify any alternatives that were considered by the Lead Agency but were rejected. Factors described by CEQA Guidelines Section 15126.6 in determining whether to exclude alternatives from detailed consideration in the EIR include: a) failure to meet most of the basic project objectives, b) infeasibility, or c) inability to avoid or substantially lessen one or more significant environmental impacts. The Project’s significant impact that cannot be mitigated to less than significant are: traffic (VMT).

With respect to the feasibility of potential alternatives to the proposed Project, CEQA Guidelines Section 15126.6(f)(1) provides:
“Among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries…and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site…” In determining a range of reasonable alternatives to be evaluated in the EIR, a number of possible alternatives were initially considered and, for a variety of reasons, rejected. Alternatives were rejected because either: 1) they could not accomplish most of the basic objectives of the Project, 2) they would not have avoided or substantially lessened significant adverse environmental impacts, or 3) they were considered infeasible to construct or operate. Alternatives that were considered but rejected are described below.

Alternative Sites
CEQA requires that the discussion of alternatives focus on alternatives to the project or its location that are capable of avoiding or substantially lessening any significant effects of the project. The key question and first step in the analysis is whether any of the significant effects of the project would be avoided or substantially lessened by developing the project in another location. Only locations that would avoid or substantially lessen any of the significant effects of the project need be considered for inclusion in the EIR (CEQA Guidelines Section 15126.6(f)(2). In addition, an alternative site need not be considered when implementation is “remote and speculative,” such as when the alternative site is beyond the control of a project applicant. (DEIR, p. 6-4) The Project proposes to redevelop an approximately 12.3-acre site with 246 residential units. Given the size and type of the proposed development, a similarly sized project and land use elsewhere would likely result in the same or similar transportation impacts. However, if the Project was located in a Transit Priority Area (TPA), significant and unavoidable VMT impacts could be eliminated. Currently, there is only one TPA in the City of Los Alamitos that is located at the intersection of Los Alamitos Boulevard and Katella Avenue. This area is currently developed with commercial uses and is not planned for residential uses. This area has a General Plan designation of Commercial and a zoning designation of General Commercial (C-G). A General Plan Amendment and Zone Change would be

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required to develop residential uses in this area. Implementing the Project on a different parcel within the TPA would require acquisition of developed property, demolition of existing operational structures, and discontinuing existing land uses, which would likely be disruptive to existing businesses and operations. (DEIR, p. 6-4)
The Project site currently has a General Plan land use designation of “Multi-Family Residential-25” and a zoning designation of R-3 (Multi-Family Residential). The Project is consistent with the General Plan land use and zoning designations, and therefore the Project does not require a general plan amendment or zone change to implement the development. Furthermore, the Project Applicant does not control any other parcels of land in or near the Project site that could be used as an alternative location for the proposed Project. (DEIR, p. 6-4)
Therefore, because an alternative location is not available that would avoid or substantially lessen the significant environmental effects of the Project, and because the Project Applicant does not have control over, and cannot reasonably obtain control over, any other parcels of land in the jurisdiction of the City that could accommodate the Project, an alternative location alternative is not feasible.

Accordingly, this alternative is not further considered in the Draft EIR. (DEIR, p. 6-4) Alternatives to Eliminate or Lessen VMT Impacts
The Project would only result in one significant and unavoidable impact, i.e., impacts related to traffic (VMT) generated by the Project. All other impacts of the Project would be mitigated to less than significant with incorporation of mitigation measures. With the exception of VMT impacts, all environmental impacts of the Project are related to the physical disturbance of the Project site during construction activities and are not specific to the Project itself but are a result of redevelopment of the Project site. In other words, construction-related impacts related to biological resources, cultural resources, geology and soils, and tribal cultural resources would occur with any type of redevelopment of the Project site and would result in the need for the same or similar mitigation measures. The only alternative that would eliminate the construction-related biological resources, cultural resources, geology and soils, and tribal cultural resources impacts is the No Project/ No Development Alternative. (DEIR, p. 6-5)
A variety of alternatives were considered that would eliminate or lessen the Project’s significant and unavoidable VMT impacts. Pursuant to the Governor’s Office of Planning and Research (OPR) Technical Advisory on Evaluating Transportation Impacts in CEQA dated December 2018, projects that meet one of the screening criteria below, would not have a VMT impact. (DEIR, p. 6-5) • Small Project Screening
• Map Based Screening
• Transit Priority Area (TPA) Screening
• Local Community Serving Project Type Screening
An alternative that meets the Small Project screening criteria would require the Project to generate fewer than 110 daily vehicle trips. In order to meet this criterion, the Project would need to be

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significantly reduced to approximately 10 dwelling units, which would not be consistent with the City’s General Plan or its Housing Element. As discussed in Section 4.12, Population and Housing, the City adopted its General Plan Housing Element to reflect the 2021-2029 cycle on February 21, 2023. The Project site is located within the Multiple-Family Residential-25 General Plan designation, which specifies a density range of 20 to 25 dwelling units per acre. Moreover, the Project site is identified within the City’s Housing Element as a housing element site with an estimate of 246 units, which is identified to meet the Regional Housing Needs Allocation (RHNA) target of 769 units citywide.

Furthermore, this alternative would not meet any of the Project Objectives. Therefore, this alternative was rejected from further consideration. (DEIR, p. 6-5) In order to meet the Map Based screening criteria, the Project would need to be relocated into a transportation analysis zone (TAZ) with a low VMT. As discussed in detail above, an alternative location is not feasible because an alternative location is not available that would avoid or substantially lessen the significant environmental effects of the Project, and the Project Applicant does not have control over, and cannot reasonably obtain control over, any other parcels of land in the jurisdiction of the City that could accommodate the Project. Therefore, this alternative was rejected from further consideration. (DEIR, p. 6-5)
In order to meet the TPA screening criteria, the Project would need to be relocated to a TPA. As discussed in detail above, an alternative location is not feasible because there is only one TPA in the City of Los Alamitos that is currently used for commercial uses and not planned residential uses.

Therefore, similarly, this alternative was rejected from further consideration. (DEIR, p. 6-5) In order to meet the Local Community Serving Project Type screening criteria, the proposed land use would need to change from residential to commercial uses. Commercial uses would result in a substantial increase in vehicle trips in comparison to the Project, which would increase air quality, energy, greenhouse gas, and noise impacts. Additionally, this alternative would not meet any of the Project objectives and therefore was rejected from further consideration. (DEIR, p. 6-6) Based on the preceding, alternatives to eliminate VMT impacts were rejected from further consideration. (DEIR, p. 6-6)
Reduced Density Alternative
The Reduced Density Alternative, which assumes the Project Site is proposed for a 25% reduction in residential units, was considered to analyze an alternative that could potentially accomplish most of the project objectives of the Project and could avoid or substantially lessen one or more of the Project’s significant effects. (DEIR, p. 6-6)
Although a Reduced Density Alternative would have the ability to partially meet most of the Project objectives, it was rejected from further consideration because it would not avoid or substantially lessen the Project’s significant impacts. More specifically, this alternative would not avoid the Project’s significant and unavoidable VMT impacts. VMT impacts are evaluated based on VMT per capita (population). Although the Reduced Density Alternative would reduce vehicle trips and VMT, it would