Agenda packet — Orange City Council, April 11, 2023 (part 3 of 14)

4 PED PB ISOLATION UNIT
1 POWER BUSS PANEL, 6 CONN

ECONOLITE SYSTEMS CABINET TESTING
3 CAB18773P 1 BATAVIA @ GROVE AVE (RR)
TS2-2 PNG P44 BM 16 HORIZ RR CAB IN/OUTWHITE
INCLUDES THE FOLLOWING:
1 CABINET 55", PAINT IN/OUT SAME
2 LIP, REAR, SHELF, P44/R77
1 DRAWER, DOOR MOUNTED,
1 THERMOSTAT KTS 011 (NO)
4 ANCHOR BOLT, 18 X 3/4 X 2.5
1 FILTER AIR 12 X 16 X 1
2 SHELF, STANDARD, P44/R77
1 DUAL FAN PANEL
1 LOCK, CABINET, DEAD BOLTWITH 2 KEYS,
CORBIN
1 LOCK, SUB TREASURY, BEVEL BOLTW/2 KEYS
LONG 04266
1 LED, T12 SIGN LAMP, 8 WATT

DETECTION
1 PANEL, LOOP INTERFACE
1 DETECTOR RACK, TS2 16 CH
MISC
2 CKBKR 10A 1P 120/240V
1 CIRCUIT BRKR, 15A, 1P 120/240V
1 IC, MEMORY, TOKEN
1 SURGE PROTECTOR AC 120V
1 CIRCUIT BRKR, 20A 1P 120/240V

PLUG-INS
1 MMU2-16LEip-E W/ETHERNET PORT
6 FLASH TRANSFER RELAY
16 LOAD SWITCH W/INPUT IND, SSR
1 FLASHER, 2 CKT 15A SOLID STATE
1 PWR SUPPLY, 5 AMP EDI PS-250-E

SUB-ASSEMBLIES
2 POWER STRIP, 4 OUTLET, 15 AMP
1 STAGGERED DUAL BUSS BARAC NEUTRAL, BOTH
RAISED
5 CABLE, SDLC BUSS TO 15M
1 HUB, SDLC, 5-CONNECTOR
1 POWER AUX PANEL, TS2
1 ASSY, LOAD RESISTOR
1 BIKE PUSH BUTTON PANEL
1 BUS INTERFACE UNIT 3.0
1 MAIN PANEL, TS1 PNG
1 POLICE/AUX SWITCH PANEL
4 PED PB ISOLATION UNIT
1 POWER BUSS PANEL, 6 CONN
1 ASSY, RAILROAD PREEMPTION PNL
$40.36 $17,757.78 $17,757.78
295
Quotation
1250 N. Tustin Ave. Anaheim, Ca. 92807
econolite.com/feedback

Page 4 ends

ECONOLITE SYSTEMS CABINET TESTING
4 CAB18772P 1 CHAPMAN AVE @ MANCHESTER/CITY PARKWAY
NORTH TS2-2 PNG P44 BM 16 HORIZ CAB
IN/OUT-WHITE (2 RACKS)
INCLUDES THE FOLLOWING:
1 CABINET 55", PAINT IN/OUT SAME
2 LIP, REAR, SHELF, P44/R77
1 DRAWER, DOOR MOUNTED,
1 THERMOSTAT KTS 011 (NO)
4 ANCHOR BOLT, 18 X 3/4 X 2.5
1 FILTER AIR 12 X 16 X 1
2 SHELF, STANDARD, P44/R77
1 DUAL FAN PANEL
1 LOCK, CABINET, DEAD BOLTWITH 2 KEYS,
CORBIN
1 LOCK, SUB TREASURY, BEVEL BOLTW/2 KEYS
LONG 04266
1 LED, T12 SIGN LAMP, 8 WATT

DETECTION
1 PANEL, LOOP INTERFACE
2 DETECTOR RACK, TS2 16 CH
MISC
2 CKBKR 10A 1P 120/240V
1 CIRCUIT BRKR, 15A, 1P 120/240V
1 IC, MEMORY, TOKEN
1 SURGE PROTECTOR AC 120V
1 CIRCUIT BRKR, 20A 1P 120/240V

PLUG-INS
1 MMU2-16LEip-E W/ETHERNET PORT
6 FLASH TRANSFER RELAY
16 LOAD SWITCH W/INPUT IND, SSR
1 FLASHER, 2 CKT 15A SOLID STATE
1 PWR SUPPLY, 5 AMP EDI PS-250-E

SUB-ASSEMBLIES
2 POWER STRIP, 4 OUTLET, 15 AMP
1 STAGGERED DUAL BUSS BARAC NEUTRAL, BOTH
RAISED
5 CABLE, SDLC BUSS TO 15M
1 HUB, SDLC, 5-CONNECTOR
1 POWER AUX PANEL, TS2
1 ASSY, LOAD RESISTOR
1 BIKE PUSH BUTTON PANEL
2 BUS INTERFACE UNIT 3.0
1 MAIN PANEL, TS1 PNG
1 POLICE/AUX SWITCH PANEL
4 PED PB ISOLATION UNIT
1 POWER BUSS PANEL, 6 CONN

ECONOLITE SYSTEMS CABINET TESTING
$42.55 $18,488.51 $18,488.51
5 44665G68 31 DET, 2 CH, SS OUTPUT, RACK MTG RENO A&E G68-E ECPI FRONT PLATE$2.20 $221.90 $6,878.90 296
Quotation
1250 N. Tustin Ave. Anaheim, Ca. 92807
econolite.com/feedback

Page 5 ends

Unless specifically requested or noted on this quotation, the product(s) quoted herein may or may not comply with any Buy America requirements.

Cabinet designs are considered final at time of order. Changes requested after date of order may result in additional fees and extended shipping lead times.

The information transmitted is intended only for the person or entity to which it is addressed and may contain confidential and/or legally privileged material. Any review, retransmission, dissemination, or other use of, or taking of any action in reliance upon, this information by persons or entities other than the intended recipient is prohibited except as required by law.

Quote Valid For Days: 60
FOB: Econolite Factory
Terms: NET30
*Ship Terms: PPD
**Taxes and Tariffs Estimated (if included)
Corey Kelly
Corey Kelly, Account Manager
Mobile: +1 7142734912
[email protected]
Shipping Date: To be determined at time of receipt of order SubTotal $78,229.57
Shipping & Handling*
Taxes** $6,062.79
Tariffs** $231.77
TOTAL $84,524.13
297
To: City of Orange
From: Corey Kelly
Date: 1-27-23
Re: Sole Source
To whom it may concern,

This letter is to verify that Econolite located at 1250 N. Tustin Ave., Anaheim, California 92807 is the sole developer, provider or manufacturer of any and all, “Econolite” and “Safetran” products in the state of California.

This would include:

1. Plug-N-Go Cabinets: TS1 and TS2

2. Controllers: Cobalt® and Safetran 2070®. This also includes any products or licensing that would be associated with Econolite proprietary products. Example: ASC3® or EOS® software upgrades can only be purchased through Econolite as the software is developed, registered, and licensed for use only by Econolite.

3. System software: Centracs®, Centracs MOE®, Centracs SPM®. Example: Centracs® software upgrades can only be purchased through Econolite as the software is developed, registered, and licensed for use only by Econolite.

4. Autoscope® video detection: ENCORE®, Rack Vision Terra® and Vision® are registered trademarks of Image Sensing Systems. Econolite is the sole distributor of Autoscope® products in the United States.

5. Econolite Blue Series Cabinets.

6. In-ground wireless detection: Econolite-branded AccuSense® sensors, peripherals, and software.

7. Econolite Signals and Display Products

8. Econolite branded BIU’s, Load Switches, Power Supplies, Zinc Blue UPS and any other products with the Econolite® name.

If you have any questions concerning this matter, please contact me at (714) 273-4912.

We appreciate the opportunity for your business!
Thank You,
Corey Kelly
Econolite
298
Agenda Item
City Council
Item #: 3.17. 4/11/2023 File #: 23-0226
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Sean deMetropolis, Fire Chief

1. SUBJECT
Authorize the increase of purchase order for rescue ambulance gurney service and repair from Stryker Medical.

2. SUMMARY
Stryker Medical provides rescue ambulance gurney service and repair, which are used on all emergency transports. The costs of these services have exceeded the original budgeted amount.

3. RECOMMENDED ACTION
Approve the increase of purchase order for rescue ambulance gurney service and repair for $15,000 from Stryker Medical.

4. FISCAL IMPACT
The total expenditure for this purchase is $15,000 and will be funded through General Fund (100).

5. STRATEGIC PLAN GOALS
Goal 1: Provide for a safe community
b: Provide and maintain infrastructure necessary to ensure the safety of the public.

6. DISCUSSION AND BACKGROUND
Stryker Medial provides rescue ambulance gurney service and repair for the Fire Department. The original purchase order created for Stryker Medical for Fiscal Year 2022-2023 was $17,000. The expenditures have exceeded this amount and an increase is necessary to fulfill our obligations for Fiscal Year 2022-2023.

7. ATTACHMENTS
· None
City of Orange Page 1 of 1 Printed on 4/6/2023
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Agenda Item
City Council
Item #: 3.17. 4/11/2023 File #: 23-0226
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Sean deMetropolis, Fire Chief

1. SUBJECT
Authorize the increase of purchase order for rescue ambulance gurney service and repair from Stryker Medical.

2. SUMMARY
Stryker Medical provides rescue ambulance gurney service and repair, which are used on all emergency transports. The costs of these services have exceeded the original budgeted amount.

3. RECOMMENDED ACTION
Approve the increase of purchase order for rescue ambulance gurney service and repair for $15,000 from Stryker Medical.

4. FISCAL IMPACT
The total expenditure for this purchase is $15,000 and will be funded through General Fund (100).

5. STRATEGIC PLAN GOALS
Goal 1: Provide for a safe community
b: Provide and maintain infrastructure necessary to ensure the safety of the public.

7. ATTACHMENTS
· None
City of Orange Page 1 of 1 Printed on 4/6/2023
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Agenda Item
City Council
Item #: 3.18. 4/11/2023 File #: 23-0233
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Christopher Cash, Public Works Director

1. SUBJECT
Declaring the property located at 692 North Adele Street, former Water Well Site #16, as surplus to the City’s needs, and authorizing the disposal of the property. Resolution No. 11445.

2. SUMMARY
Resolution No. 11445 will declare the property located at 692 North Adele Street, former Water Well Site #16, as surplus to the City’s needs and will authorize the disposal of the property.

3. RECOMMENDED ACTION
Adopt Resolution No. 11445. A Resolution of the City Council of the City of Orange finding that certain City-owned real property located at 692 North Adele Street, also known as Water Well Site No. 16, in the City of Orange is surplus to the City’s needs and authorizing the disposal of said property.

4. FISCAL IMPACT
None.

5. STRATEGIC PLAN GOALS
Goal 2: Be a fiscally healthy community.
d: Effectively manage and develop City assets.

6. DISCUSSION AND BACKGROUND
The subject property was acquired by the City from Conrock in 1978 (Grant Deed, recorded September 1, 1978, in book 12827, book 1255). The property had an existing water well on it at that time. The water well had been installed by the Santa Ana Valley Irrigation Company (S.A.V.I.) when they owned it prior to conveying it to Conrock.

After the City acquired the property, the water well was discovered to have a collapsed casing. The City attempted to pull out the pump located in the well, but because of the collapsed casing, the pump could not be pulled out. The City subsequently destroyed the well per State standard.

The property is approximately 51,867 square feet. About half of the property is flat and usable, and the other half is a steep hillside sloping downward to Santiago Creek. The property is landlocked with the only access being from Santiago Creek or through the Santiago Creek Orange Mobile Home Park. The City has an access easement through the mobile home park to access the property for City of Orange Page 1 of 2 Printed on 4/6/2023
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Item #: 3.18. 4/11/2023 File #: 23-0233
water well purposes only.

Upon adoption of Resolution No. 11445, staff will initiate the process of notifying agencies of the surplus property per the Surplus Land Act (California Government Code Section 55220 et seq.). After the 60 day notification period expires, staff will proceed with the disposition of the property. An appraisal will be obtained by the City for the potential sale of the property.

7. ATTACHMENTS
· Resolution No. 11445
· Location map
· Assessor’s map
· Aerial photo
City of Orange Page 2 of 2 Printed on 4/6/2023
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Agenda Item
City Council
Item #: 3.18. 4/11/2023 File #: 23-0233
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Christopher Cash, Public Works Director

1. SUBJECT
Declaring the property located at 692 North Adele Street, former Water Well Site #16, as surplus to the City’s needs, and authorizing the disposal of the property. Resolution No. 11445.

4. FISCAL IMPACT
None.

5. STRATEGIC PLAN GOALS
Goal 2: Be a fiscally healthy community.
d: Effectively manage and develop City assets.

The property is approximately 51,867 square feet. About half of the property is flat and usable, and the other half is a steep hillside sloping downward to Santiago Creek. The property is landlocked with the only access being from Santiago Creek or through the Santiago Creek Orange Mobile Home Park. The City has an access easement through the mobile home park to access the property for City of Orange Page 1 of 2 Printed on 4/6/2023
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Item #: 3.18. 4/11/2023 File #: 23-0233
water well purposes only.

7. ATTACHMENTS
· Resolution No. 11445
· Location map
· Assessor’s map
· Aerial photo
City of Orange Page 2 of 2 Printed on 4/6/2023
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RESOLUTION NO. 11445

A RESOLUTION OF THE CITY COUNCIL OF

THE CITY OF ORANGE FINDING THAT

CERTAIN CITY-OWNED REAL PROPERTY
LOCATED AT 692 NORTH ADELE STREET,
ALSO KNOWN AS WATER WELL SITE NO. 16, IN

THE CITY OF ORANGE IS SURPLUS TO THE
CITY’S NEEDS AND AUTHORIZING THE
DISPOSAL OF SAID PROPERTY.

WHEREAS, the City of Orange (the “City”) is a municipal corporation exercising governmental functions and powers, organized and existing under the laws of the State of California; and
WHEREAS, the City owns property, which consists of approximately 51,867 square feet and commonly known as 692 North Adele Street, also known as Water Well Site No. 16 (the “Property”); and
WHEREAS, as authorized by California Government Code Section 37350, the City Council finds and determines that the Property is not needed for the purpose for which it was acquired or for any other public purpose and is, therefore, surplus real property as described in the Surplus Land Act, Government Code Section 54221(b)(1); and WHEREAS, pursuant Section 65402 of the California Government Code, the City Council finds and determines that the location, purpose and extent of the proposed disposition of the Property, have been considered and reported on by the Director of the Community Development Department of the City and that said proposed disposition to the Buyer in accordance with the terms and provisions of the Purchase Agreement conforms to the City’s adopted general plan; and
WHEREAS, this City Council, as the "lead agency" under the California Environmental Quality Act ("CEQA"), finds and determines that the sale of the Property is categorically exempt from the provisions of CEQA under Section 15312 of the State CEQA Guidelines relating to the sale of surplus government property; and
WHEREAS, the City Council believes that the sale of the Property is for the common benefit of the City and its residents, and in accord with the public purposes and provisions of applicable State and local law requirements.

NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Orange, on the basis of the facts set forth in the agenda report presented to it and any testimony received at the meeting at which this matter was considered, as follows:

1. The foregoing recitals are true and correct.
305
2 2. The City Council finds and determines that the Property is categorically exempt from the provisions of CEQA under Section 15312 of the State CEQA Guidelines and, accordingly, hereby authorizes and directs the City Clerk to file a Notice of Exemption with the Orange County Clerk.

3. The City Council hereby finds and determines that the Property is not needed for the purpose for which it was acquired or for any other public purpose and is, therefore, surplus real property.

4. The City Manager, or designee, is authorized to prepare and send all notices required by State law related to the declaration of the above identified property as surplus including, without limitation, Notices of Availability of the surplus property to all parties entitled to such notice under the Surplus Land Act, and negotiate with interested parties as provided by State law.

ADOPTED this ____ day of ____________________, 2023
Daniel R. Slater, Mayor, City of Orange
ATTEST:

Pamela Coleman, City Clerk, City of Orange

STATE OF CALIFORNIA )

COUNTY OF ORANGE )

CITY OF ORANGE )
I, PAMELA COLEMAN, City Clerk of the City of Orange, California, do hereby certify that the foregoing Resolution was duly and regularly adopted by the City Council of the City of Orange at a regular meeting thereof held on the day of , 2023 by the following vote:

AYES: COUNCILMEMBERS:

NOES: COUNCILMEMBERS:

ABSENT: COUNCILMEMBERS:

ABSTAIN: COUNCILMEMBERS:

Pamela Coleman, City Clerk, City of Orange
306
307
308
309
310
311
Agenda Item
City Council
Item #: 3.19. 4/11/2023 File #: 23-0208
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Christopher Cash, Public Works Director

1. SUBJECT
Designation of April 28, 2023, as Arbor Day. Resolution No. 11446.

2. SUMMARY
Adoption of Resolution No. 11446 will designate April 28, 2023 as Arbor Day in the City of Orange.

3. RECOMMENDED ACTION
Adopt Resolution No. 11446. A Resolution of the City Council of the City of Orange designating April 28, 2023, as Arbor Day.

4. FISCAL IMPACT
None

5. STRATEGIC PLAN GOALS
Goal 3: Enhance and promote quality of life in the community a: Renovate, maintain, develop, and/or expand public use places and spaces.

Goal 3: Enhance and promote quality of life in the community b: Deliver high quality and safe recreational, social, environmental, educational and cultural services.

6. DISCUSSION AND BACKGROUND
The City of Orange has been performing Arbor Day Events for over 30 years. Our City has been named a Tree City USA by the Arbor Day Foundation for 34 consecutive years. An annual observance of Arbor Day is a requirement for maintaining the City of Orange as a Tree City USA. The Arbor Day plantings allow us to beautify neighborhoods with the involvement of the community by planting hundreds of trees. Arbor Day is a fantastic opportunity to involve the community in the appreciation of trees. The interaction with community members and trees results in a connection with nature and a caring for important green infrastructure. This connection oftentimes spreads to other community members following an event. The direct involvement with this event not only is an opportunity to bring the community together, but it instills a sense of ownership and care for trees.

This is especially important with the involvement of the younger volunteers who often have yet to develop an appreciation for trees prior to such an event.

The observation of Arbor Day and community planting event will be on April 22, 2023. Volunteers from the community will be planting seven 15-gallon Engelmann Oak trees in the parkway on Walnut City of Orange Page 1 of 2 Printed on 4/6/2023
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Item #: 3.19. 4/11/2023 File #: 23-0208
from the community will be planting seven 15-gallon Engelmann Oak trees in the parkway on Walnut Ave, behind the Prospect Elementary School field. The trees are being donated for the event by West Coast Arborists. Participation in an Arbor Day event is required as part of the annual certification for Tree City USA.

7. ATTACHMENTS
· Resolution No. 11446
City of Orange Page 2 of 2 Printed on 4/6/2023
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Agenda Item
City Council
Item #: 3.19. 4/11/2023 File #: 23-0208
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Christopher Cash, Public Works Director

1. SUBJECT
Designation of April 28, 2023, as Arbor Day. Resolution No. 11446.

2. SUMMARY
Adoption of Resolution No. 11446 will designate April 28, 2023 as Arbor Day in the City of Orange.

3. RECOMMENDED ACTION
Adopt Resolution No. 11446. A Resolution of the City Council of the City of Orange designating April 28, 2023, as Arbor Day.

4. FISCAL IMPACT
None

5. STRATEGIC PLAN GOALS
Goal 3: Enhance and promote quality of life in the community a: Renovate, maintain, develop, and/or expand public use places and spaces.

Goal 3: Enhance and promote quality of life in the community b: Deliver high quality and safe recreational, social, environmental, educational and cultural services.

This is especially important with the involvement of the younger volunteers who often have yet to develop an appreciation for trees prior to such an event.

The observation of Arbor Day and community planting event will be on April 22, 2023. Volunteers from the community will be planting seven 15-gallon Engelmann Oak trees in the parkway on Walnut City of Orange Page 1 of 2 Printed on 4/6/2023
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Item #: 3.19. 4/11/2023 File #: 23-0208
from the community will be planting seven 15-gallon Engelmann Oak trees in the parkway on Walnut Ave, behind the Prospect Elementary School field. The trees are being donated for the event by West Coast Arborists. Participation in an Arbor Day event is required as part of the annual certification for Tree City USA.

7. ATTACHMENTS
· Resolution No. 11446
City of Orange Page 2 of 2 Printed on 4/6/2023
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1 RESOLUTION NO. 11446

A RESOLUTION OF THE CITY COUNCIL OF

THE CITY OF ORANGE DESIGNATING
APRIL 28, 2023, AS ARBOR DAY
WHEREAS, in 1872, J. Sterling Morton proposed to the Nebraska Board of Agriculture that a special day be set aside for the planting of trees; and this special day, called “Arbor Day” was first observed with the planting of more than one million trees in Nebraska. This day is now observed throughout the Nation and the World; and
WHEREAS, participating in Arbor Day events promotes the development of civic pride, a sense of community, highlights the importance of planting and caring for trees; and WHEREAS, trees are living green infrastructure, which produce oxygen, clean the air of pollutants, sequester carbon, help manage storm water; provide essential habitat for wildlife; and WHEREAS, trees in our City increase property values, and enhance economic vitality of business areas.

NOW THEREFORE, BE IT RESOLVED by the City Council of the City of Orange as follows:

1. That the foregoing recitals are incorporated in and made part of this resolution by reference;

2. That the City Council does hereby designate Friday, April 28, 2023, as Arbor Day within the City of Orange.

ADOPTED this ____ day of ____________________, 2023
Daniel R. Slater, Mayor, City of Orange
ATTEST:

Pamela Coleman, City Clerk, City of Orange
316
2 STATE OF CALIFORNIA )

COUNTY OF ORANGE )

AYES: COUNCILMEMBERS:

NOES: COUNCILMEMBERS:

ABSENT: COUNCILMEMBERS:

ABSTAIN: COUNCILMEMBERS:

Pamela Coleman, City Clerk, City of Orange
317
Agenda Item
City Council
Item #: 6.1. 4/11/2023 File #: 23-0176
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Christopher Cash, Public Works Director

1. SUBJECT
Old Towne Parking Study Findings and Recommendations.

2. SUMMARY
A comprehensive parking study of Old Towne Orange was authorized by the City Council with the goal of identifying current and future needs and potential parking management tools. The purpose of this report is to present key findings and recommendations.

3. RECOMMENDED ACTION
Receive and file.

4. FISCAL IMPACT
None. While future implementation of certain parking management strategies could have associated fiscal impacts, no funding is currently being requested.

5. STRATEGIC PLAN GOALS

1. Provide for a safe community
b. Provide and maintain infrastructure necessary to ensure the safety of the public.

6. DISCUSSION AND BACKGROUND
Old Towne Orange continues to maintain its historic charm. At the same time, it is in the midst of a gradual and sustained transformation that began over two decades ago, from a quaint shopping district to an increasingly popular destination. As the economic growth continues, there have been questions over whether Old Towne’s existing parking supply will allow for realization of the full landuse potential identified in the City’s General Plan. The Old Towne Parking Study (“Study”) was commissioned in order to provide answers to those questions, and also serve as a basis for developing sound parking policies moving ahead.

Study Scope
The Study comprised four key components:

1. Establish current and future parking demand levels in order to determine any parking deficiencies or imbalances;

2. Identify sustainable parking management strategies that the City can implement, including City of Orange Page 1 of 5 Printed on 4/6/2023 powered by Legistar™318
Item #: 6.1. 4/11/2023 File #: 23-0176

2. Identify sustainable parking management strategies that the City can implement, including providing additional parking supply, if necessary;

3. Identify and prioritize “smart” technologies that could significantly improve parking and traffic efficiency and complement other mobility initiatives.

4. Evaluate the need to modify the City’s in-lieu parking fee program, currently available to development within the Downtown Parking District established in 1998.

Parking Supply and Demand
The study area is generally bounded by Palm Avenue to the north; Palmyra Avenue to the south; Center Street to the east; and Cypress Street to the west (see attached map.) Existing conditions were determined through performing inventory (supply) and parking occupancy surveys (demand.) This was done for a typical weekday and weekend. Then, future demand was projected based on estimating parking generation associated with the area’s remaining development potential and adding to the existing baseline.

Existing Conditions
There exist approximately 2,666 city-owned parking spaces in the Old Towne study area:
· 1,674 off-street spaces (14 city-owned surface lots plus parking structure) · 992 on-street spaces, including unrestricted and time-limited Parking surveys were conducted on a typical weekday and weekend, the data from which was reported on an hour-by-hour basis. Hourly demand and corresponding occupancy rates are shown on the attached charts, generally indicating the following:
· Low utilization (under 30%) between 10 pm and 8 am on weekends, and between 10 pm and 7 am on weekdays.
· Parking supply reaches approximately 50 percent by 10 am throughout the week · Peak occupancy of about 65% on both weekdays and weekends.

While overall parking supply well exceeds demand, even during the peak hours, streets and lots near the center of Old Towne experience very high utilization (85 - 100%) while facilities at or near the periphery of the study area experience low (25 - 50%) or very low (less than 25%) utilization. While this type of parking demand distribution is not unexpected, it contributes to the perception of a parking shortage.

Future Projections
To determine future demand, a shared parking demand model was developed based on the City’s approved land-use plan (which includes projects already entitled but not constructed) and nationwide parking data empirically derived. In addition, the land-use mixture and transportation system were taken into consideration, accounting for interaction between sites (symbiosis), and non-vehicle trips City of Orange Page 2 of 5 Printed on 4/6/2023
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Item #: 6.1. 4/11/2023 File #: 23-0176
taken into consideration, accounting for interaction between sites (symbiosis), and non-vehicle trips into the area.

Based on various scenarios analyzed, the future parking deficiency can be as high as 1,076 spaces or as low as 154 spaces, depending on, among other things, the efficiency of the parking system as a whole and how much additional parking is supplied by future development. Likely, the ultimate shortfall will be around 500 - 600 parking spaces.

Parking Management Strategies and Smart Technologies
Based on the above needs assessment, the current parking supply is more than sufficient for existing conditions. Moreover, there is excess capacity to serve incremental development levels in Old Towne for the foreseeable future. However, the ultimate need for parking facilities is more uncertain, and can further evolve with future changes in travel behavior.

That being said, there are a number of parking management strategies that could be implemented to improve parking efficiency today while better positioning the City for economic development opportunities in the future. Such measures could (1) enhance the existing visitor experience, (2) improve circulation and mobility into and within the area, (3) assist merchants and businesses with creating parking turnover desirable to maximize storefront accessibility, and (4) defer - even potentially eliminate - the need to construct future parking facilities.

Smart Parking Infrastructure
The key parking strategies identified in the Study revolve around the implementation of smart parking infrastructure. Through the use of pavement sensors, cameras, digital signs, interactive apps, and even electronic pay stations, a number of different parking management tools can be integrated to work together.

1. Provide real-time, app-based information that can communicate the availability of parking at a given lot(s). Visitors would then know exactly where and when parking is available, which saves time, eliminates uncertainty, and reduces unnecessary circulation.

2. Facilitate paid parking. While sometimes unpopular when first introduced, this can be effective in creating turnover on high-demand streets and discouraging long-term visitors (and employees) from parking in prime locations. Unlike the obsolete coin-based parking meters, the new generation equipment is easy to use, can accommodate variable and demand-based pricing, streamline fee collection, and assist parking enforcement.

By improving the efficiency of the City’s parking facilities, smart parking technologies can substantially reduce the likelihood (or magnitude) of a future parking deficiency. In addition, any revenue streams generated using smart parking infrastructure could potentially be used for maintenance or fund other parking management programs. While the Study evaluated the availability and use of such technologies at a high-level, specific equipment and associated costs can be further investigated, along with phased deployment and funding strategies. This effort has been proposed in the form of a formal project contained in the Fiscal Year 2023-2024 Capital Improvement Program.

City of Orange Page 3 of 5 Printed on 4/6/2023
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Item #: 6.1. 4/11/2023 File #: 23-0176
Additional parking supply
This can be achieved through a combination of constructing more off-street parking or leasing privately owned spaces for public use. However, surface parking lots require large footprints and parking structures/garages are expensive to construct.

One potential augmentation to the City’s parking supply would be the possible development of the Grand Street Parking Lot. Primarily situated on the Old Fire Station Headquarters site, the property has the capacity to yield an additional 165 parking spaces. Given that the land is already city-owned, surface parking represents a cost-effective and flexible solution. Any surface parking can easily be repurposed in the future as conditions dictate and/or a better use for the site is identified.

Parking In-Lieu Fee
In 1998, the City established the Downtown Parking District, within which developers could pay a nominal fee in-lieu of providing code parking. At the time the study was commissioned, there was concern that the fee structure was insufficient for addressing long term needs and, because of its narrow boundaries, excluded many property owners from participating. Since then, Assembly Bill 2097 was passed, which limits the ability for municipalities to require developers to provide code parking within a ½ mile radius of a major transit center. The Orange Transportation Center, anchored by its Metrolink Station, meets that definition, and the entire study area falls within the ½ mile threshold. As a result, future development in this area can no longer be required to provide for the Municipal Code prescribed parking requirements. Because the concept of an in-lieu fee is premised on an enforceable code parking requirement, AB 2097 effectively renders the in-lieu fee untenable moving forward.

Notwithstanding, parking fees can still be charged, but must take on the form of a mitigation fee or a business improvement/special assessment district. Revenues collected from the former would only be available for capital investments whereas the latter can also fund maintenance and operations.

While further discussion and analysis would be required to implement either of these fee options, the Study lays the groundwork for doing so and, at the same time, identified maximum economically feasible fee levels as follows:
· One Time $10,000 per code prescribed parking space for new development · Annual Fee of $300-$600 per business for either new or all development In addition, any fees could be applied to the entire Study area, rather than the original eight square blocks that comprise the Downtown Parking District. Expanding the boundaries of any future fee area can serve to promote redevelopment in Old Towne while increasing revenue streams.

Summary
While the Study provides short and medium-term reassurances over the Old Towne parking supply, it does identify the possibility of an ultimate need if Old Towne is to fully build out. Whereas the City could previously expect future development to contribute toward additional parking supply, recent legislation precludes doing so. Therefore, if the City is to facilitate General Plan buildout of the area, it must look to alternatives for balancing parking supply and demand. The Study indicates that the more effective parking management strategies involve smart infrastructure and capital investment, City of Orange Page 4 of 5 Printed on 4/6/2023
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and also identifies sustainable funding mechanisms that may warrant further consideration.

7. ATTACHMENTS
· Study Area Map
· Existing Parking Demand Chart
· Staff Report Authorizing Parking Study, August 2021
· Old Towne Parking Study
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Agenda Item
City Council
Item #: 6.1. 4/11/2023 File #: 23-0176
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Christopher Cash, Public Works Director

1. SUBJECT
Old Towne Parking Study Findings and Recommendations.

3. RECOMMENDED ACTION
Receive and file.

4. FISCAL IMPACT
None. While future implementation of certain parking management strategies could have associated fiscal impacts, no funding is currently being requested.

5. STRATEGIC PLAN GOALS

1. Provide for a safe community
b. Provide and maintain infrastructure necessary to ensure the safety of the public.

Study Scope
The Study comprised four key components:

1. Establish current and future parking demand levels in order to determine any parking deficiencies or imbalances;

2. Identify sustainable parking management strategies that the City can implement, including City of Orange Page 1 of 5 Printed on 4/6/2023 powered by Legistar™323
Item #: 6.1. 4/11/2023 File #: 23-0176

2. Identify sustainable parking management strategies that the City can implement, including providing additional parking supply, if necessary;

3. Identify and prioritize “smart” technologies that could significantly improve parking and traffic efficiency and complement other mobility initiatives.

4. Evaluate the need to modify the City’s in-lieu parking fee program, currently available to development within the Downtown Parking District established in 1998.

Future Projections
To determine future demand, a shared parking demand model was developed based on the City’s approved land-use plan (which includes projects already entitled but not constructed) and nationwide parking data empirically derived. In addition, the land-use mixture and transportation system were taken into consideration, accounting for interaction between sites (symbiosis), and non-vehicle trips City of Orange Page 2 of 5 Printed on 4/6/2023
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taken into consideration, accounting for interaction between sites (symbiosis), and non-vehicle trips into the area.

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Additional parking supply
This can be achieved through a combination of constructing more off-street parking or leasing privately owned spaces for public use. However, surface parking lots require large footprints and parking structures/garages are expensive to construct.

Summary
While the Study provides short and medium-term reassurances over the Old Towne parking supply, it does identify the possibility of an ultimate need if Old Towne is to fully build out. Whereas the City could previously expect future development to contribute toward additional parking supply, recent legislation precludes doing so. Therefore, if the City is to facilitate General Plan buildout of the area, it must look to alternatives for balancing parking supply and demand. The Study indicates that the more effective parking management strategies involve smart infrastructure and capital investment, City of Orange Page 4 of 5 Printed on 4/6/2023
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and also identifies sustainable funding mechanisms that may warrant further consideration.

7. ATTACHMENTS
· Study Area Map
· Existing Parking Demand Chart
· Staff Report Authorizing Parking Study, August 2021
· Old Towne Parking Study
City of Orange Page 5 of 5 Printed on 4/6/2023
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328
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Agenda Item
City Council
Item #: 7.2. 8/10/2021 File #: 21-0405
TO: Honorable Mayor and Members of the City Council
THRU: Rick Otto, City Manager
FROM: Christopher Cash, Public Works Director

1. SUBJECT
Agreement with Fehr and Peers to perform Old Towne Orange Parking Study.

2. SUMMARY
With the addition of popular restaurants and retailers, Old Towne Orange has become more vibrant and inviting than ever before. With this trend expected to continue, it is critical for the City to better understand short and long term parking needs in the downtown area as it plans for the future.

3. RECOMMENDED ACTION

1. Approve the contract with Fehr and Peers in the amount of $92,840 for preparation of the Old Towne Parking Study; and authorize the Mayor and City Clerk to execute on behalf of the City.

2. Authorize the transfer of $92,840 from expenditure account number 952.9810.56020.20247, CITY TRF: NW & SW Merged 2003 Taxable Bonds- SAORA Capital Projects, to expenditure account number 952.9810.51670.20488, CITY TRF: NW & SW Merged 2003 Taxable Bonds - Old Towne Parking Study.

4. FISCAL IMPACT
The total expenditure for this agreement is $92,840 and will be funded in Old Town Parking Study (20488) through CITY TRF: NW & SW Merged 2003 Taxable Bonds (952.)

5. STRATEGIC PLAN GOALS
Goal 1. Provide for a safe community
b. Provide and maintain infrastructure necessary to ensure the safety of the public Goal 3. Enhance and promote quality of life in the community a. Renovate, maintain, develop and/or expand public use of places and spaces

6. DISCUSSION AND BACKGROUND
Over the past few decades, Old Towne Orange has transformed from a quaint shopping district to a popular destination, with the area’s historic character and charm being preserved during the process.

This general trend of converting what was once antique stores to now high-performing restaurants and retail is expected to continue, presenting the City with potential parking challenges and opportunities that must be better understood to ensure adequate parking supply and implement sound parking policies.

Moreover, the City established a Downtown Parking District in 1998 to provide an economic City of Orange Page 1 of 3 Printed on 8/5/2021
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Moreover, the City established a Downtown Parking District in 1998 to provide an economic development incentive for reinvesting in any of the 8 square blocks closest to the Plaza. Within its narrow boundaries, the Parking District (a) provides relief from required parking with changes in building tenancy, and (b) established an “in-lieu” fee whereby any projects adding floor area, or eliminating existing private parking spaces, would contribute funds so the City could then invest into improving parking facilities. Since the Parking District’s inception, the City has collected $111,600.

During this time, the increase in parking generation appears to have substantially outpaced additional parking that could have been created through the collected fees. In addition, potential developments situated outside the boundaries are not eligible to participate in the in-lieu fee, limiting the options that property owners have when contemplating redevelopment. Based on these circumstances and the changes that have occurred in Old Towne, staff believes it is beneficial to reevaluate both the mechanics and boundaries of the Parking District.

Lastly, there has long been uncertainty and at times, frustration, over parking supply and demand in Old Towne. As the City makes future land use decisions, a comprehensive parking document would help to inform those decisions. The recent implementation of the Orange Plaza Paseo and the consideration of scenarios for its continuation has presented potential parking impacts. Those impacts, studied as part of this process, will be considered in the final Paseo implementation.

A well-understood and well-managed parking infrastructure can become a key asset that has the potential to help advance the City’s policy goals. With that in mind, the scope of the Old Towne Parking Study is several fold:
· Establish current and future parking demand to identify any parking deficiencies or imbalances · Determine optimal limits of potential fee area expansion and analyze various fee levels through an economic development and sustainability lens · Identify sustainable parking management strategies that the City can implement, including providing additional parking supply, if necessary, and
· Identify and prioritize “smart” technologies that could significantly improve parking and traffic efficiency
Because this type of study requires highly specialized knowledge, staff recommends retaining the expertise of a transportation and parking consultant. To that end, staff issued a request-for-proposals to four engineering firms known to provide such services. The City received one proposal, from Fehr and Peers. Fehr and Peers has successfully completed parking studies in Orange County, including the cities of Anaheim, Santa Ana, and Garden Grove. More importantly, the firm has delivered on several key projects here in Orange, most recently participating in the City’s effort to modernize its Transportation System Improvement Program (TSIP) fees. From its knowledge of Orange County parking studies, to its rapport with multiple City departments, staff has confidence that Fehr and Peers is well qualified for this important project, and respectfully recommends approval of the professional services agreement. The cost of the project is $92,840.

7. ATTACHMENTS
· Consultant Proposal
City of Orange Page 2 of 3 Printed on 8/5/2021
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Item #: 7.2. 8/10/2021 File #: 21-0405
· Agreement
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Prepared for:

The City of Orange
March 2023
OC21-0831

OLD TOWNE ORANGE

PARKING STUDY
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Table of Contents
Executive Summary ..........................................................................................................................

Introduction ................................................................................................................................... 1 Existing Parking Supply and Demand ......................................................................................... 5 Existing Parking Supply.............................................................................................................................................................. 5 Existing Parking Demand .......................................................................................................................................................... 5 Parking Turnover ........................................................................................................................................................................15 Average Length of Stay ...........................................................................................................................................................18 Existing Conditions Summary ...............................................................................................................................................21 Future Parking Supply and Demand ......................................................................................... 22 Shared Parking Demand Model ...........................................................................................................................................22 Old Towne Future Buildout ....................................................................................................................................................24 Assessment of Future Parking Demand ............................................................................................................................27 Determining Future Parking Deficiencies .........................................................................................................................33 Smart Parking Equipment .......................................................................................................... 34 Old Towne Parking District Boundaries and Fee ..................................................................... 41 Parking Fee Boundaries ...........................................................................................................................................................41 Fee Structures ..............................................................................................................................................................................42 Economic Feasibility ..................................................................................................................................................................42 Parking Strategies Toolbox ........................................................................................................ 44

Appendices
Appendix A: Parking Utilization by Hour (Thursday and Saturday) Appendix B: Old Towne Orange Economic Feasibility Analysis 334
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List of Figures
Figure 1: City of Orange Parking Public Parking Locations Webmap ............................................................................ 2 Figure 2: Old Towne Orange Parking Lots and Street Parking ........................................................................................... 6 Figure 3: Weekday Total Parking Demand .............................................................................................................................. 11 Figure 4: Weekend Total Parking Demand ............................................................................................................................. 12 Figure 5: Peak Hour Parking Utilization (Thursday) ............................................................................................................. 13 Figure 6: Peak Hour Parking Utilization (Saturday) .............................................................................................................. 14 Figure 7: Average Parking Turnover Rate (Thursday).......................................................................................................... 16 Figure 8: Average Parking Turnover Rate (Saturday) .......................................................................................................... 17 Figure 9: Average Parking Length of Stay (Thursday) ......................................................................................................... 19 Figure 10: Average Parking Length of Stay (Saturday) ....................................................................................................... 20 Figure 11: Approved and Planned Project Locations .......................................................................................................... 26 Figure 12: Future Parking Demand by Land Use .................................................................................................................. 28 Figure 13: Future Parking Supply and Demand .................................................................................................................... 32 Figure 14: Old Towne Shuttle “OTiS” ......................................................................................................................................... 49 List of Tables
Table 1: Summary of Off-Street Parking ..................................................................................................................................... 7 Table 2: Summary of On-Street Parking...................................................................................................................................... 9 Table 3: Existing Peak Hour Parking Occupancy ................................................................................................................... 11 Table 4: Parking Demand Peak Hour Comparison ............................................................................................................... 23 Table 5: Future Development List ............................................................................................................................................... 25 Table 6: Summary of Existing and Future Parking Supply Scenarios ............................................................................ 31 Table 7: Summary of Payment Technologies ......................................................................................................................... 35 Table 8: Detection Options Summary ....................................................................................................................................... 39 Table 9: Enforcement Options ...................................................................................................................................................... 40 Table 10: Wayfinding Options Summary ................................................................................................................................. 40 335
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Executive Summary
The City of Orange Old Towne Parking Study was completed to understand the existing and future parking characteristics of public parking in Old Towne. Ultimately, the goal is to provide adequate measures that will improve the quality of the experience for those visiting Old Towne while balancing the needs of the local businesses.

Existing Parking Supply and Demand
Existing parking supply was inventoried for publicly available parking spaces within the study area, which is bounded by Palm Avenue to the north, Palmyra Avenue to the south, Cypress Street to the west, and Center Street to the east. The study area has approximately 2,666 publicly available city-controlled spaces, including 992 on-street parking spaces and 1,674 off-street parking spaces. Most citycontrolled parking spaces in Old Towne are free and unrestricted.

A parking utilization and turnover survey was collected on a Thursday and Saturday in October 2021 to determine existing parking demand and utilization in Old Towne on weekdays and weekends. Hourly parking surveys were conducted for city-controlled on-street and off-street parking from 8:00 AM to 12:00 AM on Thursday and 8:00 AM Saturday to 2:00 AM Sunday. Utilization deficiencies of 85% and 90% in the study area were considered to determine parking deficiencies; deficiencies were noted if more than 85% or 90% of parking spaces were used during a given period. Using this methodology, the survey results demonstrated that Old Towne Orange has sufficient parking supply to serve the current demand.

Key findings of the existing parking analysis are highlighted below.

Parking Utilization and Peak Hour Demand – Based on the data collected, the Old Towne study area currently has a daily average parking utilization of 47% on Thursday and 43% on Saturday for the citycontrolled parking spaces. Over the course of the 2-day parking survey, the peak utilization occurred on Thursday at 1:00 PM with 64% of parking utilized.

In general, the streets and lots closest to the Plaza had the highest utilization. This included Lots 1A, 2-7, Olive Street, Orange Street, Chapman Avenue and Glassell Street. Less utilized areas were Grand Street, and Lots 10-15, including the Old Towne Parking Garage. During the 2-day survey, the Old Towne Parking Garage did not exceed 53% utilization.

Old Towne Specific Plan
Parking Study Goals
Identify parking strategies and
smart parking technologies in
Old Towne to encourage better
utilization of existing parking
facilities, investigate ways for
revenue generation and offset
operational costs, and identify
sustainable parking policies to
help achieve future
development goals.
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Parking Turnover/Average Length of Stay – To
examine long-term parking of individual vehicles in
the Old Towne study area, the parking survey
included an hourly turnover survey along the core
on-street parking segments. Vehicles generally
remain parked for longer periods of time on the
north-south streets—Olive Street and Orange Street.

Parking lengths tend to be shorter on the Plaza and
along Chapman Avenue to the west of the Plaza.

Future Parking Analysis
Future parking demand was estimated by using data
from Shared Parking, Third Edition (Urban Land
Institute [ULI], 2020) applied to pending or approved projects from the City of Orange, and Santa Fe Depot Specific Plan development assumptions. Overall, existing supply would not accommodate the level of development expected from approved projects and buildout of the Santa Fe Depot Specific Plan. If approved projects and the commercial buildout of the Santa Fe Depot Specific Plan1 provide 50% of the parking supply required per the City’s Municipal Code, then the future parking demand could be accommodated.

The findings of the future parking demand assessment are described below to achieve 85% and 90% parking utilization in the study area:
 Scenario 1: No new parking supply is provided in Old Towne. Approved projects and the commercial buildout of the Santa Fe Depot Specific Plan provide no new parking supply. 1,002 parking spaces would be needed on to provide 85% utilization. 799 parking spaces would be needed to provide 90% utilization.
 Scenario 2: Approved projects and the commercial buildout of the Santa Fe Depot Specific Plan provide 50% of the parking spaces required by the City’s Municipal Code. No additional parking spaces will be needed to provide parking at 92% utilization. 287 parking spaces would be needed on to provide 85% utilization. 84 parking spaces would be needed to provide 90% utilization. 1 Residential projects in the Specific Plan were assumed to provide 100% of parking as required by the City’s Municipal Code. This supply is anticipated to be provided on-site for residents and visitors only and is not anticipated to contribute to the demand for additional public parking. 337
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Parking District Fee
Under current operations, the existing parking in-lieu fee may not provide adequate revenue to support more comprehensive parking improvements in Old Towne. The current district boundaries also limit the number of properties that can participate in the fee and does not capture the areas where most new development and redevelopment is expected to occur.

Based on economic feasibility analysis conducted by Economic & Planning Systems, and input from City staff, the following recommendations should be considered for the parking district fee:
 Expand the current fee boundaries to include an area generally bounded by Parker Street, Palm Avenue, Grand Street, and Palmyra Ave
 Convert to in-lieu fee to a parking mitigation fee or special assessment district to offset developments that do not provide parking consistent with the City’s code  A one-time mitigation fee of $10,000 per parking space would be feasible under current economic conditions, and enables redevelopment projects that would otherwise be economically or physically infeasible if all required parking spaces had to be provided on site  Alternatively, an annual special assessment district fee could be levied in place of or in addition to the one-time fee to fund ongoing improvements and operations within the parking district. An annual fee of $300 to $600 per business would be feasible under current economic conditions.

Parking Strategies Toolbox
Based on the review of the existing and future parking conditions, a toolbox of strategies are provided to manage existing and future parking demand in Old Towne:
 Create Additional Parking Supply
 Price On-Street Parking
 Establish Parking Time Limits
 Enforce Valet Service
 Microtransit Pilot Program
 Develop Informational Programs
 Accommodate TNCs
 Update Parking Standards
 Implement Travel Demand Management
This study includes general background information for each parking strategy, including advantages and disadvantages of each approach, and a suggested implementation in Old Towne. As transportation technologies continually advance, new trends and modes of transportation will need to be considered in decisions related to parking and land use to determine the most appropriate solutions or Old Towne. 338
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Introduction
Old Towne is a historic, vibrant mixed-use community located in the heart of the City of Orange. The area features a diverse mix of civic, retail, restaurants, and residential uses in a walkable environment. A variety of community events are hosted throughout the year, including holiday events and a weekly Farmers Market attracting residents and visitors alike.

Chapman University’s campus is located on the north side of Old Towne, and the City’s Metrolink station is on the west side. OCTA bus routes 54, 59, and 453 provide public transit service to Old Towne.

The City, merchants, and property owners embrace the high level of activity in Old Towne; however, concerns over parking demand within Old Towne and the anticipated development in the Santa Fe Depot Specific Plan area nearby have generated the need to study parking to prepare for future growth.

Purpose of the Parking Study
A parking study is intended to comprehensively address parking supply and demand, a parking study can be applied to on-street parking spaces, off-street parking lots, or a combination of on- and off- street parking typically found in a downtown area. Historically, the tendency has been to address parking issues through an increase in supply. In many areas, the desire to increase parking supply results in constructing additional surface lots or parking structures. Developed parking structures may require hundreds of thousands of dollars for maintenance and operation on a yearly basis. This overall approach is costly, as the initial construction cost of a single parking space in a structure can be upwards of $30,000. In addition to potential costs, the approach is not consistent with the historic and urban form that characterizes Old Towne.

Instead of addressing only supply, a parking study addresses the demand for parking, through the management of parking demand, creative informational measures, and the provision of additional supply when necessary. Additionally, a parking study outlines recommendations and strategies for implementation of parking-related improvements. In Old Towne, a parking study is appropriate because there is overall availability of supply within Old Towne currently, but possible future supply shortfalls as additional development occurs. There are also existing parking shortfalls at selected locations or during selected times.
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City of Orange Public Parking Locations Storymaps
The City of Orange maintains an interactive webmap on their website that provides public parking information for 14 public parking facilities in Old Towne such as their locations, number of parking spaces, parking time limit, directions, and street view, as illustrated in Figure 1.

Figure 1: City of Orange Parking Public Parking Locations Webmap Source: City of Orange website, 2022

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Potential Parking Lot on Grand Street
The existing fire station and Grand Street and Almond Avenue may be converted into a public parking lot with up to 163 parking spaces. As this project is preliminary and still being conceptually developed, it was not included in any of the parking supply or demand projections in this study.

Previous Studies
As part of this Parking Study, a review of previous studies completed in Old Towne was conducted to understand the existing context of parking supply and demand in Old Towne and document what the City has done to address parking utilization.

Santa Fe Depot Specific Plan Update (2006)
Adaptive Reuse Analysis
As part of the Santa Fe Depot Specific Plan Update, the City of Orange initiated an analysis of nineteen historic buildings within the Specific Plan area for adaptive reuse. This analysis included a review of all the pertinent historical surveys completed for the buildings, a brief historical and architectural description, character-defining features, suitability for adaptive reuse, and possible new uses for the buildings. The report asserted that parking was a restrictive factor for adaptive reuse suitability. Some of the buildings lacked on-site parking and/or had limited potential for future parking.

Development Capacity Analysis
As part of the Santa Fe Depot Specific Plan, the City of Orange commissioned a development capacity analysis for traffic impact analyses. The purpose was to identify a range of potential alternative land uses appropriate for selected sites (opportunity sites) that correspond to market conditions as well as to evaluate development feasibility and financial feasibility on each site. The evaluation of potential alternative land uses for each opportunity site was based on a series of factors, including the high cost of replacing public parking and the limited options for on-site parking to serve new uses in historic buildings. The analysis included a list of identified parcels likely to develop by 2020, including the nowcompleted Lemon Street surface public parking lot, the now-completed Metrolink surface parking lot, and the Chapman University-owned parking lot on Palm Avenue.

Santa Fe Depot Specific Plan EIR Traffic Study (2011)
The Traffic Study was conducted in 2011 in support of the Program Environmental Impact Report (PEIR) for the Santa Fe Depot Specific Plan. The document describes existing transportation conditions, including a street-by-street parking inventory for the Study Area. 341
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Santa Fe Depot & Downtown Plaza Parking Districts Study (2015) The City of Orange initiated a parking districts study in 2015 to address parking conditions in the Santa Fe Depot Area and the Downtown Plaza District. The purpose of the study was to establish the existing baseline parking conditions in the area, estimate future parking needs and identify options for increasing the parking supply, and evaluate future options. The parking study concluded the following:
 On-street utilization was consistently well used throughout the day whereas the off-street parking utilization was slightly more peaked.
 The study area had peak parking utilization levels that were close to the practical capacity of the parking supply, with the Downtown Plaza District peak utilization being above and the Santa Fe Depot Area utilization being below.
 There was an existing parking shortfall in the Downtown Plaza District which could be satisfied by parkers utilizing surplus capacity in the Santa Fe Depot Area.  There was a minimal increase in parking demand forecast in the future for the Downtown Plaza District because there was very little land available for new development.  There was significant future demand in the Santa Fe Depot Area for projected Specific Plan development growth (approximately 1,300 additional spaces) that would relate to the eventual buildout of the Specific Plan.
 Future parking demands from the Santa Fe Depot Specific Plan would require at least one additional parking garage to be located west of Glassell Street.  The study recommended discontinuing the existing In-Lieu Program as it was not proven to be effective due to the low fee and the difficulty of assembling sufficient revenue to fund capital parking improvements. The study recommended the In-Lieu program be converted into a Parking Credit District and combine the Downtown Plaza and the Santa Fe Depot Parking District into one combined district.

Old Towne West/Metrolink Parking Structure Parking Management Plan (2018) The Parking Management and Maintenance Plans for the Old Towne West/Metrolink parking structure (garage) were finalized in 2018 and establish operating guidelines for the structure. The Plan outlined most parking spaces be allocated for transit patrons with no time limits during the operational hours and the unused transit parking to be available for general public. In addition, the Plan allocated 100 spaces for downtown business use which are located mostly on the ground level of the parking structure with a three-hour time limit.
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Existing Parking Supply and Demand
A parking survey was conducted in October 2021 to determine existing parking supply and demand in Old Towne. The study area is generally bounded by Palm Avenue to the north, Palmyra Avenue to the south, Cypress Street to the west, and Center Street to the east. Figure 2 illustrates the study area, including the city-controlled on-street parking segments and off-street parking lots. Table 1 documents the number of off-street parking lots, each lot’s parking supply, and any identified parking conditions and restrictions related to public access. Table 2 documents the number of on-street parking spaces on each roadway segment.

The parking surveys were collected on Thursday, September 30th and Saturday, October 2nd, 2021. Hourly parking surveys were conducted for city-controlled on-street parking and off-street parking lots from 8:00 AM to 12:00 AM on Thursday and 8:00 AM Saturday to 2:00 AM Sunday.

Existing Parking Supply
There are currently approximately 2,666 parking spaces in the Old Towne study area, including 992 onstreet parking spaces, and 1,674 off-street parking spaces in public parking lots. Parking spaces in Old Towne are mostly free with a mix of unrestricted, permit, and multi-hour time limit.

Existing Parking Demand
Figure 3 and Figure 4 summarize the existing utilization during the peak hours in Old Towne. The parking supply includes all legally available city-controlled parking spaces.

Based on the two-day parking survey, the peak hour parking demands occurred at 1:00 PM on Thursday (64% utilization) and 1:00 PM on Saturday (63% utilization).

By comparison, the 2015 Parking District Study had identified higher parking utilization rates (more than 90%) during peak hours in Downtown Plaza and Santa Fe Depot District based on parking data from 2013. The decrease in utilization rate can be contributed to the addition of new parking facilities including the construction of Old Towne West/Metrolink Parking Structure with 627 spaces. It is also possible that the COVID-19 pandemic has shifted travel patterns, and led to an increase in pick-up and delivery orders which decreased the overall parking utilization.

Public Parking
Supply:

Maximum Parking
Demand:
343
I2
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Palm Ave
Chapman Ave
Palmyra Ave
Lot 2 Lot 1
Lot 3
Lot 5 Lot 4
Lot 6
Lot 8 Lot 7
Lot 9
Lot
10 Lot 11
Lot
12 Lot 13
Lot 14
Lot 15
C:\Users\smusharrat\Downloads\Orange Parking\Orange_GIS\MXD \Study_Area.mxd Figure 2
N
Parking Lots
On-Street Parking (Turnover)
O
On-Street Parking (Utilization)
On-Street Parking (Closed To Parking At Time Of Data Collection) Parking District
I2 Metrolink Station
Old Towne Orange Study Area
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Table 1: Summary of Off-Street Parking
Name Location Total Number
of Spaces Reservations Spaces
Lot 1 South of Chapman Ave, between Orange
St and Grand St 43
Handicap 2
Fire
Department 4
Ride Share 2
Lot 1A South of Chapman Ave, between Orange
St and Grand St 28
3-Hr. Visitor 25
Handicap 2
20 Min. 1
Lot 2 West Orange St, between Chapman Ave
and Almond Ave 93
3-Hr. Visitor 89
Handicap 4
Lot 3 Orange St, between Maple Ave and
Chapman Ave 65
3-Hr. Visitor 61
Handicap 4
Lot 4 Maple Ave and Orange St 19
3 Hr. 18
Handicap 1
Lot 5 Maple Ave and Olive St 26
3-Hr. Visitor 24
Handicap 2
Lot 6 East of Olive St, between Maple Ave and
Chapman Ave 27
3-Hr. Visitor 26
Handicap 1
Lot 7 Olive St, between Chapman Ave and
Almond Ave 13 3-Hr. Visitor 13
Lot 8 West of Olive St, between Chapman Ave
and Almond Ave 53
3-Hr. Visitor 50
Handicap 3
Lot 9 Olive St and Almond Ave 26
3-Hr. Visitor 25
Handicap 1
Lot 10
(Old Towne
West/Metrolink
Parking Structure)
Maple Ave and Lemon St 627
3-Hr. Visitor 118
Handicap 15
Clean Air/Van
Pool/EV 42
Electric Vehicle 5
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Name Location Total Number
of Spaces Reservations Spaces
Lot 11 South of Almond Ave, between Grand St
and Center St 36 Handicap 2
Lot 12 Center St and Almond Ave 99
2-Hr. Visitor 10
Handicap 5
Electric Vehicle 7
Reserved 7
Lot 13 North of Chapman Ave, between Grand
St and Shaffer St 154
5 Minute 2
Handicap 6
Authorized 1
Loading 1
Lot 14 Atchison St east of Metrolink Station 53 Handicap 4 Lot 15 West of Metrolink Station 311 Handicap 4
Total Parking
Spaces Available 1,673
Notes:

The above information is based on fieldwork conducted in October 2021.

In Old Towne West Parking Garage, 447 parking spaces are allocated for Metrolink commuters and, are open to general use after 9:00 am. The 3 Hr. Visitor parking spaces are allocated for downtown business users.

Loading spaces are not included in the parking supply
Permit parking spaces were all at 85% utilization or higher except for Lemon St between Maple Ave and Chapman Ave, Maple Ave between Grand St and Center St, and Grand St between Palm Ave and Maple Ave. Approximately 40 of the available 963 spaces on weekdays are permit parking spaces. For weekends, approximately 20 of 989 available spaces are permit parking spaces. 346
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Table 2: Summary of On-Street Parking
Location Parking Spaces Loading Spaces Reservations Spaces Cypress St B/ Maple Ave - Chapman Ave 36 2
2 Hr. 3
Permit 5
Cypress St B/ Chapman Ave - Almond Ave 32 2 Hr. 4
Lemon St B/ Palm Ave - Maple Ave 37 7
Lemon St B/ Maple Ave - Chapman Ave 19 Permit 12
Lemon St B/ Chapman Ave - Almond Ave 23 2 2 Hr. 2
Lemon St B/ Almond Ave - Palmyra Ave 35
Olive St B/ Palm Ave - Maple Ave 46 Permit 43
Olive St B/ Almond Ave - Palmyra Ave 36
Glassell St B/ Palm Ave - Maple Ave 27
2 Hr. 21
30 Min. 3
Glassell St B/ Maple Ave - Chapman Ave 28 2 Hr. 7
Glassell St B/ Chapman Ave - Almond Ave 22 2 Hr. 5
Glassell St B/ Almond Ave - Palmyra Ave 18
Orange St B/ Palm Ave - Maple Ave 35
1 Hr. 4
Permit 31
Orange St B/ Almond Ave - Washington Ave 19
Orange St B/ Washington Ave - Palmyra Ave 17
Grand St B/ Palm Ave - Maple Ave 39
2 Hr. 5
Permit 34
Grand St B/ Maple Ave - Chapman Ave 29 8 Permit 9
Grand St B/ Chapman Ave - Almond Ave 23
2 Hr. 4
30 Min. 7
Grand St B/ Almond Ave - Washington Ave 19
Grand St B/ Washington Ave - Palmyra Ave 17
Center St B/ Maple Ave - End 20 Permit 20
Center St B/ Chapman Ave - Almond Ave 42 3 2 Hr. 5
Maple Ave B/ Cypress St - Lemon St 8
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Location Parking Spaces Loading Spaces Reservations Spaces Maple Ave B/ Lemon St - Olive St 16
Maple Ave B/ Olive St - Glassell St 14 Permit 6
Maple Ave B/ Glassell St - Orange St 15 1 Hr. 9
Maple Ave B/ Orange St - Grand St 16 Permit 7
Maple Ave B/ Grand St - Center St 20 2 Hr. 3
Almond Ave B/ Cypress St - Lemon St 14
Almond Ave B/ Lemon St - Olive St 13
Almond Ave B/ Olive St - Glassell St 13
Almond Ave B/ Glassell St - Orange St 12
Almond Ave B/ Orange St - Grand St 13
Almond Ave B/ Grand St - Center St 5
Olive St B/ Maple Ave - Chapman Ave 35 30 Min. 4
Olive St B/ Chapman Ave - Almond Ave 27 6 15 Min. 1
Orange St B/ Maple Ave - Chapman Ave 21 6 30 Min. 2
Orange St B/ Chapman Ave - Almond Ave 27 11 2 Hr. 5
Chapman Ave B/ Lemon St - Olive St 17 3 Hr. 2
Chapman Ave B/ Olive St - Glassell St 8 2 Hr. 4
Chapman Ave B/ Glassell St - Orange St 8
Chapman Ave B/ Orange St - Grand St 20
Glassell St/Chapman Ave Circle NW 13
Glassell St/Chapman Ave Circle NE 13
Glassell St/Chapman Ave Circle SE 12
Glassell St/Chapman Ave Circle SW 13
Total Parking Spaces Available 992 23
Note:

The above information is based on fieldwork conducted in October 2021.

Glassell St between Maple Ave and Almond Ave is currently closed-off to parking. The number of parking spaces on this street segment is 54.

Loading spaces and motorcycle parking are not included in the parking supply 348
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Table 3: Existing Peak Hour Parking Occupancy
Day Peak Hour
of Demand
Total
Inventory
Peak Hour
Occupancy
Remaining Parking
Supply % Occupied
Thursday (9/30/2021) 1:00 PM 2,666 1,697 969 64%
Saturday (10/02/2021) 1:00 PM 2,666 1,677 989 63%
Source: Fehr & Peers, 2021
The existing hourly parking supply and demand in the study area on Thursday and Saturday are summarized in Figure 3 and Figure 4.

Figure 3: Weekday Total Parking Demand 452 649 802 855 927 943 901 849 779 713 674 649 643 455 353 277 249 466532601 658681 754 639 600 566 573 586 610 588 528 451 420 384 2,666
34%
45%
54%
57%
60% 64%
58% 54%
50% 49% 48% 48% 46%
38%
30%
26% 24%
0 500
1000
1500
2000
2500
3000 Parking Spaces
Time of Day
Off-Street Parking Demand On-Street Parking Demand Total Supply 349
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Figure 4: Weekend Total Parking Demand
Figure 5 and Figure 6 illustrate the peak hour parking utilization in Old Towne from Thursday and Saturday, respectively. Hourly parking utilization maps for each day of data collection are provided in Appendix A.

Overall, the Thursday and Saturday daily parking trends observed during the data collection show parking supply is approximately half full (50% utilized) by 10:00 AM with midday peaks at 64% occupancy on weekdays and 63% occupancy on weekends. On both days, the PM demand declines after midday and slightly increases after 5:00 PM and starts declining again after 8:00 PM.

Based on the survey data, Thursday had higher parking utilization in the early AM compared to Saturday.

Segments surrounding Downtown Plaza Park along Olive Street, Orange Street, Chapman Avenue, and Glassell Street and most lots between Lemon Street and Grand Street were more than 90% utilized between 10:00 AM and 8:00 PM. Many parking areas were at or near full occupancy, again in those areas closest to the Plaza Park. Some parking locations had occupancy that exceeded supply. In these locations, automobiles parked in unmarked on-street spaces illegally. 483 578 660 719 722 726 680 659 609 598 638 658 650 571 500 454 398 386 340 483578660719 722 788 680 659 609 598 638 658 650 571 500 454 398 386 340 2,666
30%
41%
52%
58% 60% 63%
59% 54%
48% 44%
48% 49% 48%
39%
33%
28%
24% 23%
20%
0 500
1000
1500
2000
2500
3000 Parking Spaces
Time of Day
Off-Street Parking Demand On-Street Parking Demand Total Supply 350
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Almond Ave
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Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100%
Figure 6
Parking Utilization (12:00 PM - Thursday)
351
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Maple Ave
Almond Ave
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Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100%
Figure 7
Parking Utilization (1:00 PM - Saturday)
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Parking Turnover
Parking turnover is the ratio of the number of vehicles parked in a duration to the number of parking spaces available. Parking turnover surveys were collected during the hourly data collection periods for the core on-street parking segments in the study area:
 Chapman Avenue between Lemon Street and Grand Street,  Olive Street between Maple Avenue and Almond Avenue,
 Orange Street between Maple Avenue and Almond Avenue,  The Plaza to the northwest, northeast and southeast corners.

Glassell Street between Maple Avenue and Almond Avenue, and the southwest corner of the Plaza were excluded as these street segments were closed off for parking to accommodate outdoor dining during the survey period.

Since Old Towne does not impose universal parking fees or time restrictions for on-street parking, longterm parking has the potential to create a deficient parking supply, particularly in locations with higher demand. To determine the parking turnover ratio, license plate numbers were recorded for vehicles parked along the street in the study area every hour during the survey period to identify how many vehicles utilized each parking space during the 12- or 14-hour period. Daily segment turnover rates were calculated by dividing the total number of vehicles parked along each roadway segment during the total period divided by the total supply of the same roadway segment, as shown in the equation below:

Daily Turnover Rate = (# Parked Vehicles) ÷ (# Parking Supply) Figure 7 and Figure 8 illustrate the average turnover rates from parking data collected from Thursday and Saturday, respectively. The turnover rate indicates the average number of vehicles using each parking space along the roadway segment in a day. For instance, a roadway segment with 5 available parking spaces and a turnover rate of 3 translates to a total of approximately 15 vehicles parked on the segment throughout the 12-hour study. A lower turnover rate indicates the lack of parking turnover activity occurring along a segment.

The locations with the lowest turnover rates for each day were:
 Orange Street between Maple Avenue and Chapman Avenue  Olive Street between Chapman Avenue and Almond Avenue High turnover rates (more than 7 vehicles per space per day) were most prevalent along Chapman Avenue and the Plaza. Turnover rates on Saturday were observed higher compared to Thursday. 353
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Almond Ave
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Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure 8
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Turnover Rate
(Average Vehicles per Space per Day)
< 4
4 - 5
5 - 6
6 - 7
7 - 8
8+
Average Parking Turnover Rate (Thursday)
354
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Almond Ave
t S dnar G
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t Sr et neC
t S no meL
t Sll essal G
t S evil O
t S sser pyC
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure 9
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Turnover Rate
(Average Vehicles per Space per Day)
< 4
4 - 5
5 - 6
6 - 7
7 - 8
8+
Average Parking Turnover Rate (Saturday)
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Average Length of Stay
Using data from the turnover survey, the average length of stay of parked vehicles was analyzed to identify the average number of hours that vehicles are parked in Old Towne. The average length of stay was assessed to determine the amount and frequency of vehicles that remain parked over an extended period as well as the locations where long-term parking was most prevalent. The parking turnover data revealed the following average lengths of stay over the two-day survey:

Thursday
 74% of vehicles parked for 2 hours or less
 13% of vehicles parked for 4 hours or more
Saturday
 75% of vehicles parked for 2 hours or less
 10% of vehicles parked for 4 hours or more
Figure 9 and Figure 10 illustrate the average
length of stay for each on-street parking segment
where parking turnover data was collected for
Thursday and Saturday, respectively.

As shown, vehicles generally remain parked for
longer periods of time on the north-south streets—
Olive Street and Orange Street. Parking lengths
tend to be shorter on the Plaza and along Chapman Avenue to the west of Plaza Circle. Relatedly, Olive Street and Orange Street have lower turnover rates, while Chapman Avenue and the Plaza have higher rates. The segments with the highest turnover rates by day are listed below:

Thursday:
 Chapman Avenue (north and south side of street) between Lemon Street and Olive Street  Chapman Avenue (north side of street) between Olive Street and the Plaza  The Plaza NE
Saturday:
 Chapman Avenue (north and south side of street) between Lemon Street and Olive Street  Chapman Avenue (south side of street) between Olive Street and Plaza Square  The Plaza SE and Plaza NW Quadrants
 Chapman Avenue (south side of street) between the Plaza and Orange Street 356
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Almond Ave
t S dnar G
t S egnar O
t Sr et neC
t S no meL
t Sll essal G
t S evil O
t S sser pyC
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure 10
N
I2 Metrolink Station
ñ City Hall
Parking District
Average Parking Length of Stay
(Average Hours per Space per Day)
< 2
2 - 3
3 - 4
4+
Average Parking Length of Stay (Thursday)
357
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Maple Ave
Almond Ave
t S dnar G
t S egnar O
t Sr et neC
t S no meL
t Sll essal G
t S evil O
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Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure 11
N
I2 Metrolink Station
ñ City Hall
Parking District
Average Parking Length of Stay
(Average Hours per Space per Day)
< 2
2 - 3
3 - 4
4+
Average Parking Length of Stay (Saturday)
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Existing Conditions Summary
The findings of the existing parking utilization survey are detailed below:
 There is sufficient parking supply in Old Towne to meet the current demand. The existing data collection showed that overall, Old Towne Orange has sufficient parking supply to serve the current demand. A threshold of 90% utilization in the study area was used to determine parking deficiencies. Over the course of the two-day parking survey, the peak maximum occupancy occurred midday Thursday with 64% of parking utilized at 1:00 PM. However, there are several parking hotspots where occupancy frequently exceeds 90% during select time periods or where illegal parking occurs, or both. Specifically, parking in the immediate vicinity of the Plaza is heavily utilized, while the areas farther from the circle rarely exceed the 90% threshold. The garage in the study area is particularly underutilized, especially those outside of the core parking district.  Old Towne visitors may not be aware of available public parking in adjacent areas. The results of the utilization study showed a maximum of 64% utilization. However, parking is frequently at capacity in the areas closest to the Plaza. This contradiction indicates that individuals may not be aware of all locations where public parking is available or may not be comfortable seeking parking farther from their destination. As illustrated on the utilization maps in Appendix A, several parking locations show maximum occupancy (shown in red) adjacent to other on- and off-street parking areas that have available parking (shown in green and yellow).  Extended lengths of stay – or vehicles parked over 4 hours – represents an average of 8% of the total parking demand. Without time restrictions on parking, vehicles are permitted to stay in Old Towne without limitation. The two-day (Thursday and Saturday) parking survey revealed that extended parking, in which vehicles stay over 4 hours, represents approximately 7% to 9% of total daily parking demand.
 The Old Towne West/Metrolink Parking Structure is underutilized. The survey data indicates almost half of underutilized capacity for publicly available parking spaces during peak periods of parking demand in the garage. During the weekday (Thursday) parking surveys, the maximum parking utilization of the garage was 47%. The weekend (Saturday) maximum parking utilization was 53% on Saturday night. At the time of the parking survey, Metrolink ridership saw an 85% decrease2 of ridership compared to pre-pandemic levels, and there may be greater demand from Metrolink riders in the future as the ridership continues to return. 2 https://metrolinktrains.com/rider-info/safety--security/health-safety/coronavirus/caresactfunding/ 359
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Future Parking Supply and Demand
Fehr & Peers analyzed future parking supply and demand to forecast future parking conditions in Old Towne using information from the City on planned future development projects. A shared parking demand model was developed to estimate the future parking demand in Old Towne.

Shared Parking Demand Model
To understand how parking demand would change with future development in old Towne Orange, Fehr & Peers reviewed parking demand for the anticipated land uses and parking supply standards from Section

17.34.060 of the Orange Municipal Code. However, these standards reflect the minimum required parking supplied and are not reflective of current or future parking demand characteristics. The parking demand data collected in the surveys were used in combination with data from Shared Parking, Third Edition (Urban Land Institute [ULI], 2020) and the existing land use information to develop a parking demand model that reflects the study area and can estimate the parking demand from approved and pending projects.

The shared parking model uses base parking ratios for land uses that are based on a national study of parking occupancy data from across the United States. The ratios are based on expected peak parking demand of vehicles assuming nearly 100 percent modal split to automobile. In addition to parking demand and modal split, the parking ratios are based on 85th percentile parking demand observed, for the purpose of optimizing supply. This is so that parking supply is not designed to the absolute peak demand generated during limited hours of a peak day on a peak month.

The parking model includes modal adjustments to account for local transit availability, parking fees, ride sharing programs, and other transportation demand management systems. Additionally, the parking model accounts for internal capture of people who park once and visit multiple land uses. Modal adjustments and internalization were adjusted to reflect transit, walking, and biking connectivity to Old Towne. The internalization was adjusted to reflect the relative distance between the various land uses in Old Towne. Time of day and seasonal variations are included in the model to account for the variability of parking demand across various land uses. The variations are based on data from across the United States but were adjusted to reflect the temporal aspects of demand specific to Old Towne. The model provides parking demand ratios that can be applied to a variety of land uses to estimate peak parking demand for a given land use.

Table 4 summarizes the shared parking ratios and the City of Orange parking supply standards per land use type.
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Table 4: Parking Demand Peak Hour1 Comparison
Land Use Quantity Unit
Shared Parking Ratios2 City of Orange
Parking
Standards Weekday Weekend 3
Retail [a] 1,000 SF 3 4 4
Supermarket/Grocery [b] 1,000 SF 5 5 4
Office 1,000 SF 5 2 4
Fine/Casual Dining 1,000 SF 16 18 4
Family/Full-Service Restaurant 1,000 SF 18 17 4
Fast Casual/Fast Food 1,000 SF 14 14 4
Bar/Lounge/Night Club 1,000 SF 18 20 4
Hotels 12 keys 5 5 12
Multifamily Residential: Studio [c] 1 DU 1 1 1
Multifamily Residential: One Bedroom [c] 1 DU 1 1 1.5
Multifamily Residential: Two Bedrooms [c] 1 DU 1.8 1.8 1.8 Multifamily Residential: Three+ Bedrooms [c] 1 DU 2.6 2.6 2 SF = Square Feet, DU= Dwelling Unit
1Peak Hour is assumed at 1PM in the month of October
2Shared Parking, Third Edition, 2020
3City of Orange Municipal 17.34.060: Required Number of Parking Spaces. Required number of parking spaces for Downtown Plaza District. Downtown plaza district includes properties within the eight-block area bounded by Maple Avenue, Grand Street, Almond Avenue and Lemon Street and the requirements are noted in Table 17.34.060(C) of the Municipal Code. The same requirements apply for the Santa Fe Depot Specific Plan. This is consistent for all uses except for Hotel, which is referenced from Table 17.34.060(A) of the Municipal Code. The only hotel project (Orange Plaza Inn/Richland Hotel) is located outside of the Downtown plaza district. [a] Retail less than 400,000 sf
[b] Retail less than 25,000 sf Gross Floor Area
[c] Development Size—3 units to 50 units

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Old Towne Future Buildout
Fehr & Peers worked with City of Orange planning staff to identify planned development projects in the Old Towne area. At the time of conducting this study, six projects were pending, approved, or under construction (approved projects) in the study area that would result in near-term changes to parking supply and demand.

In addition, Fehr & Peers reviewed the Santa Fe Depot Specific Plan to gather information about the anticipated projects in and adjacent to Old Towne which include:
 261 residential units
 316,396 square feet of commercial development
 371,778 square feet of institutional development
 171,160 square feet of industrial development
These land uses will be located west of the Old Towne which will impact parking in the Old Towne when built out. Institutional development from the Santa Fe Depot Specific Plan was not included in the review as these projects will be operated by Chapman University and will provide reserved spaces for the users.

Industrial development projects were not included either due to their location outside of Old Towne and are not anticipated to have any effect of public parking in Old Towne3.

Table 5 and Figure 11 identify the approved projects in and adjacent to the study area and the planned Santa Fe Depot Specific Plan area.
3 Residential projects in the Specific Plan were assumed to provide 100% of parking as required by the City’s Municipal Code. This supply is anticipated to be provided on-site for residents and visitors only and is not anticipated to contribute to the demand for additional public parking. 362
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Table 5: Future Development List
Name Location Land Use Type Size Unit
Peak Hour
Parking
Demand4
Approved Projects
First Presbyterian Church
Christian Education Center
Adaptive Reuse
191 N Orange St Mixed-Use
Restaurant 2,374 SF
Market 2,288 SF
Retail 800 SF
Office 14,960 SF
(Former) Spic-N-Span
Drycleaner
201 W Chapman
Ave
Commercial Coffee House 1,145 SF
Sunkist Fruit Exchange
Building Adaptive Reuse 195 S Glassell St Commercial Restaurant 2,856
SF
Old Towne Gateway1 401 W Chapman
Ave
Commercial Restaurant 7,610 SF
Hilbert Museum1 167 N Atchinson
St
Educational Art Gallery 5,000 SF
Orange Plaza Inn/Richland
Hotel
137 E Maple Ave Lodging Hotel 12 keys
Santa Fe Depot Specific Plan
Santa Fe Depot Specific
Plan Development2
To the West of the
Study Area
Residential - 261 DU
Commercial - 316,396 SF
Total
Residential Multifamily
Housing 261
DU 394 Spaces
Commercial Retail3 287,844 SF 733 spaces
Commercial Restaurant3 45,625 SF 680 spaces
Office Office 14,960 SF 47 spaces
Lodging Hotel 12 keys 4 spaces
SF = Square Feet, DU= Dwelling Unit
1 Located in the Santa Fe Depot Specific Plan Area
2 Source: Santa Fe Depot Specific Plan Update, Development Capacity Analysis, 2006 3 Assuming 90% of General Retail and 10% of Family/Full Service Restaurant 4Peak Hour Parking Demand was developed using Shared Parking, Third Edition (Urban Land Institute [ULI], 2020). This represents the parking demand at the peak hour (1:00 PM) for each land use type, accounting for the more efficient use of supply due to likelihood that patrons and visitors may park once and visits multiple destinations in Old Towne and the Santa Fe Depot area 363
Metrolink Station
Existing Parking District
2 2
Approved and Planned Project Locations
Figure 11
Pending Projects
Square Footage of Pending Projects
Santa Fe Depot Specific Plan Boundary
Not a part of Santa Fe Depot Specific Plan
Not Included in Parking Demand Calculation
Proposed Fee Boundary
20,925 sqft
2,856 sqft
1,145 sqft
9,953 sqft
7,610 sqft
sqft
5,000 sqft
2 N
Hilbert
Museum
Old Towne
Gateway Sunkist Fruit
Exchange
Spic-N-Span
Drycleaner
First Presbyterian
Church
Orange Plaza Inn
Residential
Existing Kept
Removed
Added
Chapman Ave
Maple Ave
Palm Ave
Parker St
Cypress St
Lemon St
Olive St
Glassell StOrange St
Grand St
Center St
Shaffer St
Sycamore Ave
Walnut Ave
Almond Ave
Palmyra Ave
Washington Ave
New Commercial
Annually
60% Commercial
Annually
Source: Santa Fe Depot S
pecific Plan Update, 2006
201
6 301
144,931
256,091
345,563
490,494
10,000
194,075
371,778
381,778
-
1,316
171,160
171,160
154,931
451,482
888,501
1,043,432
345,563
28,797
207,338
15,949
Commercial Instituional Industrial Totals
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Assessment of Future Parking Demand
The information for the approved and Santa Fe Depot Specific Plan development projects identified in Table 5 was applied to the parking demand model to estimate future parking demand in Old Towne.

Table 5 presents the peak hour parking demand for the future development projects.

Future development is forecasted to increase parking demand by 1,529 new parking spaces on a weekday and 1,537 on a weekend, as shown in Figure 12. Although there are available parking spaces in the study area, it is reasonable to assume that some parking will be built as part of the Santa Fe Depot development projects.

As noted above, the parking demand data collected in the surveys were used in combination with data from Shared Parking, Third Edition (Urban Land Institute [ULI], 2020) and the existing land use information to develop a parking demand model that reflects the study area and can estimate the parking demand from approved and pending projects. The ITE shared parking manual accounts for the mix of uses present in Old Towne and the projected mix of uses in the Santa Fe Depot Specific Plan, which assumes a more efficient use of supply due to likelihood that patrons and visitors may park once and visits multiple destinations in Old Towne and the Santa Fe Depot area.

In coordination with City of Orange planning staff, two scenarios were identified for future parking assessment of weekday and weekend non-residential parking demand. In both scenarios it was assumed that parking will be provided by residential development to meet the demand of residents and visitors. 365
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Figure 12: Future Parking Demand by Land Use

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Scenario 1
This scenario assumes no new parking spaces are provided. Approved projects and Santa Fe Depot Specific Plan commercial development are assumed to provide no new spaces.

Figure 13 identifies the existing peak parking demand on Thursday from 1:00 PM – 2:00 PM, with a total of 1,697 vehicles parked (64% utilization). With an estimated 1,484 weekday parking spaces demanded for the approved projects and Santa Fe Depot Specific Plan buildout, the total parking demand increases to 3,181 on a weekday. On a weekend, the existing peak parking demand is from 1:00 PM – 2:00 PM, with a total of 1,697 vehicles parked (63% utilization), as shown in Figure 13. With the future development project weekend added parking demand of 1,502 vehicles, the parking demand increases to 3,179 on a weekend.

Under this scenario, 515 and 513 additional parking spaces will be needed to meet the weekday and weekend parking demand, respectively.

Two different utilization rates were considered. A utilization rate, or threshold, is a measure of how utilized parking supply will be. When utilization rates are low, there is an excess of available parking. While this creates an environment where motorists almost always find a parking space easily, it also means public right-of-way and resources have been allocated to vehicle parking that is needed most of the time. A utilization rate between 85% and 90% utilization is typically considered ideal. At this level of utilization, parking supply is considered well-utilized with sufficient capacity for circulation and turnover. 85% utilization is more standard for most suburban shopping centers where parking is free and demand is moderate to high at peak times. 90% utilization is typically used in downtown settings where parking may or may not be priced and demand is high at peak times. Both utilization rates were considered as Old Towne Orange represents a blend of suburban and downtown place types.

To achieve 85% parking occupancy, the recommended future parking supply is 3,742 spaces on a weekday and 3,740 spaces on a weekend. To achieve 85% utilization rate, a total of 1,076 additional parking spaces will be needed to provide sufficient parking on a weekday and 1,074 additional parking spaces on a weekend.

To achieve a 90% parking occupancy, the recommended future parking supply is 3,535 spaces on a weekday and 3,533 spaces on a weekend. To achieve 90% utilization rate, a total of 869 additional parking spaces will be needed to provide sufficient parking on a weekday and 867 additional parking spaces on a weekend.
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Scenario 2
This scenario assumes that approved future development projects and commercial buildout of the Santa Fe Depot Specific Plan would provide 50% of the parking spaces required by the City’s code parking. This parking supply increase results in 715 new spaces added to the existing parking supply to result in a total future parking supply to 3,381 spaces. The future weekday parking demand of 3,181 spaces will result in 94% utilization and the future weekend parking demand of 3,179 spaces will result in a 94% utilization.

Under this scenario, there will be a surplus of 200 parking spaces on a weekday and a surplus of 202 parking spaces on a weekend.

To achieve an 85% parking utilization, 361 additional parking spaces will be needed to on a weekday and 359 parking spaces on a weekend.

To achieve an 90% parking utilization, 154 additional parking spaces will be needed to on a weekday and 152 parking spaces on a weekend.

Table 6 and Figure 13 summarize the existing and future parking supply for both scenarios on a weekday and a weekend.

The future parking demand estimates identified in this section are based on the best available information provided by the City of Orange. Future parking demand can change based on changes to the approved projects or other projects being proposed in Old Towne.

Existing supply would not accommodate level of development expected from approved projects and contemplated in the Santa Fe Depot Specific Plan. If approved projects and the commercial buildout of the Santa Fe Depot Specific Plan provide 50% of the parking supply required per the City’s code, it would accommodate future parking demand. If approved projects and the commercial buildout of the Santa Fe Depot Specific Plan provide more than 50% of the parking supply required per the City’s code, there would be a larger surplus and potentially no additional spaces would be required to meet 85% or 90% utilization.
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Table 6: Summary of Existing and Future Parking Supply Scenarios Weekday Weekend
Scenario 1 – No New Parking Supply Added
Existing Parking Supply 2,666 2,666
Total Future Parking Supply 2,666 2,666
Existing Parking Peak Demand1,2 1,697 1,677
Approved Projects Parking Peak Demand 289 256
Santa Fe Depot Specific Plan Parking Demand 1,196 1,246 Total Future Parking Demand 3,181 3,179
Needed Parking Supply 515 513
85% Utilization of Future Parking Demand 3,742 3,740
Needed Parking Supply for 85% Parking Utilization of Future Demand 1,076 1,074 90% Utilization of Future Parking Demand 3,535 3,533
Needed Parking Supply for 90% Parking Utilization of Future Demand 869 867 Scenario 2 – 50% Parking Buildout
Existing Parking Supply 2,666 2,666
Net New Spaces (50% Parking Buildout) 715 715
Total Future Parking Supply 3,381 3,381
Existing Parking Peak Demand1,2 1,697 1,677
Approved Projects Parking Peak Demand 289 256
Santa Fe Depot Specific Plan Parking Demand 1,196 1,246 Total Future Parking Demand 3,181 3,179
Parking Surplus 200 202
85% Utilization of Future Parking Demand 3,742 3,740
Needed Parking Supply for 85% Parking Utilization of Future Demand 361 359 90% Utilization of Future Parking Demand 3,535 3,533
Needed Parking Supply for 90% Parking Utilization of Future Demand 154 152

1. Represents the maximum demand observed during weekday survey (Thursday 1:00 PM)

2. Represents the maximum demand observed during weekend survey (Saturday 1:00 PM) 369
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Figure 13: Future Parking Supply and Demand

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Determining Future Parking Deficiencies
As development and redevelopment continues in Old Towne and through the Santa Fe Depot Specific Plan, it is likely that individual projects will provide varying levels of parking on-site. It is possible that many projects will supply parking at levels that fall in between the parking supply scenarios studied here (Scenario 1 – no new parking supply and Scenario 2 – 50% of parking supply as required by City code). As noted above, depending on what utilization rate is considered and how much parking is supplied by individual projects, different amounts of parking supply would be required to meet future parking demand. As such, identifying what qualifies as a parking deficiency in Old Towne Orange should use the following procedure:

1. Any residential project should perform a parking demand estimate to consider the parking demand onsite. Any project that does not provide on-site parking that meets the estimated parking demand would be considered deficient.
a. Published parking demand data through ITE or ULI could be referenced to evaluate the residential parking demand.
b. Alternatively, local data could be collected at nearby residential sites to establish a local parking demand rate.

2. Any commercial or mixed-use project should perform a Shared Parking Analysis to consider the parking demand on site. Any project that does not provide on-site parking that meets the estimated parking demand would be considered deficient.
a. The parking demand rates in Table 5 can generally be used to evaluate projects, as these were developed using a shared parking model consistent with Old Towne Orange. If the project is not consistent with the mix of uses or assumptions used in this study, it may not be appropriate to use these rates.

Projects without acceptable parking supply should be required to mitigate their parking deficiencies.

Options for this include:
 Integrating additional on-site parking (may not be financially, physically, or otherwise feasible in Old Towne for many projects due to historical structures and other limitations)  Establishing agreements with nearby properties with available parking supply  Paying into a parking mitigation fee, details are described below  Demonstrating a substantial reduction in parking demand through parking management strategies
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Smart Parking Equipment
Based on the review of the existing and future parking conditions, several types of smart parking equipment and infrastructure are recommended to assist visitors in finding available parking in the Old Towne:

Wayfinding Options: Dynamic digital signage or a parking app coupled with sensors, cameras, or other detection technology can provide live updates on the number of spaces available in a given area. A parking app can also process payment information if needed. A summary of the wayfinding options is provided in Table 7.

Detection Options: To help rectify time limit violations, the City might consider installing vehicle sensors that detect when a vehicle is parked in the space and transmit information wirelessly to parking enforcement officers. While this technology is most effective and most easily installed in parking garages or lots, the sensors can be placed on pavement, in pavement, or on meter posts. Vehicle detection cameras installed overhead above the street are another way to detect when a vehicle is parked in a space and notify parking enforcement officer of violations. A summary of the detection options is provided in Table 8.

Payment Technologies: There are several payment technologies that could be employed in Old Towne, including individual meters, kiosks, and a mobile parking app. A key issue related to all parking charges is setting the optimal level of the charges—a topic that is discussed further in the Parking Strategies Toolbox section of this report. A summary of the payment technologies is provided in Table 9.

Enforcement Options: Effective implementation of time limits and charging for parking requires enforcement. Enforcement can be implemented by installing in-meter cameras or integrated license plate reader cameras at parking meter locations that would detect when a vehicle is parked in the space and take a picture of the license if a violation occurs. A summary of the enforcement options is provided in Table 10.

Aesthetics
Given the historical character of Old Towne, visual style and aesthetics of any new equipment or infrastructure is a key consideration. Most of the smart parking equipment described in this section has some level of customization through different vendors. Wayfinding signage and apps and payment apps and kiosks would be custom-made or customizable equipment/tools. More standardized technology, such as meters and sensors, have fewer customization options beyond paint color, but could be installed with discretion and aesthetics in mind.
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Table 7: Wayfinding Options Summary
Dynamic Digital Signage Parking App
Example
Description
Coupled with sensors, cameras, or other detection these signs provide live updates on the number of spaces available in a given area.

Coupled with sensors, cameras, or other detection this customizable app provides live updates on the number of spaces available in a given area. It can also process payment information if needed.

Typical Vendor ParkHelp Smart Parking
On-Street/Off-Street Off-Street: Lots and Garages On-Street and Off Street Capital Costs $8,000 - $20,000 per sign
The City could integrate existing storymaps website which shows where parking is available in Old Towne at minimal cost, and this is already integrated for the Old Towne West garage on Lemon Street.

Operating Costs
Limited to no ongoing maintenance required. The Old Towne West garage on Lemon Street currently includes this type of signage on the ground floor.

No new operating costs would be expected, as the City already hosts the storymaps for Old Towne and integrates this functionality for the Old Towne West garage.

Summary of
Strengths/Functions

1. Allows for real-time wayfinding.

2. No ongoing maintenance or hosting issues.

3. Already deployed in Old Towne West structure, so familiar to residents and patrons of Orange.

1. Customizable tool that can direct folks to available parking spaces.

2. Can be deployed for on-street and off-street parking.

3. Existing City storymaps already provide a framework, hosting, and maintenance that could be enhanced to include all parking in Old Towne.

Summary of
Weaknesses

1. Limited to off-street facilities, signage may be too clunky or not effectively placed for on-street parking.

2. Does not allow folks to review parking options before traveling to Old Towne.

1. Equity and accessibility concerns for folks without access to a smart phone or data plan.
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Table 8: Detection Options Summary
Sensors
Land Use
Overhead Cameras
Example
Description
Sensors are placed either on pavement, in pavement, or on meter post. Detects when a vehicle is parked in the space and transmits that information wirelessly to meter and parking enforcement officer.

Customers log on to a smartphone app and enter a parking zone or space number. Payment for time spent is automatically drawn from customer's account.

Vehicle detection cameras installed
overhead above the street. Detects when a
vehicle is parked in a space and notifies
parking enforcement officer of violations.

Typical Vendor Nwave; PNI Nwave; PNI IPS Group ParkSonic Spacing One sensor per parking space One sensor per parking space One sensor per parking space
Depends on sight lines, but typically one
per block
Capital Costs Most vendors have no upfront costs, but jurisdiction would need to provide labor for installation
See “Payment
Technologies”
$200 - $500 per camera
Operating Costs $12-$15 per month per sensor; $144-$180 per year per sensor See “Payment Technologies”
Similar to meters and kiosks, some vendors
offer maintenance plans and software
updates, but many municipal customers
choose to cover maintenance through
existing departments/operators that
maintain utilities/lighting within the
jurisdiction, as cameras are most typically
installed on existing lighting or utility poles.
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Sensors
Land Use
Overhead Cameras
On-Street/
Off-Street
On-street and off-street (most
effective in off-street lots and
garages)
On-street and off-street (most
effective in off-street lots and
garages)
On-Street and Off Street
(most effective in on-street
parking)
On-street
Summary of
Strengths/
Functions

1. Allows for more efficient
enforcement by notifying and
directing enforcement officers
to violators.

2. Ability to track vehicles
exceeding maximum time limits
without chalking.

3. Ability to track vehicles
parking without paying.

1. Allows for more efficient
enforcement by notifying and
directing enforcement officers to
violators.

2. Ability to track vehicles
exceeding maximum time limits
without chalking.

3. Ability to track vehicles parking
without paying.

1. Allows for more efficient
enforcement by notifying
and directing enforcement
officers to violators.

2. Ability to track vehicles
exceeding maximum time
limits without chalking.

1. Same enforcement efficiency and time
tracking benefits as sensors.

2. Provides video surveillance options for
other law enforcement applications.

3. Best for unobstructed-view areas with a
high density of parking spaces.

Summary of
Weaknesses
Visual confirmation of violations
must be done by enforcement
personnel
Visual confirmation of violations
must be done by enforcement
personnel
Visual confirmation of
violations must be done by
enforcement personnel
Requires an available place to mount the
camera that has clear sight lines to parking
spaces
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Table 9: Summary of Payment Technologies
Individual Meters Kiosks Parking App
Example
Description
One or two meters are mounted to metal post.

Customer purchases time at the meter up to the
maximum allowable. Remaining time is displayed
visually. Meter is solar-powered, with wireless
communications ability.

Centralized kiosk serves multiple spaces.

Customer purchases time at the kiosk up to the
maximum allowable. In some systems,
customer needs to place a ticket on the
dashboard as proof of payment. Kiosk is solarpowered, with wireless communications ability.

Customers log on to a smartphone app and
enter a parking zone or space number.

Payment for time spent is automatically drawn
from customer's account.

Typical Vendor IPS Group Parkeon ParkMobile
Spacing
Each meter serves one designated parking space
A post that supports two meters can serve two
spaces.

Each kiosk can serve as many spaces as
needed. Spacing should be determined by ease
of walking distance for customers; typically one
kiosk every 150-200 feet.

N/A
Pay-by-Space or
Zones
Pay-by-space only Can do either pay-by-space or zone payment Can do either pay-by-space or zone payment Effect on
Sidewalk
Allow about two feet behind face of curb for
meter installation
Limited; likely need only one or two kiosks on
each block face None
Accepts Coins Yes Yes No
Accepts Bills No Yes No
Accepts Cards Yes Yes Yes
Pay by App Yes Yes Yes
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Individual Meters Kiosks Parking App
Pay by Phone Yes Yes Yes
Potential
Enhancements
for Ease of
Enforcement
Sensors
Overhead cameras
In-meter cameras (only option that would allow
fully automated enforcement)
Sensors
Overhead cameras
Sensors
Overhead cameras
Maintenance
Needs
Many meters to service; however, limited impact
from downtime of an individual meter
Relatively small number of kiosks to service,
but larger impact from downtime of an
individual kiosk
No physical maintenance needed; however,
systemwide impact if app fails
Consumer
Convenience
Issues
Generally well understood by customers and
easy/convenient to use, particularly if meter
allows option to pay by phone.

If doing pay-by-plate or pay-by-space,
customer must walk to kiosk and remember
either license plate or space number. Or,
customer must walk to kiosk and then return to
vehicle to display receipt on dashboard.

Customer must have smartphone with app
installed; can introduce equity issues for those
who do not have or do not feel comfortable
using smartphones.

Capital Costs $450 - $800 per meter $500 - $800 per kiosk No up-front cost to set up app. Vendor also
provides signs and decals (can be customized
for the city).

Operating Costs
Some vendors offer maintenance plans, typically at approximately $1000 annually per kiosk/meter.

Some vendors will negotiate a share of parking revenue, which varies depending on number of meters, parking rates, etc. Operating costs of payment (credit card fees) are typically paid by the customers.
$0.35 per transaction (paid by the consumer).

Customized promo codes for merchant
validations, which can provide discounted or
free parking to the end user. The price for this
service is $250/month.

Summary of
Strengths

1. Convenient option for most customers.

2. Malfunctions isolated to single parking spaces.

3. Visual inspection easy to perform, even without
license plate readers.

1. Greatest payment flexibility.

2. Limited maintenance needs.

1. No physical installation or maintenance
required.

2. No capital cost to the city.

Summary of
Weaknesses

1. Large number of meters to maintain and
service.

2. Takes up sidewalk space.

1. Least physically convenient option for
customers.

2. Kiosk malfunction results in loss of revenue
from many parking spaces.

1. Inconvenient for customers without
smartphones or who do not have app
installed.
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Table 10: Enforcement Options
Name In-Meter Cameras License Plate Readers
Example
Description
Parking meters with an integrated license plate reader camera.

Detects when a vehicle is parked in the space and takes a picture of the license if a violation occurs. Ticket is mailed to violator.

License plate reader cameras installed on enforcement vehicles.

Automatically scans license plates, digitally "chalking" vehicles and notifying parking enforcement officer of violations.

Typical Vendor Municipal Parking Services (only vendor of this technology) Genetec Spacing One meter per one perpendicular or two parallel spaces N/A Capital Costs None; vendor does not sell meters, but instead negotiates to share parking and ticket revenue with City.
$2,000 per reader, typically includes installation onto existing enforcement vehicles.

Operating Costs
Negotiated share of parking and ticket revenue, which varies depending on number of meters, parking rates, and anticipated frequency of violations.

None required, although most vendors offer maintenance plans to cover periodic software updates and damage.

On-Street/Off-Street On-Street and Off Street (most effective in on-street parking) On-Street and Off-Street Summary of
Strengths/Functions

1. Allows fully automated enforcement, so reduces the costs for enforcement personnel.

1. Can be used to enforce all payment technologies.

2. Can also be used to enforce time-limited and residential permit parking areas, as well as for other law enforcement applications.

Summary of
Weaknesses

1. Only one vendor currently offers this technology, so risk single provider of this technology.

2. Parking tickets delivered by mail have uncertain legality in California, so should consult City Attorney before proceeding.

1. High upfront and maintenance costs.

2. Parking enforcement officers only catch violators they pass on their patrol; they do not receive notification of the location of violations.
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Old Towne Parking District
Boundaries and Fee
The current in-lieu parking district fee applies to development and redevelopment projects within the bounds of Lemon Street, Maple Avenue, Grand Street, and Almond Avenue when one of the following conditions is met:
 An existing building footprint is expanded
 A new building is built
 Existing parking spaces are eliminated (e.g., conversion to outdoor patios) A project that meets any one of these criteria would be required to provide on-site parking consistent with the City’s municipal code, as presented in Table 4 of this report. If it is infeasible to provide on-site parking consistent with the City’s requirements, that project may opt-in to the in-lieu fee. The current fee amount is $2,100 per space for new building areas and $9,100 per space when parking is removed.

To date, a total of $111,600 has been collected since the fee’s inception.

In reviewing the application and effectiveness of the current fee, the following observations were made:
 The existing fee may not provide adequate revenue to support more comprehensive parking improvements in Old Towne
 The cost to construct new parking exceeds the current fee amount o The average cost to construct a new surface lot space is approximately $10,000 to $20,000
o The average cost to construct a new garage space is approximately $40,000 to $50,000  New state requirements could make an in-lieu fee for parking within ½ mile of the City’s Metrolink station infeasible. Restructuring the fee type to be a mitigation fee or special assessment district would address this issue.
 Further study, such as a nexus study or establishment of a special assessment district would need to be completed to implement a new fee structure.

Parking Fee Boundaries
The current district boundaries are shown in Figure 11 , and as described above are Lemon Street, Maple Avenue, Grand Street, and Almond Avenue. These boundaries do not include most of the approved and planned projects presented in Figure 11. The current boundaries limit the number of properties that can participate in the fee program and does not capture the areas where most new development and redevelopment is expected to occur.
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As such, it is recommended to expand the current fee boundaries to include an area generally bounded by Parker Street, Palm Avenue, Grand Street, and Palmyra Ave, also shown in Figure 11.

Fee Structures
As described above, new state requirements under Assembly Bill 2097 could make an in-lieu fee for parking within ½ mile of the City’s Metrolink station infeasible. Rather than enforcing parking minimums established in the City’s Municipal Code, the requirements for inclusion in the fee could consider the existing parking demand compared to provided parking supply. This is described in more detail above when determining future parking deficiencies. The fee could also be restructured as a parking mitigation fee, or a special assessment district could be established to fund parking improvements.

A parking mitigation fee would be a mandatory fee that could only be used to fund capital improvements.

A special assessment district would also be a mandatory fee. Unlike the mitigation fee, the funds from a special assessment district could be used to fund capital improvements and ongoing maintenance and operations of parking management strategies or other parking improvements. Also unlike a parking mitigation fee, the special assessment district would likely require voter approval – either registered voters or business owners within the district, depending on how the program is structured.

As noted above, further study, such as a nexus study or establishment of a special assessment district would need to be completed to implement a new fee structure.

Economic Feasibility
Economic & Planning Systems (EPS) was retained to review the economic feasibility of increasing the fee amount and explore what other options could be used to provide revenue to support parking improvements within the parking district.

EPS reviewed four potential development/redevelopment scenarios which were considered representative of the types of projects common in Old Towne to determine what would be the maximum feasible parking fee that projects could support in Old Towne. The four scenarios were as follows:
 Change of Use/Small Expansion: A local church and small administrative offices are converted into a mixed-use retail, market, restaurant and office space with a small expansion of total square footage. Very limited space for parking is available on-site.  Change of Use/Moderate Expansion: A historic structure used as a specialty retail store is converted to a restaurant and multi-family residential. This results in a moderate increase in square footage. All parking required per the City code for the residential use is accommodated on-site, but there is no space available for parking for the restaurant use.  New Construction/Major Expansion: A small retail building is renovated and an additional larger building is added to the property which includes retail, restaurant, and office uses. There is a 380

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moderate amount of parking accommodated on-site, but a parking deficit remains as the site is limited.
 New outdoor dining: An existing restaurant is configuring their on-site parking to allow for an expanded outdoor dining patio. This new patio space removes four on-site parking spaces.

The feasibility analysis considered the potential revenue, operating expenses and value of the example properties in each scenario to determine how much each property could pay in mitigation fees to offset their parking deficiencies. The detailed economic analysis including all tables and sources is presented in Appendix B.

A one-time fee of $10,000 per parking space would be feasible under current economic conditions and enables redevelopment projects that would otherwise be economically infeasible if all required parking spaces had to be provided on site. This could be levied through a mitigation fee or a special assessment district.

Alternatively, under the special assessment district, an annual fee could be levied in place of or in addition to the one-time fee to fund ongoing improvements and operations within the parking district. An annual fee of $300 to $600 per business would be feasible under current economic conditions. A lower onetime fee could be combined with an annual fee could provide a revenue source for the City to support ongoing operations or maintenance of some of the parking management strategies presented in the toolbox in the following section. An annual fee could also be structured to incorporate existing businesses in Old Towne.
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Parking Strategies Toolbox
A variety of parking management strategies have been identified for implementation in Old Towne. These strategies can be used in isolation or combined as part of a larger management strategy. The strategies are summarized below.

The City of Orange intends to prioritize investments in Smart Parking equipment, which while not included in the toolbox below, are described above and facilitate the implementation some strategies below such as paid parking through smart parking payment technologies.

Create Additional Public Parking Supply
Description: Parking demand from the approved projects will be accommodated by the existing parking supply. While parking demand is expected to increase as new development occurs in the Old Towne and Santa Fe Depot Specific Plan area, the anticipated parking demand should be accommodated by the existing parking supply and parking provided by new developments in the Santa Fe Depot Specific Plan area. For Old Towne, this additional parking supply can be provided in a variety of ways.  Renting privately owned spaces for public use could be one way to create parking supply when a small number of public parking spaces are needed. These spaces will have posted restrictions to limit their use by non-customers. This arrangement would allow the City to lease the space under an agreement subject to cancellation by both parties. Alternatively, some cities allow for in-lieu or tax exemptions to property owners who allow public parking to incentivize use of private land for public use. Cities that have set up lease programs for private spaces are uncommon but not unknown.

The Old Towne parking district can be responsible for implementing and monitoring this lease program.

Advantages: The City is able to increase the number of available parking spaces without having to pay to construct the spaces. The business owner benefits by receiving a payment for their parking spaces, which can often go unused due to restrictions on the use by non-customers. By allowing either party to terminate the agreement, there is flexibility to end the arrangement, if the spaces are no longer needed or if the business owner requires their use due to a business expansion or a change in business conditions.

Considerations: The main drawbacks to this approach are the difficulty in convincing business owners to allow the leasing of their spaces and the fact that a leased space is not a permanent public space, compared with a parking lot or garage.
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 If parking demand is not met by leasing parking spaces, then off-street parking (parking lots or structures) would need to be constructed. Off-street parking spaces are sometimes funded through the issuance of bonds, which are then repaid through revenue generated by the parking facilities.

In the face of evolving transportation technologies, it is recommended that future parking lots or structures be constructed with consideration for alternative future uses. For instance, private companies are considering how to future-proof parking structures by including creative building materials and utility features, in case portions of the structure are adapted into land uses other than parking over time.

Advantages: Ample parking supply is positively perceived by business owners and visitors. The main advantages of this approach are the ability to garner public support for off-street parking and the permanence of the parking spaces.

Considerations: A significant issue with off-street parking is the desire of business owners to have off-street parking built when it is not warranted or needed. Adding off-street parking results in a higher direct expense and opportunity cost. The average cost of building surface parking is $10,000 - $20,000 per space, the average cost of a parking structure is $30,000 - $50,000 per space, and the average cost of an underground parking is $50,000+ per space. These costs do not include the cost of land on which the parking is built. Absent parking revenues also offset these costs, and these funds must come from other sources. The evolving improvements in technology and transportation require a combination of deliberate and flexible land use decisions that may need to be adapted over time. Additionally, paving land for parking will result in environmental costs such as greenspace loss, stormwater management costs, heat island effects, and traffic impacts from construction. It should also be considered that development of off-street parking poses challenges to the existing aesthetics in Old Towne.

Parking structures can make efficient use of land in downtown where land is more valuable. 383

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Paid On-Street Parking
Description: Paid parking for on-street public parking helps manage parking demand through encouraging drivers to use parking efficiently in the highly desired places and create parking space turnover. Setting the optimal price level for parking is important as parking prices which are set too high may discourage parking and lead to less revenue than charging a lower prices. Parking prices which are too low may not generate sufficient revenue and prove ineffective in managing demand. In Old Towne, Olive Street and Orange Street could implement paid parking to encourage parking turnover.

Several options could be administered for paid parking which include pay stations, parking validation/merchant programs or variable rates (example, first hour fee), parking benefit districts, access control and discounted employee parking. Historically, many parking garages and parking meters used set rates per hour which did not vary throughout the day. Recently, some parking facilities have started to use variable rates which might include the first 90 minutes free, and $2 per hour for each hour after that with a maximum per day. By allowing the first 90 minutes to be free, there is no disincentive for casual shoppers and diners who stay for 90 minutes or less. Related to this variable pricing, some jurisdictions allow for restaurants and shops to validate parking, whereby the first 1 to 2 hours of parking are free.

Validation programs are also oriented towards casual shoppers and diners.

Another variation in paid parking is the allowance of employees to buy discounted parking passes. For example, instead of an employee paying a daily rate for parking, they could be allowed the opportunity to purchase a discounted monthly parking pass. This would allow the City to recover the capital and operating costs of providing parking while providing a benefit to the local employees.

Paid parking would not need to be implemented across the entire Old Towne area to be effective. It should be implemented on streets with similar levels of demand and proximity to the highest demand parking areas. For example, if paid parking were implemented on Glassell Street between Almond Street and the Plaza, it should be implemented on both sides of the street and on the other three approaches (Glassell Street and Chapman Avenue) leading to the Plaza.

Advantages: While charging for parking may be unpopular, several benefits include the ability to effectively manage parking demand, monitor occupancy and turnover and collect revenue. Paid parking creates a revenue source that may fund streetscape improvement, maintenance, and the construction of additional parking spaces. Paid parking can also maximize turnover and manage demand in the most utilized areas of a downtown with the highest parking demand. It can also emphasize the popularity and viability of a downtown, as areas with paid parking tend to be highly utilized and sought after by business, residents, patrons, and visitors.

Considerations: There may be resistance from business owners and residents in implementing paid parking in areas where charging for parking is implemented for the first time. It requires determination of optimal pricing and equipment. The use of paid parking requires the City to administer the program that implements and oversees its operation. For effective implementation of this strategy, application towards an entire parking facility or area should be preferred so potential cruising for free parking is mitigated. 384

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Establish Time Limits
Description: Time-based parking restrictions can be used to discourage long-term parking by employees or residents and encourage turnover of parking spaces. As noted in the discussion of Existing Conditions, approximately 8% of the vehicles in the study area occupied spaces for 4 hours or longer. The extended use of these spaces is likely attributable to employees from businesses. Currently, Glassell Street and Chapman Avenue have 2-hr parking time limits around the Old Towne Plaza and this restriction can be expanded to Olive Street and Orange Street. Enforcement is often administered by the Police Department of the City; although, it is a common practice to have private parking enforcement administered by a contracted vendor.

Advantages: Time limits can be effective in generating turnover in more highly desired or premium spaces.

Considerations: Employees in many downtowns often attempt to evade the hourly limits by moving their vehicles from one space to another throughout the day. Consequently, long-term parking may be pushed from one street to another street without restrictions. Continuous enforcement by Police or contracted vendor to impose parking time limits is required.

Revenues from charging for parking can be used for downtown improvements.

Implementing parking signage with time limits and restrictions and enforcing it is one of the simplest ways of managing parking demand.
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Microtransit Pilot Program
Description: Microtransit is a flexible, on-demand shared transportation where rides are usually requested via an app. Programs can also provide a hybrid between fixed-route shuttles and on-demand service. Examples include Free Rides Around the Neighborhood (FRAN) in Center City Anaheim and Free Rides Everywhere Downtown (FRED) in Downtown San Diego. The service allows riders choose to begin and end their trips at one of the predefined stops. This strategy could be effective in encouraging visitors to “park once” at one of the publicly available parking spaces and take the microtransit service to travel to their destinations in Old Towne.

The proposed vision for a potential pilot program for Old Towne is presented below on Figure 14. This service would use all electric shuttles that could carry 5-8 passengers each, connecting residents, students, employees, patrons, and visitors in Old Towne to underused parking supply and shuttling them to their ultimate destination.

The Old Towne Shuttle or “OTiS” could be structured as a free ride program like FRAN or FRED, or as a paid service. The program could be administered by the City, like FRAN, or by a third-party like FRED, which is administered by a company called Circuit. Circuit runs electric shuttle programs in southern California in San Diego, Oceanside, Huntington Beach, Newport Beach, Santa Monica, and Chula Vista. The service could be structured as demand responsive (designated service area, users call for a ride on an app and are picked up/dropped off anywhere in the service area) or fixed route (established route/stops and frequency like traditional bus service). Demand responsive service allows users to tailor their rides to their needs, while fixed route service allows certainty in where and when shuttles will be present.

The shuttles would be restricted to streets with speed limits of 35 mph or less. The key corridors in Old Towne such as Chapman Avenue, Lemon Street, Olive Street, Grand Street and Maple Avenue all meet this requirement.

Advantages: Microtransit encourages taking alternative transportation modes by providing first and last mile service and provides flexibility as it may not follow fixed routes. This service can promote Old Towne businesses by leveraging the branding and adding to the already vibrant identity and character of Old Towne.

Considerations: Extensive communication and marketing are important to adopt this type of pilot program. If a paid microtransit program is implemented, it may attract customers who are willing to pay higher fare for better personalized experience, thus resulting in equity concerns. If the shuttle is provided at no charge, alternate means of funding ongoing maintenance and operations would need to be identified. The annual parking fee discussed above (determined to be economically feasible at $300 to $600 per year per business) could be used to support the operations of this program.

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Figure 14: Old Towne Shuttle “OTiS”
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Valet Service
Description: Project specific valet service allows visitors to drop off their vehicle with an attendant for efficient parking where visitors will be given a ticket that is used for identifying the appropriate vehicle upon the visitor’s return. Any off-street parking lot in Old Towne Orange could potentially be converted to valet parking.

Advantages: Valet parking allows stacking vehicles to achieve greater density of parking than is possible with self-parking. This results in the use of smaller parking facilities due to the limited access and control of the parking facility. Old Towne has an existing clientele base who may use valet service if provided.

Considerations: The cost of managing and operating the system would fall on the developer of business.

The valet should be contained within the specific development site. A development that is approved with a valet operating will need to continue using the valet operations unless the lack of need for a valet can be justified.

Develop Informational Programs
Description: Parking usage and public perception of parking is affected by how familiar people are with the area they are parking in. For example, first-time visitors will often park in the first space that they see.

While ther visitors may slowly loop around the area in search of prime parking immediately in front of their destination if they are apprehensive or unaware of other places where parking is available. This behavior results in more time spent seeking parking and parking shortfalls in one area adjacent to blocks with available parking.

Another issue is the use of the desirable, high-demand on-street spaces by merchants and employees. In some cases, these individuals might be unaware of the consequences of occupying the high-demand spaces for long-term parking.

Informational programs can reduce these issues by directing people to available parking. They can include a wide variety of elements including static signage, maps showing the locations of parking facilities, websites, mobile apps, and even parking guides or docents.

The City of Orange maintains a website that provides public parking information for 14 public parking facilities in Old Towne. It is recommended that the City explores options to develop a robust informational program for parking.

Advantages: Informational programs are effective means to increase public knowledge of parking availability and easy to implement through branding, signage, online sources, and the existing City website. These programs require limited oversight once in place and promote more efficient use of existing parking supply. They can increase visibility of available parking and activity in the less busy portions of Old Towne as visitors park and walk in areas they may not have visited. 388

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Considerations: Static signs and maps are limited to what can be placed on them, therefore changes to parking facilities may require the installation of new signage. Implementing intelligent signage can be expensive.

Accommodate Transportation Network Companies
Description: Ride-sharing services known as Transportation Network Companies (TNCs) are private carsharing companies, such as taxis, Uber, and Lyft. As demand and use for TNCs rise, this strategy would involve converting select on-street parking spaces or curbs into more designated passenger loading zones.

Advantages: The benefit of adding loading zones to accommodate TNCs is maximizing the number of people gaining access to Old Towne from a single parking space at a much higher turnover rate.

Considerations: Prior to considering modifications to curbside management or adding passenger loading zones, it is recommended that the City conduct a survey to determine the prevalence of TNC or rideshare use in Old Towne. The survey should include interviews with valet vendors to determine if TNC or rideshare is impacting valet use. If the volume of rideshare is substantial, an initial recommendation is to utilize and consolidate excess curb space or areas with a prevalence of illegal parking as pilot pickup/drop-off zones.

Regulatory changes are required to allow for modifications to parking requirements. Determination and monitoring of location and frequency of curbside zones should be done.

Valet service provides better parking efficiency. Downtowns are increasingly accommodating for TNC curbspace management.
389

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Update Parking Standards
Description: Currently there are misalignments between the parking demand and the City parking standards in Old Towne. In coordination with the regular review of parking demand, the City could utilize the collected parking demand data to establish new parking standards for Old Towne developments based on data collected.

Currently, the City of Orange requires that 4 spaces be provided for 1,000 square feet of all commercial developments (retail, office, restaurant, etc.) As shown in Table 4 of this report, the estimated parking demand of a restaurant is noticeably higher than an office or general retail use. As the business mix in Old Towne incorporates more restaurants, bars, and cafes, there may be a misalignment of the parking requirements and the parking demand that will be generated by these businesses.

Providing more flexibility to developers with parking standards based on a development’s location and circumstances can increase parking efficiency. For instance, decreasing parking requirements for projects located near transit can incentivize transit-oriented development and decrease parking demand. Reducing parking requirements for developers that provide bicycle parking or annual transit passes to building occupants can also decrease parking demand. Any such change to parking requirement should be documented and justified by a project applicant.

Advantages: Can decrease parking demand and promote alternative forms of transportation, could create a better alignment between parking supply and demand. This strategy could also increase the generation of revenue from an in-lieu fee, if parking supply requirements were “right-sized” to fit parking demand.

Considerations: Reevaluating and revising parking standards can be time-consuming.

Implement Transportation Demand Management (TDM)
Description: In addition to the various techniques described which address parking supply and its operation, addressing parking demand itself is another method available to the City. This use of Travel Demand Management (TDM) attempts to reduce the number of persons needing or wanting to drive and park in Old Town Orange.

The majority of TDM strategies are for work-related trips, particularly on the employment end. TDM can be classified into three broad categories, which include:
 Informational – These strategies provide information about ride sharing and other alternative travel modes with the thought that when more information is available about travel choices, commuters are more likely to use modes other than driving. Most TDM plans include some level of informational strategies.
 Incentives – These types of strategies provide financial incentives for the use of alternative travel modes. For example, providing free transit passes or monetary travel credits to employees is a 390

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typical TDM measure. Many, but not all, TDM plans or programs have some level of financial incentives.
 Disincentives – Disincentive-based strategies involve charging or assessing fees for driving or using automobiles. These types of strategies are rarely applied in the United States except for parking charges, as previously described.

Advantages: TDM provides a cost-effective way to reduce the need for parking spaces. Fewer people parking has the same effect on providing sufficient parking as building additional spaces.

Considerations: TDM requires administration which may require a City staff person to be designated as a TDM coordinator for Old Towne, who would distribute information on alternative travel modes, coordinate ridesharing, and other related items.

Updated parking standards can decrease parking requirements and allow for alternative modes. 391

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Appendix A - Hourly Parking
Utilization Maps (Thursday and
Saturday)
392
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.1
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (8:00 AM - Thursday)
393
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.2
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (9:00 AM - Thursday)
394
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.3
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (10:00 AM - Thursday)
395
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.4
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (11:00 AM - Thursday)
396
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.5
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (12:00 PM - Thursday)
397
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.6
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (1:00 PM - Thursday)
398
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.7
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (2:00 PM - Thursday)
399
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.8
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (3:00 PM - Thursday)
400
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.9
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (4:00 PM - Thursday)
401
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.10
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (5:00 PM - Thursday)
402
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.11
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (6:00 PM - Thursday)
403
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.12
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (7:00 PM - Thursday)
404
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.13
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (8:00 PM - Thursday)
405
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.14
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (9:00 PM - Thursday)
406
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.15
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (10:00 PM - Thursday)
407
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.16
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (11:00 PM - Thursday)
408
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.17
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (12:00 AM - Friday)
409
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.18
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (8:00 AM - Saturday)
410
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.19
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (9:00 AM - Saturday)
411
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.20
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (10:00 AM - Saturday)
412
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.21
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (11:00 AM - Saturday)
413
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.22
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (12:00 PM - Saturday)
414
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.23
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (1:00 PM - Saturday)
415
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.24
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (2:00 PM - Saturday)
416
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.25
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (3:00 PM - Saturday)
417
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.26
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (4:00 PM - Saturday)
418
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.27
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (5:00 PM - Saturday)
419
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.28
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (6:00 PM - Saturday)
420
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.29
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (7:00 PM - Saturday)
421
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.30
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (8:00 PM - Saturday)
422
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.31
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (9:00 PM - Saturday)
423
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.32
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (10:00 PM - Saturday)
424
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.33
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (11:00 PM - Saturday)
425
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.34
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (12:00 AM - Sunday)
426
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.35
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (1:00 AM - Sunday)
427
I2
ñ
Maple Ave
Almond Ave
Orange St
Grand St
Center St
Cypress St
Lemon St
Olive St
Glassell St
Chapman Ave
Washington Ave
Palmyra Ave
Palm Ave
Figure A.36
N
I2 Metrolink Station
ñ City Hall
Parking District
Parking Utilization
0%
< 25%
25 - 50%
50 - 75%
75 - 85%
85 - 100% Parking Utilization (2:00 AM - Sunday)
428

Page 55 ends

Appendix B – Old Towne Orange
Economic Feasibility Analysis
429
Table 1
Summary Table
The Orange Old Towne Parking Study; EPS #214044
Example Change of Use /
Small Expansion
Mixed Use
Redevelopment /
Change of Ownership1
New Construction /
Expansion
Outdoor Dining
Expansion2
Existing Sq Ft 19,000 12,000 11,200 4,000
New Project Sq Ft 20,400 18,350 28,800 5,000
Net New Sq Ft 1,400 6,350 17,600 1,000
Existing Parking 19 0 60 16
Proposed Parking 6 18 65 12
Required Parking 82 46 116 16
In‐Lieu Parking Spaces 76 28 51 4

PROJECT FEASIBILITY ANALYSIS BY FEE TYPE OPTION
No In-Lieu Option3
Parking built on‐site Infeasible Infeasible Infeasible Marginal Option 1: One-time In-Lieu Parking Fee ($ per space)
$2,500
$5,000
$7,000 (current fee)
$10,000
$15,000 Marginal Marginal
$20,000
$25,000
Up to $45,000
Option 2: Annual Parking Payment
$200
$400
$600
$800
$1,000 Marginal Marginal
$1,200
$1,400
Up to $2,800
[1] Feasibility analysis assumes land acquisition costs of approximately $162 per sq. ft. land cost. [2] Net new square footage represents expansion of new outdoor dining space only, not new building space. [3] Providing required spaces on-site is estimated to cost in excess of $40,000 per space, making all projects infeasible or marginal.

Sources: City of Orange; Economic & Planning Systems, Inc.

Infeasible
Infeasible
Feasible
Feasible Feasible Feasible
Feasible Marginal
Infeasible Infeasible
Feasible Feasible Feasible
Marginal

PRELIMINARY DRAFT
Infeasible Infeasible
430
Table 2
Example 1 - Change of Use / Small Expansion
The Orange Old Towne Parking Study; EPS #214044
DEVELOPMENT PROGRAM ASSUMPTIONS ASSUMPTION/FACTOR PER BLDG SQ. FT. AMOUNT Description Change in use from church administration to retail, restaurant & office use Based on example of First Presbyterian Church Reuse (191 N Orange St) Gross Land Area (sq. ft.) 26,500
Existing Space
Gross Building Area (SF) 19,000
Church administration use (SF) older office 19,000
Existing Parking Spaces 19
Proposed Space
Proposed New Building Area (SF) 1,400
Proposed Gross Building Area (SF) 20,400
Retail (SF) 800
Market (SF) 2,250
Restaurant (SF) 2,350
Office (SF) 15,000
Parking Spaces Required
Retail/Market/Restaurant/Office 4 per 1,000 square feet 82 Total Parking Spaces Required
Parking Spaces Proposed On‐Site 6
Parking Deficit 76
REVENUE ASSUMPTIONS ASSUMPTION/FACTOR PER BLDG SQ. FT. AMOUNT Existing Revenue
Gross Revenue (NNN)1 $25.00 /sq. ft./yr $475,000
(less) Operating Expenses 3.0% ($14,250)
(less) Vacancy Rate 10.0% ($47,500)
Subtotal, Annual Net Operating Income $22 $413,250
Capitalized Value 6.0% cap rate $363 $6,887,500
Proposed Revenue
Retail/Market/Restaurant
Gross Revenue (NNN)1 $36.00 /sq. ft./yr $194,400
(less) Operating Expenses 3.0% ($5,832)
(less) Commissions 5.0% ($9,720)
(less) Vacancy Rate 5.0% ($9,720)
Subtotal, Annual Net Operating Income $31 $169,128
Capitalized Retail Value 5.0% cap rate $178 $3,382,560
Office
Gross Revenue (NNN)1 $31.00 /net sq. ft./yr $465,000
(less) Operating Expenses 3.0% ($13,950)
(less) Commissions 5.0% ($23,250)
(less) Vacancy Rate 10.0% ($46,500)
Subtotal, Annual Net Operating Income $20 $381,300
Capitalized Office Value 6.0% cap rate $424 $6,355,000
Net Value Increase $140 $2,850,060

PRELIMINARY DRAFT
431
ANNUAL PARKING PAYMENT IMPACT ASSUMPTION/FACTOR PER BLDG SQ. FT. AMOUNT Annual Parking Payment Cost $0 per space per year $0
Capitalized Value2 5.0% retail cap rate $0
DEVELOPMENT COSTS ASSUMPTION/FACTOR PER BLDG SQ. FT. AMOUNT Direct Costs
Building Costs
Building Construction Cost3 $150 /GLA sq. ft. $11 $210,000 Total Direct Costs $11 $210,000
Indirect Costs
Tenant Improvements (retail)4 $30.00 /net sq. ft. $30 $24,000 Tenant Improvements (market) $60.00 /net sq. ft. $60 $135,000 Tenant Improvements (restaurant)4 $60.00 /net sq. ft. $60 $141,000 Tenant Improvements (office) $30.00 /net sq. ft. $30 $450,000 Parking In Lieu Fee $7,000 per space $26 $532,000
A&E 2% of direct costs $0 $4,200
Other Professional Services 2% of direct costs $0 $4,200 General & Administrative 2% of direct costs $0 $4,200
Property Tax During Construction 1% of retail value $0 $2,100 Financing Costs 4% of direct costs $3 $59,680
Developer Fee 5% of direct costs $2 $37,310
Total Indirect Costs $73 $1,393,690
Subtotal, Direct, and Indirect Costs $84 $1,603,690
Contingency 5.0% of direct and indirect costs $4 $80,185 Project Return 15% of direct and indirect costs $13 $252,581 Total Costs $102 $1,936,456
NET PROJECT VALUE $914,000
Per Square Foot $45
[1] Based on conversations with local brokers and CoStar listings of newer office, restaurant, and retail lease rates. [2] Assumes annual parking payment is paid by and associated with the retail tenant operations. [3] According to Rider Levett Bucknall and EPS experience in the area. [4] Based on conversations with local brokers.

Sources: City of Orange; CoStar; Economic & Planning Systems, Inc.

PRELIMINARY DRAFT
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Table 3
Example 2 - Mixed Use Redevelopment / Change of Ownership1 The Orange Old Towne Parking Study; EPS #214044
DEVELOPMENT PROGRAM ASSUMPTIONS ASSUMPTION/FACTOR PER BLDG SQ. FT. AMOUNT Description Change in use from retail & storage to restaurant & residential Based on example of Old Towne Gateway (401 W Chapman Ave) Gross Land Area (sq. ft.) 30,300
Existing Space
Gross Building Area (SF) 12,000
Historic Structure, Retail Use (SF) 5,250
Historic Structure, Storage Use (SF) 500
Non‐Historic Structure, Storage Use (SF) 6,250
Proposed Space
Proposed Demolition (SF) 6,250
Proposed New Building Area (SF) 12,600
New Restaurant (SF) 1,600
New Trash Enclosure & Storage (SF) 100
New Residential (SF) 10,900
Proposed Gross Building Area (SF) 18,350
Restaurant (SF) 6,850
Trash Enclosure & Storage (SF) 600
Residential (SF) 3 Two‐Story Buildings 10,900 Residential Rental Unit Count 1,090 sq. ft. per unit 10 Parking Spaces Required
Restaurant 4 per 1,000 square feet 28 Residential 1.8 per unit (assume all 2‐Bedroom units) 18 Total Parking Spaces Required 46
Parking Spaces Proposed On‐Site 18
Parking Deficit 28
REVENUE ASSUMPTIONS ASSUMPTION/FACTOR PER BLDG SQ. FT. AMOUNT Existing Revenue
Restaurant
Gross Revenue (NNN) $0.00 /sq. ft./yr $0
Capitalized Value 6.0% cap rate $0 $0
Proposed Revenue
Restaurant Retail
Gross Revenue (NNN)1 $36.00 /net sq. ft./yr $246,600
(less) Operating Expenses 3.0% ($7,398)
(less) Commissions 5.0% ($12,330)
(less) Vacancy Rate 5.0% ($12,330)
Subtotal, Annual Net Operating Income $31 $214,542
Capitalized Retail Value 5.0% cap rate $626 $4,290,840
Residential
Gross Potential Rent $3.25 per SF/Month $39 $425,100
(less) Vacancy Rate 5.0% of Gross Potential Rent ‐$2 ($21,255) Gross Residential Revenue $37 $403,845
(less) Operating Expenses 30.0% of Gross Revenue ‐$7 $121,154 Net Operating Income (NOI) $21 $282,692
Supportable Development Cost 5.0% Project Yield Rate (on NOI) $413 $5,653,830 Capitalized Residential Value 3.5% cap rate $741 $8,076,900 Net Value Increase $674 $12,367,740

PRELIMINARY DRAFT
433
ANNUAL PARKING PAYMENT IMPACT ASSUMPTION/FACTOR PER BLDG SQ. FT. AMOUNT Annual Parking Payment Cost $0 per space per year $0
Capitalized Value2 5.0% retail cap rate $0
DEVELOPMENT COSTS ASSUMPTION/FACTOR PER BLDG SQ. FT. AMOUNT Direct Costs
Building Costs
Building Construction Cost3 $275 /GLA sq. ft. $289 $3,465,000 Site work $10 /GLA sq. ft. $10 $120,000
Parking Cost $40,000 per space $60 $720,000
Total Direct Costs $359 $4,305,000
Indirect Costs
Tenant Improvements (restaurant)4 $75.00 /net sq. ft. $43 $513,750 Parking In Lieu Fee $7,000 per space $16 $196,000
A&E 5% of direct costs $18 $215,250
Other Professional Services 3% of direct costs $11 $129,150 General & Administrative 3% of direct costs $11 $129,150 Property Tax During Construction 1% of retail value $4 $43,050 Financing Costs 6% of direct costs $25 $300,885
Developer Fee 4% of direct costs $16 $188,650
Total Indirect Costs $143 $1,715,885
Subtotal, Direct, and Indirect Costs $502 $6,020,885
Contingency 5.0% of direct and indirect costs $25 $301,044 Project Return 15% of direct and indirect costs $79 $948,289 Total Costs $606 $7,270,219
RESIDUAL LAND VALUE $5,098,000
Per Land Square Foot5 $168.25
[1] Based on conversations with local brokers and CoStar listings of newer office, restaurant, and retail lease rates. [2] Assumes annual parking payment is paid by and associated with the retail tenant operations. [3] According to Rider Levett Bucknall and EPS experience in the area. [4] Based on conversations with local brokers.

Sources: City of Orange; CoStar; Economic & Planning Systems, Inc. [5] Based on CoStar transaction data from Aug 2020 - Aug 2022, land value estimated at $162 per square foot. Example property at 401 W Chapman Street sold for $5,000,000 in 2017.

PRELIMINARY DRAFT
434
Table 4
Example 3 - New Construction / Expansion
The Orange Old Towne Parking Study; EPS #214044
DEVELOPMENT PROGRAM ASSUMPTIONS ASSUMPTION/FACTOR PER BLDG SQ. FT. AMOUNT Description New Retail/Office construction along Glassell Street Based on example of Jensen Building (190 S Glassell St) Gross Land Area (sq. ft.) 50,200
Existing Space
Gross Building Area (SF) 11,200
Retail space (SF) 11,200
Existing Parking Spaces 60
Proposed Space
Proposed New Building Area (SF) 17,600
Proposed Gross Building Area (SF) 28,800
Existing Retail (SF) 11,200
Retail (SF) 4,400
Restaurant (SF) 4,400
Office (SF) 8,800
Parking Spaces Required
Retail/Restaurant/Office 4 per 1,000 square feet 116 Total Parking Spaces Required
Parking Spaces Proposed On‐Site 65
Parking Deficit 51
REVENUE ASSUMPTIONS ASSUMPTION/FACTOR PER BLDG SQ. FT. AMOUNT Existing Revenue
Gross Revenue (NNN)1 $30.00 /sq. ft./yr $336,000
(less) Operating Expenses 3.0% ($10,080)
(less) Vacancy Rate 5.0% ($16,800)
Subtotal, Annual Net Operating Income $28 $309,120
Capitalized Value 5.0% cap rate $552 $6,182,400
Proposed Revenue
Retail/Restaurant
Existing Retail Revenue (NNN)1 $30.00 /sq. ft./yr $336,000 New Retail Revenue (NNN)1 $36.00 /sq. ft./yr $158,400
New Restaurant Revenue (NNN)1 $36.00 /sq. ft./yr $158,400 (less) Operating Expenses 3.0% ($19,584)
(less) Commissions 5.0% ($32,640)
(less) Vacancy Rate 5.0% ($32,640)
Subtotal, Annual Net Operating Income $65 $567,936
Capitalized Retail Value 5.0% cap rate $1,014 $11,358,720 Office
Gross Revenue (NNN)1 $31.00 /net sq. ft./yr $272,800
(less) Operating Expenses 3.0% ($8,184)
(less) Commissions 5.0% ($13,640)
(less) Vacancy Rate 10.0% ($27,280)
Subtotal, Annual Net Operating Income $20 $223,696
Capitalized Office Value 6.0% cap rate $424 $3,728,267
Net Value Increase $506 $8,904,587

PRELIMINARY DRAFT
435
ANNUAL PARKING PAYMENT IMPACT ASSUMPTION/FACTOR PER BLDG SQ. FT. AMOUNT Annual Parking Payment Cost $0 per space per year $0
Capitalized Value2 5.0% retail cap rate $0
DEVELOPMENT COSTS ASSUMPTION/FACTOR PER BLDG SQ. FT. AMOUNT Direct Costs
Building Costs
Building Construction Cost3 $275 /GLA sq. ft. $432 $4,840,000 Site work $10 /GLA sq. ft. $10 $112,000
Total Direct Costs $442 $4,952,000
Indirect Costs
Tenant Improvements (retail)4 $30.00 /net sq. ft. $30 $132,000 Tenant Improvements (restaurant)4 $60.00 /net sq. ft. $60 $264,000 Tenant Improvements (office) $30.00 /net sq. ft. $30 $264,000 Parking In Lieu Fee $7,000 per space $12 $357,000
A&E 2% of direct costs $9 $99,040
Other Professional Services 2% of direct costs $9 $99,040 General & Administrative 2% of direct costs $9 $99,040
Property Tax During Construction 1% of retail value $4 $49,520 Financing Costs 4% of direct costs $21 $238,760
Developer Fee 5% of direct costs $24 $270,402
Total Indirect Costs $167 $1,872,802
Subtotal, Direct, and Indirect Costs $609 $6,824,802
Contingency 5.0% of direct and indirect costs $30 $341,240 Project Return 15% of direct and indirect costs $96 $1,074,906 Total Costs $736 $8,240,948
NET PROJECT VALUE $664,000
Per Square Foot $23
[1] Based on conversations with local brokers and CoStar listings of newer office, restaurant, and retail lease rates. [2] Assumes annual parking payment is paid by and associated with the retail tenant operations. [3] According to Rider Levett Bucknall and EPS experience in the area. [4] Based on conversations with local brokers.

Sources: City of Orange; CoStar; Economic & Planning Systems, Inc.

PRELIMINARY DRAFT
436
Table 5
Example 4 - Outdoor Dining Expansion
The Orange Old Towne Parking Study; EPS #214044
DEVELOPMENT PROGRAM ASSUMPTIONS ASSUMPTION/FACTOR PER BLDG SQ. FT. AMOUNT Description Building new outdoor dining space with existing restauarant tenants.

Gross Land Area (sq. ft.) 10,000
Existing Space
Gross Building Area (SF) 4,000
Restaurant use (SF) 4,000
Existing Parking Spaces Equivalent 16
Proposed Space
Proposed New Outdoor Dining Area (SF) 1,000
Proposed Gross Building Area (SF) 5,000
Restaurant (SF) 4,000
Outdoor Dining Area (SF) 1,000
Net New Parking Spaces Required
Restaurant/Office 4 per 1,000 square feet 16 Total Parking Spaces Required
Parking Spaces Proposed On‐Site 12
Parking Deficit 4
REVENUE ASSUMPTIONS ASSUMPTION/FACTOR PER BLDG SQ. FT. AMOUNT Existing Revenue
Gross Revenue (NNN)1 $30.00 /sq. ft./yr $120,000
(less) Operating Expenses 3.0% ($3,600)
(less) Vacancy Rate 5.0% ($6,000)
Subtotal, Annual Net Operating Income $28 $110,400
Capitalized Value 5.0% cap rate $552 $2,208,000
Proposed Revenue
Retail/Market/Restaurant
Gross Revenue (NNN)1 $30.00 /sq. ft./yr $120,000
Outdoor Dining Premium $15.00 /sq. ft./yr $15,000
(less) Operating Expenses 3.0% ($3,600)
(less) Vacancy Rate 5.0% ($6,000)
Subtotal, Annual Net Operating Income $31 $125,400
Capitalized Retail Value 5.0% cap rate $627 $2,508,000
Net Value Increase $60 $300,000

PRELIMINARY DRAFT
437
ANNUAL PARKING PAYMENT IMPACT ASSUMPTION/FACTOR PER BLDG SQ. FT. AMOUNT Annual Parking Payment Cost $0 per space per year $0
Capitalized Value 5.0% cap rate $0
DEVELOPMENT COSTS ASSUMPTION/FACTOR PER BLDG SQ. FT. AMOUNT Direct Costs
Outdoor Dining Patio Improvements $50 /GLA sq. ft. $50 $50,000 Total Direct Costs $13 $50,000
Indirect Costs
Parking In Lieu Fee $7,000 per space $6 $28,000
A&E 2% of direct costs $0 $1,000
Other Professional Services 2% of direct costs $0 $1,000 General & Administrative 2% of direct costs $0 $1,000
Financing Costs 4% of direct costs $1 $3,120
Total Indirect Costs $9 $34,120
Subtotal, Direct, and Indirect Costs $21 $84,120
Contingency 5.0% of direct and indirect costs $1 $4,206 Project Return 15% of direct and indirect costs $3 $13,249 Total Costs $25 $101,575
NET PROJECT VALUE $198,000
Per Square Foot $40
[1] Based on broker conversations and CoStar listings of newer office, restaurant, and retail lease rates.

Sources: City of Orange; CoStar; Economic & Planning Systems, Inc.

PRELIMINARY DRAFT
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Agenda Item
City Council
Item #: 6.2. 4/11/2023 File #: 23-0223
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Leslie Hardy, Community Services Director

1. SUBJECT
Parameters for Naming the Pocket Park at Well 28.

2. SUMMARY
At its March 14, 2023 meeting, the City Council discussed naming of the future Pocket Park at the Well 28 site. The City Council expressed interest in discussing and setting parameters for naming the future park.

3. RECOMMENDED ACTION
Provide direction to staff regarding naming parameters for the future Pocket Park at Well 28.

4. FISCAL IMPACT
None.

5. STRATEGIC PLAN GOALS
Goal 3: Enhance and promote quality of life in the community a: Renovate, maintain, develop, and/or expand public use places and spaces.

6. DISCUSSION AND BACKGROUND
Well 28 is located at 225 W. Maple Street, in the Old Towne area of the City of Orange. In addition to constructing a well, the site will also include a public pocket park surrounding the perimeter of the well facility. At its March 14, 2023 meeting, the City Council approved the plans and specifications for the project and authorized the Public Works Department to solicit construction bids.

During this item, the City Council discussed providing parameters for names for the future park.

Possible parameters could include a connection to the Cypress Barrio, a significant historical figure from that area, etc. Community Services staff will then work with the Park Planning and Community Events Commission (Commission) to solicit input for potential name options based on those parameters. The Commission has recently developed a process for collecting input for names of future parks.

Based on the input received, the Commission would then present the City Council with three potential name options for consideration, as the selection of the name of the park is left to the discretion of the City Council.

At this time, staff is recommending that the City Council provide naming parameters for the future City of Orange Page 1 of 2 Printed on 4/6/2023
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Item #: 6.2. 4/11/2023 File #: 23-0223
At this time, staff is recommending that the City Council provide naming parameters for the future pocket park.

7. ATTACHMENTS
· None
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Agenda Item
City Council
Item #: 6.2. 4/11/2023 File #: 23-0223
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Leslie Hardy, Community Services Director

1. SUBJECT
Parameters for Naming the Pocket Park at Well 28.

3. RECOMMENDED ACTION
Provide direction to staff regarding naming parameters for the future Pocket Park at Well 28.

4. FISCAL IMPACT
None.

5. STRATEGIC PLAN GOALS
Goal 3: Enhance and promote quality of life in the community a: Renovate, maintain, develop, and/or expand public use places and spaces.

During this item, the City Council discussed providing parameters for names for the future park.

At this time, staff is recommending that the City Council provide naming parameters for the future City of Orange Page 1 of 2 Printed on 4/6/2023
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Item #: 6.2. 4/11/2023 File #: 23-0223
At this time, staff is recommending that the City Council provide naming parameters for the future pocket park.

7. ATTACHMENTS
· None
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Agenda Item
City Council
Item #: 6.3. 4/11/2023 File #: 23-0245
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Russell Bunim, Community Development Director

1. SUBJECT
A Resolution delegating authority to the City Manager to make technical changes and other nonsubstantive edits to the 2021-2029 Housing Element that may result from the California Department of Housing and Community Development review, in a form approved by the City Attorney, for final certification of the Housing Element, without further City Council consideration or re-adoption of the 2021-2029 Housing Element.

2. SUMMARY
The 2021-2029 Housing Element of the General Plan was adopted by the City Council on February 14, 2022. The document was found to be in substantial conformance with state law on January 27, 2023 by the California Department of Housing and Community Development (HCD). However, prior to state certification HCD has requested additional information about certain identified candidate housing sites that may warrant minor revisions to the adopted Element. Given the non-substantive nature of the potential edits, HCD has indicated that such revisions may be made by the City Manager provided that the Council grants this authority through adoption of a resolution.

3. RECOMMENDED ACTION
Adopt Resolution No. 11448. A Resolution of the City Council of the City of Orange granting the City Manager the authority to make specified changes to the 2021-2029 adopted Housing Element.

4. FISCAL IMPACT
None.

5. STRATEGIC PLAN GOALS
Goal 3: Enhance and promote quality of life in the community c: Support and enhance attractive, diverse living environments.

6. DISCUSSION AND BACKGROUND
On February 10, 2023, the City Council adopted Resolution No. 11431 approving General Plan Amendment No 2022-0001 which adopted the City of Orange 2021-2029 General Plan Housing Element (Housing Element). The adopted Housing Element was sent to the California Department of Housing and Community Development (HCD) for review and certification.

In discussions between City staff and HCD staff, HCD has requested minor non-substantive corrections and supplemental information clarifying the City’s methodology and processes in City of Orange Page 1 of 2 Printed on 4/6/2023
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Item #: 6.3. 4/11/2023 File #: 23-0245
corrections and supplemental information clarifying the City’s methodology and processes in determining the components of the Housing Element. This Resolution will authorize the City Manager to approve such changes and supplemental explanations, subject to approval of the City Attorney as to form. This delegation will ensure quick and timely response to HCD and certification of the Housing Element.

7. ATTACHMENTS
· Resolution No. 11448
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Agenda Item
City Council
Item #: 6.3. 4/11/2023 File #: 23-0245
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Russell Bunim, Community Development Director

4. FISCAL IMPACT
None.

5. STRATEGIC PLAN GOALS
Goal 3: Enhance and promote quality of life in the community c: Support and enhance attractive, diverse living environments.

In discussions between City staff and HCD staff, HCD has requested minor non-substantive corrections and supplemental information clarifying the City’s methodology and processes in City of Orange Page 1 of 2 Printed on 4/6/2023
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Item #: 6.3. 4/11/2023 File #: 23-0245
corrections and supplemental information clarifying the City’s methodology and processes in determining the components of the Housing Element. This Resolution will authorize the City Manager to approve such changes and supplemental explanations, subject to approval of the City Attorney as to form. This delegation will ensure quick and timely response to HCD and certification of the Housing Element.

7. ATTACHMENTS
· Resolution No. 11448
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RESOLUTION NO. 11448

A RESOLUTION OF THE CITY COUNCIL OF

THE CITY OF ORANGE GRANTING THE CITY

MANAGER THE AUTHORITY TO MAKE
SPECIFIED CHANGES TO THE 2021-2029

ADOPTED HOUSING ELEMENT
WHEREAS, following a public hearing held on February 10, 2023, the City Council adopted Resolution No. 11431, which approved General Plan Amendment No. 2022-0001, adopting and adding the 2021-2029 Housing Element to the City of Orange’s General Plan (the “Housing Element”); and
WHEREAS, after being adopted, the Housing Element was submitted to the California Department of Housing and Community Development (“HCD”) on February 14, 2023; and WHEREAS, after reviewing the Housing Element, HCD requested certain changes and clarifications be made to the Housing Element in order for the City to obtain HCD certification in accordance with California law, which changes consist of clerical corrections, minor technical changes and/or supplemental information for the Housing Element.

NOW, THEREFORE, BE IT BE RESOLVED by the City Council of the City of Orange as follows:

Delegation of Authority. The City Manager is hereby authorized to make clerical corrections; minor technical changes; other non-substantive edits; and/or append supplemental information to the Housing Element, in a form approved by the City Attorney, to ensure the Housing Element receives final certification from the State of California. Unless substantive changes are required, no additional City Council action is required to ratify such changes.

ADOPTED this ____ day of ___________________, 2023.

Daniel R. Slater, Mayor, City of Orange
ATTEST:

Pamela Coleman, City Clerk, City of Orange
447
2 STATE OF CALIFORNIA )

COUNTY OF ORANGE )

AYES: COUNCILMEMBERS:

NOES: COUNCILMEMBERS:

ABSENT: COUNCILMEMBERS:

ABSTAIN: COUNCILMEMBERS:

Pamela Coleman, City Clerk, City of Orange
448
Agenda Item
City Council
Item #: 8.1. 4/11/2023 File #: 23-0217
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Christopher Cash, Public Works Director

1. SUBJECT
Introduction and First Reading of Ordinance No. 05-23 authorizing updates to the informal bid limits set forth in the Orange Municipal Code.

2. SUMMARY
The current informal bid limits in the Orange Municipal Code reflect outdated dollar limits, which conflict with periodic amendments issued by the California Uniform Construction Cost Accounting Commission. The proposed Ordinance updates the informal bid limits to reference the current Uniform Construction Cost Account Act values.

3. RECOMMENDED ACTION
Introduce and conduct First Reading of Ordinance No. 05-23. An Ordinance of the City Council of the City of Orange amending Chapter 3.08 of the Orange Municipal Code to update Uniform Public Construction Cost Accounting Act references to conform to current law.

4. FISCAL IMPACT
None.

5. STRATEGIC PLAN GOALS
Goal 4: Provide outstanding public service
b: Provide facilities and services to meet customer expectations.

6. DISCUSSION AND BACKGROUND
On June 22, 1999, the City Council adopted Resolution No. 9133 electing to become subject to the Uniform Construction Cost Accounting Act, Public Contract Code Section 22030 et seq. (the “Act”) for public project construction work contracted by the City of Orange. The benefit of the Act is that it allows a city’s formal and informal bid limits to adapt to current economic conditions by having them adhere to those limits established by the California Uniform Construction Cost Accounting Commission, as amended from time to time. However, Ordinance No. 10-06, adopted on June 13, 2006, codified the then-current (2006) bid limits into the Orange Municipal Code (OMC). Codification of the 2006 dollar limits has created a discrepancy between the City’s adherence to the Act and the outdated references in the OMC. For example, in 2006, the informal bid limit was $125,000. Today, the informal bid limit is $200,000. In 2006, the City could perform public work by force account up to $30,000 but today that limit is $60,000.

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Item #: 8.1. 4/11/2023 File #: 23-0217
Ordinance No. 05-23 will amend the pertinent provisions in Chapter 3.08 of the OMC to replace language specifying a dollar limit with a general statement referencing the values set forth in Section 22032(a) of the Act. Thus, the OMC will adhere to the limits specified in the Act when this limit is amended in the future, as intended.

7. ATTACHMENTS
· Ordinance No. 05-23 - CLEAN
· Ordinance No. 05-23 - REDLINED
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Agenda Item
City Council
Item #: 8.1. 4/11/2023 File #: 23-0217
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Christopher Cash, Public Works Director

1. SUBJECT
Introduction and First Reading of Ordinance No. 05-23 authorizing updates to the informal bid limits set forth in the Orange Municipal Code.

4. FISCAL IMPACT
None.

5. STRATEGIC PLAN GOALS
Goal 4: Provide outstanding public service
b: Provide facilities and services to meet customer expectations.

City of Orange Page 1 of 2 Printed on 4/6/2023
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Item #: 8.1. 4/11/2023 File #: 23-0217
Ordinance No. 05-23 will amend the pertinent provisions in Chapter 3.08 of the OMC to replace language specifying a dollar limit with a general statement referencing the values set forth in Section 22032(a) of the Act. Thus, the OMC will adhere to the limits specified in the Act when this limit is amended in the future, as intended.

7. ATTACHMENTS
· Ordinance No. 05-23 - CLEAN
· Ordinance No. 05-23 - REDLINED
City of Orange Page 2 of 2 Printed on 4/6/2023
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ORDINANCE NO. 05-23

AN ORDINANCE OF THE CITY COUNCIL OF

THE CITY OF ORANGE AMENDING CHAPTER

3.08 OF THE ORANGE MUNICIPAL CODE TO

UPDATE UNIFORM PUBLIC CONSTRUCTION

COST ACCOUNTING ACT REFERENCES TO
CONFORM TO CURRENT LAW.

WHEREAS, on June 22, 1999, the City Council adopted Resolution No. 9133 electing to become subject to the Uniform Construction Cost Accounting Act (the “Act”) for public project construction work contracted by the City of Orange; and WHEREAS, the benefit of the Act is that it allows a city’s formal and informal bid limits to adapt to current economic conditions by having them adhere to those limits established by the California Uniform Construction Cost Accounting Commission, as amended from time to time; and
WHEREAS, by Ordinance No. 10-06 adopted on June 13, 2006, the then-current (2006) bid limits were codified into the Orange Municipal Code; and WHEREAS, codification of the 2006 dollar limits has created a discrepancy between the City’s adherence to the Act and the outdated references in the Orange Municipal Code.

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF ORANGE DOES HEREBY ORDAIN AS FOLLOWS:

SECTION I:

This Ordinance is not a project under the California Environmental Quality Act (CEQA) per State CEQA Guidelines Section 15378, because it involves administrative activities of the City that will not result in direct or indirect physical changes in the environment.

SECTION II:

Section 3.08.500 of the Orange Municipal Code, “Revenue and Finance – Purchasing System – Public Projects – General Bid Limits,” is hereby revised to read as follows:

3.08.500 Public Projects—General Bid Limits.

A. Public projects up to that amount set forth in Public Contract Code section 22032(a), or as it may be amended from time to time, may be performed by the employees of the City by force account.
453
2 B. Public projects up to that amount set forth in Public Contract Code section 22032(a), or as it may be amended from time to time, may be let to contract by the informal bid procedures prescribed in Sections 3.08.150 through 3.08.170 of this chapter.

C. Public projects up to that amount set forth in Public Contract Code section 22032(b), or as it may be amended from time to time, may be let to contract by the informal procedures prescribed in Section 3.08.520 of this chapter.

D. Public projects greater than that amount set forth in Public Contract Code section 22032(c), or as it may be amended from time to time, shall, except as otherwise provided in this chapter, be let to contract by the formal bidding procedures prescribed in Sections 3.08.530 through 3.08.580 of this chapter.

E. The City Council may utilize the bidding procedures set forth in this chapter when contracting for “maintenance work” or when contracting for any other work which does not fall within the definition of “public project.”
SECTION III:

Section 3.08.520 of the Orange Municipal Code, “Revenue and Finance – Purchasing System – Public Projects – Informal Bidding Procedures,” is hereby revised to read as follows:

3.08.520 Public Projects—Informal Bidding Procedures.

Pursuant to the Uniform Public Construction Cost Accounting Act as adopted by the City (Public Contract Code section 22000 et seq.), the following shall govern the selection of contractors when a public project which is anticipated to fall within the monetary limits on informal bids described in Section 3.08.500.C of this chapter is to be performed:

A. The City shall prepare a notice of the opportunity to bid which describes the project in general terms, states the time and place for the submission of bids and describes how to obtain more detailed information about the project.

B. The City shall provide the notice to all contractors for the category of the work to be bid, as shown on the list of contractors developed and maintained by the Department of Public Works in accordance with criteria promulgated from time to time by the California Uniform Construction Cost Accounting Commission (“Commission”).

C. The City may also provide the notice to all construction trade journals specified by the Commission for the County of Orange. Additional contractors and/or construction trade journals may also be notified at the discretion of the Director of Public Works; provided, however:
(1) if the City has not prepared a list of qualified contractors for the particular category of work to be performed, the notice inviting bids shall be provided only to the construction trade journals 454
3 specified by the Commission; and (2) if the product or service is proprietary in nature such that it can be legally obtained only from a certain contractor(s), the notice inviting informal bids may be provided exclusively to such contractor(s).

D. All notices to contractors and construction trade journals pursuant to this section shall be provided not less than 10 calendar days before bids are due.

E. The City Manager shall have the authority to award informal contracts pursuant to this section with a value of $30,000 or less pursuant to the findings and recommendations presented by the Director of Public Works. Such contracts shall have the prior approval of, and be executed by, the City Manager and shall be approved as to form by the City Attorney. All contracts with a value in excess of $30,000 to be awarded pursuant to this section shall require the approval of the City Council and shall be executed by the Mayor and approved as to form by the City Attorney.

Unless the agreement provides otherwise, the City Manager may approve dollar increases to contracts that have been approved by the City Council. The extent of the City Manager’s authority to approve such increases shall be in the amount of $10,000 or 10%, whichever is greater.

However, in no event may the City Manager approve an increase of more than $30,000.

F. If all informal bids received exceed that amount set forth in Public Contract Code section 22032(b), or as it may be amended from time to time, and the City Council determines that the cost estimate was reasonable, the City Council may award the contract to the lowest responsible bidder at up to that additional amount set forth in Public Contract Code section 22034(d), or as it may be amended from time to time, by resolution approved by the vote of the whole City Council as required by Section 22034(d). Such contracts shall be executed by the Mayor and approved as to form by the City Attorney. Otherwise, such work shall be awarded to the lowest responsible bidder pursuant to the formal bid procedures prescribed in Sections 3.08.530 through 3.08.570 of this chapter
SECTION IV:

The first paragraph of Section 3.08.560 of the Orange Municipal Code, “Revenue and Finance – Purchasing System – Public Projects – Award of Formal Bid Contracts,” is hereby revised to read as follows:

3.08.560 Public Projects—Award of Formal Bid Contracts.

All contracts for public work with a value greater than that amount set forth in Public Contract Code section 22032(c), or as it may be amended from time to time, shall require the approval of the City Council and shall be executed by the Mayor and approved as to form by the City Attorney. Unless the agreement provides otherwise, the City Manager may approve dollar increases to contracts that have been approved by the City Council. The extent of the City Manager’s authority to approve such increases shall be in the amount of $10,000 or 10%, whichever is greater. However, in no event may the City Manager approve an increase of more than $30,000. If a contract is awarded, it shall be awarded by the City Council to the lowest 455
4 responsible bidder. The determination of the “lowest responsible bidder” shall be at the discretion of the City Council pursuant to the findings and recommendations presented by the Director of Public Works at the time of award of contract. In determining the lowest responsible bidder, the following shall be considered by the City Council, in addition to price:

SECTION V:

To the extent required to implement the provisions of this Ordinance, City staff is directed to modify any Administrative Policies in conflict herewith.

SECTION VI:

If any section, subdivision, paragraph, sentence, clause or phrase of this Ordinance is for any reason held to be invalid or unconstitutional, such decision shall not affect the validity of the remaining portions of this Ordinance. The City Council hereby declares that it would have passed this Ordinance, and each section, subdivision, paragraph, sentence, clause and phrase thereof, irrespective of the fact that any one (or more) section, subdivision, paragraph, sentence, clause or phrase had been declared invalid or unconstitutional.

SECTION VII:

The City Clerk is hereby directed to certify the adoption of this Ordinance and cause the same to be published as required by law. This Ordinance shall take effect thirty (30) days from and after the date of its final passage.

ADOPTED this day of , 2023.

Daniel R. Slater, Mayor, City of Orange
ATTEST:

Pamela Coleman, City Clerk, City of Orange
456
5 STATE OF CALIFORNIA )

COUNTY OF ORANGE )

CITY OF ORANGE )
I, PAMELA COLEMAN, City Clerk of the City of Orange, California, do hereby certify that the foregoing Ordinance was introduced at the regular meeting of the City Council held on the ___ day of _____________, 2023, and thereafter at the regular meeting of said City Council duly held on the ___ day of ____________, 2023 was duly passed and adopted by the following vote, to wit:

AYES: COUNCILMEMBERS:

NOES: COUNCILMEMBERS:

ABSENT: COUNCILMEMBERS:

ABSTAIN: COUNCILMEMBERS:

Pamela Coleman, City Clerk, City of Orange
457
ORDINANCE NO. 05-23

AN ORDINANCE OF THE CITY COUNCIL OF THE
CITY OF ORANGE AMENDING CHAPTER 3.08 OF

THE ORANGE MUNICIPAL CODE TO UPDATE

UNIFORM PUBLIC CONSTRUCTION COST

ACCOUNTING ACT REFERENCES TO
CONFORM TO CURRENT LAW.
[Pertinent provisions only]
SECTION II:

Section 3.08.500 of the Orange Municipal Code, “Revenue and Finance – Purchasing System – Public Projects – General Bid Limits,” is hereby revised to read as follows:

3.08.500 Public Projects—General Bid Limits.

A. Public projects of $30,000.00 or lessup to that amount set forth in Public Contract Code section 22032(a), or as it may be amended from time to time, may be performed by the employees of the City by force account.

B. Public projects up to that amount set forth in Public Contract Code section 22032(a), or as it may be amended from time to time, of $30,000.00 or less may be let to contract by the informal bid procedures prescribed in Sections 3.08.150 through 3.08.170 of this chapter.

C. Public projects up to that amount set forth in Public Contract Code section 22032(b), or as it may be amended from time to time, of $125,000.00 or less may be let to contract by the informal procedures prescribed in Section 3.08.520 of this chapter.

D. Public projects greater than that amount set forth in Public Contract Code section 22032(c), or as it may be amended from time to time, of more than $125,000.00 shall, except as otherwise provided in this chapter, be let to contract by the formal bidding procedures prescribed in Sections 3.08.530 through 3.08.580 of this chapter.

Section 3.08.520 of the Orange Municipal Code, “Revenue and Finance – Purchasing System – Public Projects – Informal Bidding Procedures,” is hereby revised to read as follows:
458
2 3.08.520 Public Projects—Informal Bidding Procedures.

B. The City shall mail provide the notice to all contractors for the category of the work to be bid, as shown on the list of contractors developed and maintained by the Department of Public Works in accordance with criteria promulgated from time to time by the California Uniform Construction Cost Accounting Commission (“Commission”).

C. The City may also mail provide the notice to all construction trade journals specified by the Commission for the County of Orange. Additional contractors and/or construction trade journals may also be notified at the discretion of the Director of Public Works; provided, however: (1) if the City has not prepared a list of qualified contractors for the particular category of work to be performed, the notice inviting bids shall be sent provided only to the construction trade journals specified by the Commission; and (2) if the product or service is proprietary in nature such that it can be legally obtained only from a certain contractor(s), the notice inviting informal bids may be sent provided exclusively to such contractor(s).

D. All mailings of notices to contractors and construction trade journals pursuant to this section shall be completed provided not less than 10 calendar days before bids are due.

E. The City Manager shall have the authority to award informal contracts pursuant to this section with a value of $30,000.00 or less pursuant to the findings and recommendations presented by the Director of Public Works. Such contracts shall have the prior approval of, and be executed by, the City Manager and shall be approved as to form by the City Attorney. All contracts with a value in excess of $30,000.00 to be awarded pursuant to this section shall require the approval of the City Council and shall be executed by the Mayor and approved as to form by the City Attorney. Unless the agreement provides otherwise, the City Manager may approve dollar increases to contracts that have been approved by the City Council. The extent of the City Manager’s authority to approve such increases shall be in the amount of $10,000.00 or 10%, whichever is greater. However, in no event may the City Manager approve an increase of more than $30,000.00.

F. If all informal bids received exceed that amount set forth in Public Contract Code section 22032(b), or as it may be amended from time to time, $125,000.00 and the City Council determines that the cost estimate was reasonable, the City Council may award the contract to the 459
3 lowest responsible bidder at up to $137,500.00that additional amount set forth in Public Contract Code section 22034(d), or as it may be amended from time to time, by resolution approved by the vote of the whole City Council as required in the Uniform Public Construction Cost Accounting Act, Public Contract Codeby Section 22000 22034(d)et seq. Such contracts shall be executed by the Mayor and approved as to form by the City Attorney. Otherwise, such work shall be awarded to the lowest responsible bidder pursuant to the formal bid procedures prescribed in Sections

3.08.530 through 3.08.570 of this chapter
SECTION IV:

3.08.560 Public Projects—Award of Formal Bid Contracts.

All contracts for public work with a value greater than that amount set forth in Public Contract Code section 22032(c), or as it may be amended from time to time, of more than $125,000.00 shall require the approval of the City Council and shall be executed by the Mayor and approved as to form by the City Attorney. Unless the agreement provides otherwise, the City Manager may approve dollar increases to contracts that have been approved by the City Council.

The extent of the City Manager’s authority to approve such increases shall be in the amount of $10,000.00 or 10%, whichever is greater. However, in no event may the City Manager approve an increase of more than $30,000.00. If a contract is awarded, it shall be awarded by the City Council to the lowest responsible bidder. The determination of the “lowest responsible bidder” shall be at the discretion of the City Council pursuant to the findings and recommendations presented by the Director of Public Works at the time of award of contract. In determining the lowest responsible bidder, the following shall be considered by the City Council, in addition to price:
460
Agenda Item
City Council
Item #: 9.1. 4/11/2023 File #: 23-0169
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Russell Bunim, Community Development Director

1. SUBJECT
Public Hearing to consider Appeal No. 0562-23, Street Lights Mixed-Use Apartment Development, 840 The City Drive South, including adoption of Mitigated Negative Declaration (MND) No. 1875-21 and associated Mitigation Monitoring and Reporting Program.

2. SUMMARY
An appeal of the Planning Commission approval of Conditional Use Permit No. 3138-21, Major Site Plan Review No. 1040-21, Design Review No. 5030-21, Administrative Adjustment No. 0051-21, and MND No. 1875-21 and associated Mitigation Monitoring and Reporting Program, to allow the demolition of an existing multi-tenant commercial building in order to construct a new 225-unit mixeduse apartment development with ground floor retail/restaurant area, subterranean parking, surface parking, residential amenities, open parking structure for the adjacent office complex use, site improvements, and a reduction of 48 parking spaces and 670 square feet of open space.

3. RECOMMENDED ACTION
The City Council shall consider the record and such additional evidence as may be offered and may affirm, reverse, or modify, in whole or in part, the action that was appealed. Staff will return to the Council at a subsequent meeting with a Resolution reflecting the action taken.

4. FISCAL IMPACT
None.

5. STRATEGIC PLAN GOALS
Goal 3: Enhance and promote quality of life in the community. c: Support and enhance attractive, diverse living environments.

6. DISCUSSION AND BACKGROUND
On February 23, 2023, the Planning Commission approved Conditional Use Permit No. 3138-21, Major Site Plan Review No. 1040-21, Design Review No. 5030-21, Administrative Adjustment No. 0051-21, and MND No. 1875-21 and associated Mitigation Monitoring and Reporting Program to allow for the demolition of an existing multi-tenant commercial building and surface parking lot in order to construct a new 225-unit vertical mixed-use apartment development, including 9,000 square feet of ground level retail/restaurant area, a 421-space three-level subterranean parking structure City of Orange Page 1 of 4 Printed on 4/6/2023
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feet of ground level retail/restaurant area, a 421-space three-level subterranean parking structure beneath the footprint of the building, 13 parallel surface parking spaces, residential amenities, a 145- space two-story open parking structure for the adjacent office complex use, site improvements, a 48- space (10%) reduction in required parking, and a 670-square-foot (0.98%) reduction in open space for the project.

The project site is currently developed with a one-story multi-tenant commercial building, a four-story office building, and surface parking lot. The project site is part of a larger 15.1-acre office complex containing four and eight story buildings, structured, and surface parking. Surrounding land uses include commercial uses to the north, east, and west, and single/multi-family residential uses to the south in the City of Santa Ana. More detailed information about the project is provided in the February 23, 2023 Planning Commission Staff Report (Attachment 6).

Planning Commission Hearing
The Planning Commission conducted a public hearing for the project on February 23, 2023. The Planning Commission approved the project by a unanimous (5-0) vote subject to Conditions of Approval within Resolution No. PC 33-22 (Attachment 7). The February 23, 2023 Planning Commission Meeting Draft Minutes are included as Attachment 8.

Appeal
On March 2, 2023, the Planning Division received an appeal application from Adam Frankel, Lozeau Drury LLP on behalf of Supporters Alliance for Environmental Responsibility (SAFER) (Attachment 1). The following reason was given for the appeal:

There is “fair argument” that the Project may have significant unmitigated adverse environmental impacts. Therefore, CEQA requires that the City of Orange (“City”) prepare an environmental impact report (“EIR”) for the Project, pursuant to the California Environmental Quality Act (“CEQA”), Public Resources Code section 21000, et seq. SAFER respectfully requests that you do not adopt the MND and instead undertake the necessary efforts to prepare an EIR, as required under CEQA. See Attached Letter.

Detailed comments on the content of the MND are presented in a letter from Mr. Frankel submitted with the appeal provided in Attachment 1. The environmental consultant’s written responses to Mr.

Frankel’s comments are included as Attachment 2.

Public Notification
On March 30, 2023, the City mailed a Public Hearing Notice for the April 11, 2023 City Council meeting to a total 574 property owners/tenants and persons specifically requesting notice. The project site was also posted with the notification on the same date.

7. ENVIRONMENTAL REVIEW
Mitigated Negative Declaration: MND No. 1875-21 (Attachments 9, 10, and 11) was prepared to evaluate the physical environmental impacts of the project, in conformance with the provisions of the California Environmental Quality Act (CEQA) per State CEQA Guidelines Section 15070 and in conformance with the Local CEQA Guidelines. The MND finds that the project will have less than significant impacts to the environment, with the implementation of standard conditions and mitigation measures related to Biological Resources, Cultural Resources/Tribal Cultural Resources, Geology and Soils, Hazards and Hazardous Materials, Hydrology and Water Quality, Noise, and City of Orange Page 2 of 4 Printed on 4/6/2023
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and Soils, Hazards and Hazardous Materials, Hydrology and Water Quality, Noise, and Transportation. Section 5 of the MND (Attachment 9) summarizes the project’s significant impacts, mitigation measures, and levels of significance after mitigation. Incorporation of mitigation measures into the project results in a reduction of significant impacts to less than significant levels to the environmental factors listed above. With the adoption of the MND and related Mitigation Monitoring and Reporting Program and implementation of conditions of approval contained in Resolution No. PC 33-22, potential environmental concerns are considered resolved.

The 20-day public review period began on November 23, 2022 and ended on December 14, 2023.

On November 23, 2022, the City sent a Notice of Intent to adopt MND No. 1875-21 to a total of 609 property owners and tenants within a 400-foot radius of the project site, adjacent cities, and other potentially affected public agencies and utility service providers initiating the public review period for the environmental document as described above. This notification was also on file with the Orange County Clerk Recorder and was posted at the site. Copies of the document were available for public review at Orange City Hall in the Offices of the City Clerk and Community Development Department, and on the City’s website.

The City received three comment letters during the public review period from the Department of Transportation (Caltrans), Orange County Health Care Agency, Environmental Health Division (OCHCA), and Orange County Transit Authority (OCTA). It is important to note that a comment letter was not received during the public review period from the appellant, Adam Frankel. Responses to comments to all correspondence received were forwarded to the respective authors in accordance with the requirements of CEQA in advance of the Planning Commission hearing. Copies of the comment letters and responses can be found in Attachment 12.

8. ATTACHMENTS
· Attachment 1 Appeal Application No. 0562-23 from Adam Frankel, Lozeau Drury LLP on behalf of SAFER
· Attachment 2 Responses to Appellant’s Comments
· Attachment 3 Vicinity Map
· Attachment 4 December 7, 2022 Design Review Committee Staff Report · Attachment 5 December 7, 2022 Design Review Committee Meeting Minutes · Attachment 6 February 23, 2023 Planning Commission Staff Report · Attachment 7 Planning Commission Resolution No. PC 33-22 · Attachment 8 February 23, 2023 Planning Commission Meeting Draft Minutes · Attachment 9 MND No. 1875-21, Dated November 14, 2022 · Attachment 10 MND No. 1875-21 Appendices
· Attachment 11 MND No. 1875-21 Mitigation Monitoring and Reporting Program, Dated January 26, 2023
· Attachment 12 Letters Received from Responsible Agencies and Responses to Comments for MND No. 1875-21
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· Attachment 13 Project Plans, Dated January 27, 2023
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Agenda Item
City Council
Item #: 9.1. 4/11/2023 File #: 23-0169
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Russell Bunim, Community Development Director

4. FISCAL IMPACT
None.

5. STRATEGIC PLAN GOALS
Goal 3: Enhance and promote quality of life in the community. c: Support and enhance attractive, diverse living environments.

6. DISCUSSION AND BACKGROUND
On February 23, 2023, the Planning Commission approved Conditional Use Permit No. 3138-21, Major Site Plan Review No. 1040-21, Design Review No. 5030-21, Administrative Adjustment No. 0051-21, and MND No. 1875-21 and associated Mitigation Monitoring and Reporting Program to allow for the demolition of an existing multi-tenant commercial building and surface parking lot in order to construct a new 225-unit vertical mixed-use apartment development, including 9,000 square feet of ground level retail/restaurant area, a 421-space three-level subterranean parking structure City of Orange Page 1 of 4 Printed on 4/6/2023
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Item #: 9.1. 4/11/2023 File #: 23-0169
feet of ground level retail/restaurant area, a 421-space three-level subterranean parking structure beneath the footprint of the building, 13 parallel surface parking spaces, residential amenities, a 145- space two-story open parking structure for the adjacent office complex use, site improvements, a 48- space (10%) reduction in required parking, and a 670-square-foot (0.98%) reduction in open space for the project.

Detailed comments on the content of the MND are presented in a letter from Mr. Frankel submitted with the appeal provided in Attachment 1. The environmental consultant’s written responses to Mr.

Frankel’s comments are included as Attachment 2.

7. ENVIRONMENTAL REVIEW
Mitigated Negative Declaration: MND No. 1875-21 (Attachments 9, 10, and 11) was prepared to evaluate the physical environmental impacts of the project, in conformance with the provisions of the California Environmental Quality Act (CEQA) per State CEQA Guidelines Section 15070 and in conformance with the Local CEQA Guidelines. The MND finds that the project will have less than significant impacts to the environment, with the implementation of standard conditions and mitigation measures related to Biological Resources, Cultural Resources/Tribal Cultural Resources, Geology and Soils, Hazards and Hazardous Materials, Hydrology and Water Quality, Noise, and City of Orange Page 2 of 4 Printed on 4/6/2023
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and Soils, Hazards and Hazardous Materials, Hydrology and Water Quality, Noise, and Transportation. Section 5 of the MND (Attachment 9) summarizes the project’s significant impacts, mitigation measures, and levels of significance after mitigation. Incorporation of mitigation measures into the project results in a reduction of significant impacts to less than significant levels to the environmental factors listed above. With the adoption of the MND and related Mitigation Monitoring and Reporting Program and implementation of conditions of approval contained in Resolution No. PC 33-22, potential environmental concerns are considered resolved.

The 20-day public review period began on November 23, 2022 and ended on December 14, 2023.

8. ATTACHMENTS
· Attachment 1 Appeal Application No. 0562-23 from Adam Frankel, Lozeau Drury LLP on behalf of SAFER
· Attachment 2 Responses to Appellant’s Comments
· Attachment 3 Vicinity Map
· Attachment 4 December 7, 2022 Design Review Committee Staff Report · Attachment 5 December 7, 2022 Design Review Committee Meeting Minutes · Attachment 6 February 23, 2023 Planning Commission Staff Report · Attachment 7 Planning Commission Resolution No. PC 33-22 · Attachment 8 February 23, 2023 Planning Commission Meeting Draft Minutes · Attachment 9 MND No. 1875-21, Dated November 14, 2022 · Attachment 10 MND No. 1875-21 Appendices
· Attachment 11 MND No. 1875-21 Mitigation Monitoring and Reporting Program, Dated January 26, 2023
· Attachment 12 Letters Received from Responsible Agencies and Responses to Comments for MND No. 1875-21
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· Attachment 13 Project Plans, Dated January 27, 2023
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Cover Letter
March 20, 2023
Monique Schwartz, Associate Planner
City of Orange Planning Division
300 East Chapman Avenue
Orange, CA 92866
Subject: Response to Comments—City of Orange 840 The City Drive Apartments Dear Ms. Schwartz:

FirstCarbon Solutions (FCS) is pleased to submit this Response to Comments letter for the proposed 840 The City Drive Apartments Project (proposed project) in the City of Orange.

This letter includes responses to the opposition letter from Lozeau Drury LLP, dated February 22, 2023, regarding the Draft Initial Study/Mitigated Negative Declaration (Draft IS/MND) for the proposed project.

Although a lead agency is not required to provide written responses to comments on an IS/MND under the California Environmental Quality Act (CEQA), the City of Orange has evaluated the comments received on the Draft IS/MND and has elected to provide responses to comments regarding environmental issues. None of the comments received require significant revisions to the Draft IS/MND, result in the need to prepare an Environmental Impact Report (EIR), or require recirculation of the Draft IS/MND.

If you should have any questions, please feel free to contact me by phone at cso@fcsintl.com.

Sincerely,
Cecilia So, Senior Project Manager
FirstCarbon Solutions
250 Commerce, Suite 210
Irvine, CA 92602
Enc: Attachment A: Comment Letter
511
1 Responses to
Comments

RESPONSES TO COMMENTS
List of Authors
The comment letter from Lozeau Drury, LLP, dated February 22, 2023, regarding the Draft IS/MND for the proposed project is included in Attachment A and is transcribed below. In the following responses to comments memorandum, the text of the communication is summarized and followed by the corresponding response. Individual comments within each communication are numbered so comments can be cross-referenced with responses.

Author Code
Lozeau Drury, LLP .................................................................................................................................DRURY 512
2 Responses to
Comments
Letter from Lozeau Drury LLP, dated February 22, 2023
Comment DRURY-1
This comment pertains to the Draft IS/MND’s CEQA adequacy. The commenter asserts that there is a fair argument that the proposed project may have adverse environmental impacts. The comment claims that an IS/MND pursuant to CEQA Guidelines 15162 and 15164 is not the appropriate level of review and requests that the City prepare an EIR.

The comment introduces the commenters and consultants who have been hired to contribute to this opposition letter. The comment claims that an IS/MND does not include the appropriate level of environmental analysis that would be afforded by an EIR and urges the City to prepare a Draft EIR for the proposed project.

Response to DRURY-1
To show that a Mitigated Negative Declaration (MND) is not adequate and that an EIR is required by CEQA, commenters must demonstrate that the record contains substantial evidence supporting a fair argument that the project may have a significant adverse environmental impact. For purposes of CEQA, “substantial evidence includes fact, a reasonable assumption predicated upon fact, or expert opinion supported by fact” (Public Resources Code [PRC] § 21080(e)(1)). “Substantial evidence is not argument, speculation, unsubstantiated opinion or narrative, evidence that is clearly inaccurate or erroneous, or evidence of social or economic impacts that do not contribute to, or are not caused by, physical impacts on the environment” (PRC § 21080(e)(2)).

For a fair argument to be supported by substantial evidence, it must be based upon an accurate, factual understanding of the proposed project. Based on the analysis conducted for this project, there would be no significant adverse environmental impacts associated with the proposed project; therefore, an IS/MND is the appropriate level of environmental documentation pursuant to CEQA. Furthermore, after review of the comment letter, the City has concluded that there is no substantial evidence in the comments, or elsewhere in the administrative record, to support a fair argument that the project may have a significant environmental impact on any resource evaluated under CEQA. Therefore, an EIR is not necessary or required for this project. Comments about project approval, including general opposition to the proposed project, will be forwarded to the City Council for consideration.

Comment DRURY-2
This comment describes the legal standard of an EIR and its purpose. The California Supreme Court has held that if no EIR has been prepared for a nonexempt project, but substantial evidence exists in the record that suggests that the project may result in significant adverse impacts, then the proper remedy is to order the preparation of an EIR. Significant environmental effect is defined broadly as a substantial or potentially substantial adverse change in the environment. An EIR is required if there is substantial evidence in the record that the proposed project may have a significant effect on the environment. A negative declaration can only be issued if there is not a "fair argument" that the project will have a significant environmental effect. 513
3 Responses to
Comments
Response to DRURY-2
The City properly prepared an Environmental Checklist, technical studies, and associated analyses to determine the appropriate scope of environmental review under CEQA. As documented in the Draft IS/MND, the Environmental Checklist concluded that the proposed project would not result in any significant environmental impacts that would not be able to be mitigated to a less than significant level.

The Draft IS/MND fully discloses potential environmental impacts and mitigation, as appropriate, and reduces impacts to below significance. Based on these conclusions, an EIR was not warranted or required by CEQA. In the following sections, the commenter discusses the proposed project’s impacts to air quality, greenhouse gas (GHG) emissions, energy, and hazardous materials, and claims that there is ample evidence to support a fair argument that the proposed project would result in significant impacts relating to the aforementioned resource areas. Please see Response to DRURY-1 regarding the appropriate level of CEQA documentation for the proposed project.

The information provided by the commenter is noted. The Draft IS/MND incorporates all relevant statutory, regulatory, and legal guidance. No revision to the Draft IS/MND in response to this comment’s general recitation of legal concepts is necessary.

Comment DRURY-3
This comment states that air quality experts from Baseline Environmental Consulting reviewed the Draft IS/MND and related documents for the proposed project and found substantial evidence of a fair argument that the proposed project would have significant air quality, GHG emissions, energy, and hazardous waste impacts. The comment recommends that an EIR must be prepared to further evaluate and mitigate these impacts.

Response to DRURY-3
Please see Response to DRURY-1 regarding the appropriate level of CEQA documentation for the proposed project. Please see Response to DRURY-2 for explanations why the potential fair arguments raised are not based on substantial evidence.

Comment DRURY-4
This comment discusses the Draft IS/MND’s analysis of air quality. Specifically, the comment states that there are issues with the Draft IS/MND’s claims about diesel particulate matter (DPM) and toxic air contaminant (TAC) emissions and the methods used in the analyses. Baseline Environmental Consulting also claims the Draft IS/MND failed to include a quantified Health Risk Assessment (HRA) for the proposed project, which will produce toxic DPM emissions during construction for approximately 1.5 years. The comment states that an EIR must be prepared to further address and mitigate these impacts.

Response to DRURY-4
The air quality analysis adequately analyzes potential health risk impacts to nearby sensitive receptors.

Specifically, the South Coast Air Quality Management District (SCAQMD) Localized Significance 514
4 Responses to
Comments
Thresholds (LST) were used to assess localized impacts from nitrogen oxide (NOX), carbon monoxide (CO), particulate matter less than 10 microns in diameter (PM10), and particulate matter less than 2.5 microns in diameter (PM2.5). The primary pollutant of concern during construction that would be assessed in a construction HRA is DPM. DPM differs from other TACs in that it is not a single substance, but a complex mixture of hundreds of substances. PM10 and PM2.5 are commonly used as proxies for the purposes of estimating and assessing DPM. As described in the Draft IS/MND, the SCAQMD LSTs represent the maximum emissions from a project that are not expected to cause or contribute to an exceedance of the most stringent applicable National Ambient Air Quality Standard (NAAQS) or California Ambient Air Quality Standard (CAAQS). The LSTs are developed based on the ambient concentrations of that pollutant for each source receptor area and distance to the nearest sensitive receptor. To assess impacts from the proposed project, the LST lookup values used were for a 2-acre project site and for sensitive receptors located within 25 meters from the source of emissions to present a conservative analysis. As described in the Draft IS/MND, if a project exceeds an applicable LST, then the SCAQMD recommends that project-specific air quality modeling be performed (such as a construction HRA). Furthermore, the LST thresholds are set to analyze on-site impacts during construction and the effect on nearby sensitive receptors. The following is from SCAQMD's Final Localized Significance Threshold Methodology:

The LST lookup tables provided in Appendix C allow a user to readily determine if the daily emissions for proposed construction or operational activities could result in significant localized air quality impacts. If the calculated emissions for the proposed construction or operational activities are below the LST emission levels found on the LST lookup tables, then the proposed construction or operation activity is not significant.

Proposed projects whose calculated emission budgets for the proposed construction or operational activities are above the LST emission levels found in the LST lookup tables should not assume that the project would necessarily generate adverse impacts.

Detailed emission calculations and/or air dispersion modeling may demonstrate that pollutant concentrations are below localized significant levels.1 As such, if a project’s construction emissions would not exceed LST thresholds, a project-specific air quality modeling report, such as an HRA, would not be necessary.

DPM can be represented by PM10 and PM2.5 because the primary source of DPM emissions during construction would be from construction equipment operating on the project site and emitting particulate matter. As shown in Table 7 of the Draft IS/MND, the proposed project would not generate significant daily PM10 and PM2.5 emissions and would not exceed the maximum daily on-site LST thresholds. Furthermore, the primary source of DPM emissions would occur during the most intense phase of construction activity, which as shown in Table 7 would be from demolition activity, which would only occur for an estimated 42 days. Health risks related to DPM emissions are due to long-term 1 South Coast Air Quality Management District (SCAQMD). 2003, revised 2008. Final Localized Significance Threshold Methodology.

Website: http://www.aqmd.gov/docs/default-source/ceqa/handbook/localized-significance-thresholds/final-lst-methodologydocument.pdf. Accessed March 20, 2023. 515
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exposure and not from acute exposure, as evident from the lack of non-cancer acute reference exposure level for DPM in the Consolidated Table of Office of Environmental Health Hazard Assessment (OEHHA)/California Air Resources Board (ARB) Approved Risk Assessment Health Values. 2 When referring
to the 2-month recommendation, the commenter is referencing language included in OEHHA's 2015 Guidance Manual for Preparation of Health Risk Assessments. 3 Specifically, OEHHA's guidance
recommends that assessing health impacts for project lasting less than 2 months is not advised due to the uncertainty in assessing cancer risk from very short-term exposures. However, this guidance does not mandate that a HRA should be conducted for project construction lasting longer than two months.

Furthermore, the OEHHA guidance is not specifically for construction impacts or impacts from DPM. The SCAQMD and ARB assess risks to DPM by assuming that exposure would occur for 24-hours per day, 350 days per year, over a 30-year period. In addition, SCAQMD provides a screening method in the form of LSTs to assess localized impacts from construction without needing to perform a refined project-level HRA to determine significance. As previously discussed, the proposed project would not generate PM10 or PM2.5 emissions that exceed LST thresholds and by extension would not generate DPM emissions that would be considered significant.

Furthermore, the nature of the proposed project’s operations does not warrant or trigger the need for an operational HRA. The commenter references the OEHHA Guidance Manual for Preparation of Health Risk Assessments as requiring an HRA. The OEHHA Guidance Manual for Preparation of Health Risk Assessments, as referenced by commenter, is largely intended to assess health risk from industrial stationary sources, which are often characterized by stationary point sources, including those within the Air Toxics Hot Spots Program. The title of that publication expressly exists under the Air Toxics Hot Spots Program—Air Toxics Hot Spot Program Guidance Manual for the Preparation of Risk Assessments.

OEHHA notes that the manual was developed “for use in implementing the Air Toxics Hot Spots Program.” Generally, a facility is subject to the Hot Spots Program if it: (1) manufactures, formulates, uses, or releases a substance subject to the Act (or a substance which reacts to form such a substance) and emits 10 tons or more per year of total organic gases, particulate matter, nitrogen oxides or sulfur oxides; (2) is listed in any district's existing toxics use or toxics air emission survey, inventory or report released or compiled by a district; or (3) manufactures, formulates, uses, or releases a substance subject to the Hot Spots Program (or substance which reacts to form such a substance) and emits less than 10 tons per year of criteria pollutants and is subject to emission inventory requirements. HRAs are often prepared in conjunction with CEQA review for facilities that will emit sources of contaminants in significant quantities, consistent with the concepts and facilities identified in the Air Toxics Hot Spot Program Guidance Manual.
4 However, project operations are not expected to generate meaningful amounts of TACs or DPM because the project’s proposed uses as a residential and commercial mixed-use development are not of the nature that are associated with such emissions, such as heavy industrial 2 California Air Resources Board (ARB). 2022. Consolidated Table of OEHHA/ARB Approved Risk Assessment Health Values. December 9.

Website: https://ww2.arb.ca.gov/sites/default/files/classic/toxics/healthval/contable12092022.pdf. Accessed March 13, 2023. 3 Office of Environmental Health Hazard Assessment (OEHHA). 2015. Air Toxics Hot Spots Program Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments. February. Website:
https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf. Accessed March 20, 2023. 4 California Office of Environmental Health Hazard Assessment (OEHHA). Air Toxics Hot Spots. Website: https://oehha.ca.gov/air/air-toxicshot-spots. Accessed March 10, 2023. 516
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uses. According to the ARB’s Air Quality and Land Use Handbook: A Community Health Perspective,5 projects should avoid siting new sensitive receptors within specific distances of certain sources of air pollutants. Specifically, Table 1-1 of the Air Quality Land Use Handbook: A Community Health Perspective describes several sources such as freeways, distribution centers, refineries, and dry cleaners, and the distance which lead agencies should avid siting new sensitive receptors. For example, this handbooks states that project should avoid siting new sensitive receptors within 1,000 feet of warehouse-type land uses that accommodate more than 100 trucks per day, more than 40 trucks with operating Transport Refrigeration Units (TRUs) per day, or where TRU unit operations exceed 300 hours per week. The proposed project would not be located within the screening distances of any of the listed sources in Table 1-1 of the Air Quality Land Use Handbook: A Community Health Perspective. Furthermore, the proposed project’s ground level retail/restaurant space would not generate more than 100 truck trips per day or include the use of TRUs because the proposed land uses would not warrant such large amounts of truck activity. Therefore, an operational HRA would not be warranted because the proposed project would not generate significant amounts of truck trips that would concentrate DPM emissions near sensitive receptors. The following is from SCAQMD's Final Localized Significance Threshold Methodology:

Detailed emission calculations and/or air dispersion modeling may demonstrate that pollutant concentrations are below localized significant levels.6 As such, if a project’s construction emissions would not exceed LST thresholds, a project-specific air quality modeling report, such as an HRA, would not be necessary.

Project operations would not result in meaningful quantities of DPM or TAC emissions because the project’s uses as a mixed-use development with residential and commercial uses are not those typically associated with such contaminants, and on-site emissions would be well below the SCAQMD operational LST thresholds as a result. The project would not be a large emitter, such as a chemical manufacturing plant, nor would it contain several smaller sources concentrated in a single area, such as industrial projects with truck loading docks. The proposed project would include residential and commercial land uses and not include a land use type that operates with a truck fleet, such as a warehouse or light 5 California Air Resources Board (ARB). 2005. Air Quality and Land Use Handbook: A Community Health Perspective. Website:
https://www.arb.ca.gov/ch/handbook.pdf. Accessed March 14, 2023. 6 South Coast Air Quality Management District (SCAQMD). 2003, revised 2008. Final Localized Significance Threshold Methodology.

Website: http://www.aqmd.gov/docs/default-source/ceqa/handbook/localized-significance-thresholds/final-lst-methodologydocument.pdf. Accessed March 20, 2023. 517
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industrial logistics center. The commenter does not identify any substantial sources of TACs associated with project operation. The commenter’s reference to operational DPM emissions resulting from vehicle trips, such as trucks, is not supported by evidence, as the vast majority of vehicles that would be owned and operated by future residents and employees would be gasoline-powered and not diesel-powered, which do not generate significant amounts of DPM or other TAC emissions. While it is possible that some portion of residents and employees will drive diesel-fueled vehicles and some deliveries to the commercial land use could be from heavy-duty trucks, these emissions would not be concentrated at the project site and any truck deliveries would not be in the amount to present a health risk. Rather, vehicle emissions would be dispersed throughout the local and regional roadways. In addition, the percentage of diesel-fueled vehicles from the project occupants would be comparable to regional fleet mix; therefore, the project would not cause a substantial increase in DPM emissions during project operations.

Considering this information, it is highly unlikely that long-term operations of the mixed-use, residential, and commercial uses would generate TAC emissions that expose sensitive receptors to substantial health risks. Consistent with the California OEHHA guidelines, the nominal quantity of TAC emissions from the proposed land uses do not trigger the need for an HRA for operational activities.

Comment DRURY-5
The commenter discusses the Draft IS/MND’s analysis of GHG emissions. The commenter states that the Draft IS/MND found that impacts related to GHG resulting from the proposed project to be insignificant because its estimated emissions rate is below the draft interim GHG threshold set by SCAQMD. However, the commenter claims that the SCAQMD has never formally adopted the interim threshold of 3,000 metric tons of carbon dioxide (MT CO2e), and that the Draft IS/MND failed to consider the State's long-term climate goals. The commenter claims that the Draft IS/MND also did not evaluate building decarbonization methods such as an all-electric building design, which the commenter claims is inconsistent with the key GHG reduction strategies under the 2022 Scoping Plan. The comment states that an EIR must be prepared to accurately assess and mitigate the proposed project's significant GHG emissions impact.

Response to DRURY-5
The Draft IS/MND’s use of the SCAQMD Draft Guidance Document Interim CEQA GHG Significance Threshold is the appropriate threshold to measure project impacts against because it is the only threshold SCAQMD has provided and is based on guidance from the City in 2020, as mentioned by the commenter.

Contrary to the commenter's assertion that the threshold is not supported by substantial evidence, the 3,000 MT CO2e per year threshold is based on a 90 percent emission “capture” rate methodology. Prior to its proposed use by the SCAQMD, the 90 percent emissions capture approach was one of the options suggested by the California Air Pollution Control Officers Association (CAPCOA) in their CEQA and Climate Change white paper (2008). A 90 percent emission capture rate means that unmitigated GHG emissions from the top 90 percent of all GHG-producing projects within a geographic area—the South Coast Air 518
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Basin (SoCAB) in this instance—would be subject to a detailed analysis of potential environmental impacts from GHG emissions, while the bottom 10 percent of all GHG-producing projects would be excluded from detailed analysis. A GHG significance threshold based on a 90 percent emission capture rate is appropriate to address the long-term adverse impacts associated with global climate change because medium and large projects will be required to implement measures to reduce GHG emissions, while small projects, which are generally infill development projects that are not the focus of the State’s GHG reduction targets, are allowed to proceed. Further, a 90 percent emission capture rate sets the emission threshold low enough to capture a substantial proportion of future development projects and demonstrate that cumulative emissions reductions are being achieved while setting the emission threshold high enough to exclude small projects that will, in aggregate, contribute approximate 1 percent of projected Statewide GHG emissions in the Year 2050. 7 In setting the proposed threshold at 3,000 MT CO2e per year, SCAQMD researched a database of projects kept by the Governor’s Office of Planning and Research (OPR). That database contained 798 projects, 87 of which were removed because they were very large projects and/or outliers that would skew emissions values too high, leaving 711 as the sample population to use in determining the 90th percentile capture rate. The SCAQMD analysis of the 711 projects within the sample population combined commercial, residential, and mixed-use projects. It should be noted that the sample of projects included warehouses and other light industrial land uses but did not include industrial processes (i.e., oil refineries, heavy manufacturing, electric generating stations, mining operations, etc.). Emissions from each of these projects were calculated by SCAQMD to provide a consistent method of emissions calculations across the sample population and from projects within the sample population. In calculating the emissions, the SCAQMD analysis determined that the 90th percentile ranged between 2,983 to 3,143 MT CO2e per year.

The SCAQMD set their significance threshold at the low-end value of the range when rounded to the nearest hundred tons of emissions (i.e., 3,000 MT CO2e per year) to define small projects that are considered less than significant and do not need to provide further analysis.

As discussed above, use of this threshold is also consistent with guidance provided in the CAPCOA CEQA and Climate Change handbook. The SCAQMD’s draft threshold uses the Executive Order S-3-05 goal as the basis for the 3,000 MT CO2e annual threshold and provides substantial evidence to support the logic behind the development of this threshold in its Working Group Meetings. 8 Achieving the Executive Order’s objective would contribute to worldwide efforts to cap carbon dioxide (CO2) concentrations at 450 parts per million (ppm), thus stabilizing global climate and ensuring the project would contribute its fair share to necessary GHG emission reductions. Moreover, the proposed project would be required to comply with California Green Building Standards Code (CALGreen) 7 South Coast Air Quality Management District (SCAQMD). December 5. Working Group Board Meeting. 2008. Website:
http://www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa-significance-thresholds/ghgboardsynopsis.pdf.

Accessed March 10, 2023. 8 Ibid.
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mandatory measures, which include four electric vehicle (EV) charging spaces on Basement Level B1.5 and B2 as well solar-ready infrastructure.

Finally, the 3,000 MT CO2e per year threshold has been used as the significance threshold by many local government lead agencies for mixed-use projects throughout the Southern California Association of Governments (SCAG) region since it was developed by the SCAQMD. While the commenter notes that several agencies throughout California have adopted lower GHG thresholds, they ignore the fact that other agencies have adopted numeric thresholds as high as 100,000 MT CO2e/year.9 For all of the reasons discussed above, the City has determined that the 3,000 MT CO2e per year threshold is supported by substantial evidence, and recommends that it be used in evaluating GHG impacts.

As described in the Draft IS/MND, the proposed project would increase residential density in a developed area within walking distance of existing transit, such as the Orange County Transportation Authority (OCTA) bus stops along Garden Grove Boulevard and The City Drive South, a Class I Bikeway along the Santa Ana River, and would not conflict with the measures proposed in the 2017 Scoping Plan.

As a result, the proposed project would be located in an area with existing alternative transportation infrastructure that could reduce the use of passenger vehicles, which produce the majority of GHG emissions associated with residential development. Additionally, the proposed project would include four EV charging spaces and bicycle lockers for the residents to use, which would provide further reduce the per capita GHG emissions of future residents. Moreover, the Draft IS/MND quantified all potential project GHG emissions and demonstrated that the proposed project would not exceed the 3,000 MT CO2e GHG threshold. Therefore, the Draft IS/MND does describe the proposed project’s contribution to GHG reductions, and GHG emissions have been adequately assessed in accordance with standard industry practice and applicable thresholds of significance for the region. Additionally, the installation of all-electric building design is not required, as the project does not need to reduce emissions to meet SCAQMD air quality emissions thresholds.

The commenter’s statement that the Draft IS/MND should evaluate the proposed project’s impacts against the newly released 2022 Scoping Plan is incorrect because the Public Draft IS/MND is dated November 14, 2022, and the public review period started November 23, 2022, both of which is prior to the formal adoption of the 2022 Scoping Plan on December 15, 2022. Therefore, it would have been impossible for the Draft IS/MND to consider measures in the 2022 Scoping Plan as the final measures were unknown at that time. (See A Local & Regional Monitor v. City of Los Angeles (“City of LA”) (1993) 12 Cal.App.4th 1773, 1801 ["F[airness and the need for finality” require that the adequacy of a CEQA document “be measured against those regulations in effect” when it was presented for public review]; CEQA Guidelines § 15007.)
9 See, e.g., Website: https://www.mdaqmd.ca.gov/home/showpublisheddocument/ 8510/637406182097070000 at p. 9.
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Comment DRURY-6
The commenter discusses the Draft IS/MND’s analysis of energy. The commenter states that CEQA requires projects to include measures to reduce wasteful energy consumption and define energy conservation as wise and efficient use of energy achieved by decreasing per capita consumption, reducing reliance on fossil fuels, and increasing reliance on renewable resources.

The commenter further states that compliance with building energy efficiency standards alone is not enough and cites recent court rulings that have emphasized the need to consider all feasible renewable energy options. The comment claims that the Draft IS/MND for the project evaluated the utility provider's energy mix but did not adequately consider feasible measures to reduce fossil fuel consumption.

Response to DRURY-6
The commenter cites no evidence specific to the proposed project to support the claim that the proposed project is wasteful, inefficient, or results in unnecessary consumption of energy warranting mitigation. The Draft IS/MND does not merely rely on compliance with Title 24 to determine impacts, and the commenter does not state what other regulations the Draft IS/MND did not consider. As shown in Appendix D, Energy Calculations, the Draft IS/MND included a detailed calculation of the proposed project’s energy consumption during construction and operation and considered and disclosed to the public all potential sources of energy demand. Therefore, the proposed project has disclosed all potential project energy impacts, and no other energy regulations or policies would be applicable to the project. The commenter is incorrect that the proposed project must consider feasible mitigation measures to reduce energy impacts because the project would result in less than significant impacts to energy resources. As described in the Draft IS/MND, the proposed project would not conflict or obstruct applicable policies related to energy efficiency. Environmental documents are not required to discuss mitigation measures for insignificant environmental impacts. A discussion of mitigation measures is only required for significant environmental effects (PRC § 21100(b)(3); CEQA Guidelines § 15126.4(a)(3)). For example, in North Coast Rivers Alliance v. Marin Mun. Water Dist. (2013) 216 CA4th 614, 649, the court held that an EIR was not required to discuss green energy credits as a mitigation measure for energy impacts where the environmental document determined that the project's energy impacts would be less than significant. As evaluated and disclosed in the Draft IS/MND, impacts would be less than significant and no further mitigation is required. Nonetheless, the analysis is expanded below to address concerns raised by the commenter. Considering the guidance provided by Appendix F of the CEQA Guidelines and the Appellate Court decision in League to Save Lake Tahoe Mountain etc. v. County of Placer (2022) 75 Cal.App.5th at pp. 164-168, the proposed project would be considered to result in wasteful, inefficient, or unnecessary consumption of energy resources if it would conflict with the following energy conservation goals:
• Decreasing overall per capita energy consumption;
• Decreasing reliance on fossil fuels such as coal, natural gas, or oil; and • Increasing reliance on renewable energy sources.
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Decreasing Overall Per Capita Energy Consumption
The project site is located in an urban area near existing OCTA transit routes as well as highways, and the project would provide bicycle lockers for resident use, as a result, the proposed project would not lead to excessive fuel consumption due to mobile vehicle use. As a mixed-use project the proposed land uses would serve multiple functions and lead to lower Vehicle Miles Traveled (VMT) compared to the majority of existing development in the region. As such, the proposed project would not increase per capita energy consumption or conflict with efforts being made to decrease overall per capital energy consumption in the region.

Decreasing Reliance on Fossil Fuels
As described in the Draft IS/MND Project Description, the proposed project would include four EV charging spaces and bicycle lockers for resident use, which would allow for the use of Zero-Emission Vehicles (ZEVs) and alternative transportation methods that would not generate energy demand.

Moreover, the Draft IS/MND disclosed all of the renewable power options available to the proposed project, including how Southern California Edison (SCE), the applicable utility provider, would meet California’s Renewable Portfolio Standard (RPS) of 60 percent by 2030 and carbon-free electricity by 2045. Therefore, the proposed project would decrease reliance on fossil fuels.

Increasing Reliance on Renewable Energy Sources
The proposed project would be served by SCE, which as mentioned previously, is on track to meet the RPS of 60 percent of electricity served by 2030 would be carbon-free. SCE also offers the SCE Green Rate 50 Percent option, which includes 67.5 percent eligible renewable (geothermal, solar, and wind), 4 percent large hydroelectric, 8.1 percent natural gas, 4.1 percent nuclear and 16.3 percent unspecified sources of power, and the SCE Green Rate 100 Percent option, which includes 100 percent eligible renewable (solar).10 In addition, the proposed project would comply with all applicable rules and regulations, including building code requirements that are aimed to increase reliance on renewable energy sources. As such, the proposed project would facilitate a greater dependance on renewable energy sources and would not conflict with any efforts being made to increase reliance on renewable energy sources. Therefore, the proposed project would be consistent with this criterion.

Comment DRURY-7
This comment claims that the Draft IS/MND fails to address and mitigate potential adverse impacts associated with hazardous materials. The comment claims that there was a release of tetrachloroethene (PCE) from a dry cleaning business located at the project site, and that additional environmental investigation activities were performed at the site in 2022 but not disclosed in the Draft IS/MND. The commenter claims a mitigation measure should be prepared that requires the applicant to submit a copy of the Department of Toxic Substances Control (DTSC) letter of No Further Action to the City prior to the issuance of building permits. The 10 See, e.g., Website: https://www.mdaqmd.ca.gov/home/showpublisheddocument/ 8510/637406182097070000 at p. 9.
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comment states an EIR must be prepared to evaluate and mitigate these impacts until these corrective actions are taken.

Response to DRURY-7
As discussed in Section 5.9, Hazards and Hazardous Materials, of the Draft IS/MND it is disclosed that the PCE release from the prior dry cleaning use occurred and was discovered in a 1999 soils investigation.

Furthermore, the current property owner entered into a Voluntary Cleanup Agreement with DTSC in November 2017 for assessing and remediating the PCE at the project site. Furthermore, MM HAZ-1 requires the Owner/Developer to retain a hazards specialist to conduct biweekly site visits to observe for areas of possible contamination. Should any hazardous materials be encountered, MM HAZ-1 requires notification and coordination with Orange County Health Care Agency (OCHCA).

OCHCA provided a comment letter, dated December 14, 2022, during the public review period of the Draft IS/MND. As requested by OCHCA, MM HAZ-1 was modified to include the contact information for the Orange County Solid Waste–LEA Supervisor and the Environmental Health Main Line, should hazardous materials be encountered.

It should be noted that the developer has been working with the DTSC for several years to ensure the site is properly treated for environmental risks. There were several testing bores drilled through the site, with soil samples taken from 10 to 35 inches at 5-inch increments. Groundwater testing indicated that the groundwater is clean for residential construction. Therefore, any potential environmental risks for this site were adequately explored and the current remediation plan in place is adequate to ensure the health of the future occupants.

Comment DRURY-8
The commenter claims that an EIR is required to evaluate new significant environmental effects.

Specifically, the commenter notes that indoor air emissions would result in significant impacts related to indoor air quality, particularly formaldehyde emissions. The commenter recommends various mitigation measures to reduce these impacts, including installing high-capacity air filters throughout the building and using only ARB approved no-added formaldehyde (NAF) resins or ultra-low emitting formaldehyde (ULEF) resins for all the building's interior spaces. The commenter states the City is required to prepare an EIR to evaluate and mitigate these impacts.

Response to DRURY-8
As an initial matter, CEQA is concerned with the potential adverse effects of the project on the environment. Notably, in California Building Industry Association v. Bay Area Air Quality Management District (2015) 62 C4th 369, 377, the California Supreme Court held that CEQA does not require an agency to consider the effects of existing environmental conditions on a proposed project's future users or residents. The Court reasoned that CEQA requires analysis of the impacts of a project on the environment, including whether a project could exacerbate hazards that are already present, but not impacts of the environment on a project. The Court specifically found that the effects of existing air pollution on future residents are not impacts that are required under CEQA’s evaluations. Accordingly, 523
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impacts of the environment on the project are not impacts under CEQA unless the project would exacerbate risks. As demonstrated in the Draft IS/MND the proposed project would be consistent with all applicable regulations pertaining to building materials and therefore would not exacerbate any risks.

Accordingly, none of the various mitigation measures suggested by commenter are necessary or required.

SAFER’s conclusion that “there is substantial evidence of a fair argument that the project will have significant adverse indoor air quality and health impacts,” presupposes that formaldehyde-containing composite wood products will be used in building materials as part of the project, particularly for all interior finish systems. The project proponent has not commissioned (and does not intent to commission) the use of formaldehyde-containing composite wood products in project building materials.

Consequently, the conclusion that there are significant impacts related to indoor formaldehyde emissions warrant additional evaluation and mitigation under CEQA is based on a false assumption and should be rejected.

Moreover, Mr. Offerman’s comments regarding potential effects on future residents significantly overestimates the amount of daily formaldehyde exposure that might occur from the proposed project.

Moreover, the conclusions are based on the following inaccurate exposure assumptions: (1) that the proposed project will not comply with applicable laws and regulations such the California Composite Wood Products Regulation (California CWP Regulation) or United States Environmental Protection Agency (EPA) Toxic Substances Control Act Title IV Regulation; (2) that the formaldehyde daily emissions from construction materials would be constant over 45 years; (3) that residents would have continuous exposure and would inhale 20 cubic meters of air per day and live in the proposed project for an average 70-year lifetime and occupy their units 24 hours per day 52 weeks per year; and (4) that the employees would work at the project site for eight hours per day, five days per week, 50 weeks per year for 45 years (starting at 20 years and retiring at age 65).

It is unreasonable to assume that applicable laws and regulations pertaining to building materials would not be followed. Formaldehyde in wood products is regulated by the California Code of Regulations, Title 17, Sections 93120 through 93120.12.1. The purpose of the Airborne Toxic Control Measure is to reduce formaldehyde emissions from composite wood products, and finished goods that contain composite wood products, that are sold, offered for sale, supplied, used, or manufactured for sale in California. All manufacturers of hardwood plywood, particleboard, and medium density fiberboard products must comply with the emission requirements of California Code of Regulations (CCR) Section 93120.2(a) as tested in accordance with ASTM E 1333. Thus, all wood products and finished goods used during construction of buildings in the State of California would be compliant with the emission standards as promulgated in the CCRs. The assumptions for both residents and employees are unreasonable, highly speculative and are not supported by empirical evidence. Thus, the comment substantially overestimates the amount of formaldehyde emissions to which future residents and employees could be exposed, as well as potential health impacts.

Commenter has failed to provide any credible or peer-reviewed studies which assess long-term indoor concentrations and associated lifetime exposure to formaldehyde in new homes and commercial spaces 524
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or provide a fair argument that the existing rules and regulations on formaldehyde in building materials are ineffective. The lead agency is within its discretion to find that the existing rules and regulations are robust and adequate to ensure that issues related to formaldehyde from building materials will not be an issue for indoor air quality for the proposed project. Compliance with relevant regulatory standards provides a reasonable basis for determining that the project will not have a significant environmental impact. Tracy First v City of Tracy (2009) 177 CA4th 912.

The commenter has not presented substantial evidence that the presence of formaldehyde in composite wood products would result in a significant impact for this project. Furthermore, formaldehyde is subject to extensive regulations to address human health and environmental impacts, and the project and any procured building materials would be subject to these regulations to minimize formaldehyde emissions.

Formaldehyde use in composite wood products is regulated by both the EPA and the ARB through the Formaldehyde Emission Standard for Composite Wood Products and the Composite Wood Products Airborne Toxic Control Measure, respectively. These regulations limit the amount of formaldehyde emissions from hardwood, plywood, particleboard, and medium density fiberboard panels, and finished goods, such as furniture and cabinets fabricated with those materials. In addition, as required by law, the proposed project would comply with CALGreen mandatory measures for building materials to limit formaldehyde emissions (e.g., CALGreen Section 4.504.5, Composite Wood Products, City of Orange Ordinance Numbers 10-19 and 06-22). All materials purchased for the construction of the project would be required to comply with these limits, which would reduce any potential impacts from formaldehyde emissions.

Furthermore, the following laws and regulations help control and reduce formaldehyde emissions from building materials:

Toxic Substances Control Act
The Toxic Substances Control Act provides the EPA with the ability to require reporting, testing, and recordkeeping requirements and restriction for chemical substances and mixtures. Toxic Substances Control Act (TSCA) Title VI regulates formaldehyde emissions from composite wood products. In addition, significant new uses of formaldehyde are regulated pursuant to Section 5(a)(2) of TSCA, which are listed at 40 Code of Federal Regulations Part 721, Subpart E.

California Hazardous Waste Control Law
The Hazardous Waste Control Law is the primary hazardous waste regulation in the State of California, and implements Resource Construction and Recovery Act (RCRA) as a “cradle-to-grave” waste management system for handling hazardous wastes in a manner that protects human health and the environment. The law specifies that generators have the primary duty to determine whether their waste is hazardous and to ensure proper management. The Hazardous Waste Control Law also establishes criteria for the reuse and recycling of hazardous waste used or reused as raw materials. The law exceeds federal requirements by mandating source reduction planning, and a much broader requirement for 525
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permitting facilities that treat hazardous waste. It also regulates a number of types of waste and waste management activities that are not covered by federal law.

Clean Water Act
The Clean Water Act (CWA) (Title 33 § 1251 et seq. of the United States Code [33 USC 1251, et seq.]) is the major federal legislation governing water quality. The CWA established the basic structure for regulating discharges of pollutants into waters of the United States (not including groundwater). The objective of the CWA is “to restore and maintain the chemical, physical, and biological integrity of the nation’s waters.” The CWA establishes the basic structure for regulating the discharge of pollutants into waters of the United States. Section 311(b)(2)(A) regulates release of hazardous substances, including formaldehyde. Formaldehyde is included on the list of designated hazardous substances (40 Code of Federal Regulations [CFR] 116.4), and a table of reportable quantities of hazardous substances along with liability provisions, applicability, and notice can be found at 40 Code of Federal Regulations 117.

Clean Air Act
Congress established much of the basic structure of the Clean Air Act in 1970 and made major revisions in 1977 and 1990. The air quality standards provide benchmarks for determining whether air quality is healthy at specific locations and whether development activities will cause or contribute to a violation of the standards. The federal standards were set to protect public health, including that of sensitive individuals; thus, the EPA is tasked with updating the standards as more medical research is available regarding the health effects of the criteria pollutants. Primary federal standards are the levels of air quality necessary, with an adequate margin of safety, to protect the public health. Formaldehyde is designated as a hazardous air pollutant and regulated pursuant to national emissions standards of Section 112 of the Clean Air Act.

Comment DRURY-9
The commenter claims that the Draft IS/MND for the proposed project violates CEQA due to substantial evidence of potentially significant impacts on air quality, GHG, energy use, and hazardous materials, which the commenter claims the Draft IS/MND failed to mitigate adequately. The commenter states that the City of Orange Planning Commission should decline to adopt the Draft IS/MND and prepare an EIR for the proposed project.

Response to DRURY-9
The Draft IS/MND did provide substantial evidence that all potential impacts related to air quality, GHG, energy use, and hazardous materials were evaluated and disclosed. The commenter does not provide credible evidence that the proposed project would result in significant GHG, energy, air quality or hazardous materials impacts that would warrant additional environmental analysis or mitigation measures. The Draft IS/MND appropriately concluded that the proposed project would not result in any significant impacts when applying all existing laws, regulations, and requirements and identified mitigation measures. Further, the information provided by commenter does not identify any deficiencies or inadequacies in the Draft IS/MND’s analysis based on facts relevant to the proposed project that 526
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would warrant revisions or recirculation of the Draft IS/MND. Thus, the Draft IS/MND satisfies the environmental review requirements pursuant to CEQA, the State CEQA Guidelines, and the City’s policies for implementing CEQA.

See Responses to DRURY-2 through DRURY-8.

Comment DRURY-10
This commenter states that Baseline Environmental Consulting identified flaws in the analysis related to GHG, energy, air quality, and hazardous materials.

Response to DRURY-10
The commenter summarizes their view that the Draft IS/MND did not adequately analyze the proposed project’s impacts to GHG emissions, energy, air quality, and hazardous materials but does not provide specific examples of the alleged inconsistencies. Please refer to Responses to DRURY-2 through DRURY-9 for additional information about the Draft IS/MND’s air quality, GHG, energy, and hazardous materials analysis.

Comment DRURY-11
This commenter claims that the proposed project’s GHG emissions, which is considered less than significant in the Draft IS/MND, are based on an invalid threshold. The SCAQMD proposed a GHG significance threshold of 3,000 MT CO2e. The commenter claims this threshold is not valid for the proposed project because they believe it has not been adopted by any state or regional agencies, is not supported by substantial evidence, and does not meet the State's long-term climate action goals.

Response to DRURY-11
See Response to DRURY-5.

Comment DRURY-12
The commenter claims that the GHG emissions significance threshold of 3,000 MT CO2e per year was not adopted by any state or regional agencies. The commenter then describes how the City issued a memorandum recommending the use of the 3,000 MT CO2e per year threshold for residential/commercial projects, but they believe this threshold is not supported by substantial evidence.

Response to DRURY-12
As the commenter describes, the Draft IS/MND analyzed the proposed project’s GHG emissions against the City of Orange’s Guidance for Greenhouse Gas Emissions Analysis memorandum11, which is the most 11 City of Orange. 2020. Guidance for Greenhouse Gas Emissions Analysis. March 24. Website:
https://cityoforange.prod.govaccess.org/home/showpublisheddocument/44/637707607308500000. Accessed March 13, 2023. 527
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applicable threshold available. The commenter is incorrect that the SCAQMD 3,000 MT CO2e threshold is not based on substantial evidence, as described in Response to DRURY-5. Furthermore, the commenter does not present a more appropriate threshold.

Comment DRURY-13
This commenter states that the GHG emissions threshold varies on approach, the 90 percent market capture approach and the gap-based approach. The Working Group recommends a GHG emissions threshold of 3,000 MT CO2e per year for GHG emissions is based on a 90 percent market capture approach. The commenter states that other agencies have adopted different GHG thresholds, including the California Air Pollution Control Offices Association (900 MT CO2e), the Sacramento Metropolitan Air Quality Management District (1,100 MT CO2e), the Bay Area Air Quality Management District (1,100 MT CO2e), the San Luis Obispo County Air Pollution Control District (1,150 MT CO2e), and the County of San Diego (2,500 MT CO2e).

Response to DRURY-13
As described in Response to DRURY-5, the Draft IS/MND used the most appropriate and applicable threshold recommended by the City of Orange and the SCAQMD.

Comment DRURY-14
This commenter claims the SCAQMD did not adopt the recommended threshold of 3,000 MT CO2e due to lack of consensus among the Working Group on the scientific approach and numerical values, as well as concerns that an efficiency-based threshold or separate sector thresholds may be more appropriate. The commenter suggests that the approach used in the Draft IS/MND is not supported by substantial evidence and is now outdated because it does not account for current projections in long-term market growth.

Response to DRURY-14
See Response to DRURY-5.

Comment DRURY-15
This commenter asserts that the Draft IS/MND’s analysis of carbon neutrality is inadequate. The commenter believes that the Draft IS/MND's analysis of the project's GHG emissions based on the numeric threshold of 3,000 MT CO2e is inadequate because it fails to demonstrate how the project would meet the State’s long-term climate action goal of carbon neutrality by 2045. The commenter states the analysis should focus on incorporating design elements or performance standards that support carbon neutrality.

Response to DRURY-15
See Response to DRURY-5 regarding the adequacy of the GHG emissions analysis provided in the Draft IS/MND.
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Comment DRURY-16
This commenter asserts that the Draft IS/MND failed to evaluate consistency with ARB's current 2022 Scoping Plan. The commenter claims the Draft IS/MND conflicts with the GHG reduction strategies of the 2022 Scoping Plan, potentially having a significant impact on GHG emissions.

Response to DRURY-16
The commenter’s statement that the Draft IS/MND should evaluate the project’s impacts against the newly released 2022 Scoping Plan is incorrect because the Public Draft IS/MND is dated November 14, 2022, and the public review period started November 23, 2022, both of which is prior to the formal adoption of the 2022 Scoping Plan on December 15, 2022. Therefore, it would have been impossible for the Draft IS/MND to consider measures in the 2022 Scoping Plan as they were not publicly available.

Comment DRURY-17
This commenter asserts that the Draft IS/MND’s analysis of energy impacts is inadequate. The Draft IS/MND provides estimates of the project's construction and operational energy consumption and concludes that the project's energy impacts would be less than significant, based on compliance with Title 24 and implementation of mitigation measures. The commenter asserts that compliance with Title 24 does not adequately address potential energy impacts during project construction and operation.

Response to DRURY-17
Please refer to the Response to DRURY-6. The Draft IS/MND describes how the proposed project would be located in an urban area with existing transit, such as the OCTA bus stops along Garden Grove Boulevard and The City Drive South, which would reduce the use of passenger vehicles. As described in the Draft IS/MND Project Description, the proposed project would include four EV charging spaces and bicycle lockers for resident use, which would allow for the use of ZEVs and alternative transportation methods that would not generate energy demand and reduce per capita energy use and reliance on fossil fuels. Moreover, the Draft IS/MND disclosed all of the renewable power options available to the proposed project including how SCE, the applicable utility provider, would meet California’s RPS of 60 percent by 2030 and carbon-free electricity by 2045. As described in the Draft IS/MND, impacts related to energy consumption would not be wasteful or inefficient and no further mitigation would be required.

Therefore, the proposed project would allow for increasing reliance on renewable energy sources and would not result in the need for mitigation or renewable energy resources.

Comment DRURY-18
The commenter asserts that the Draft IS/MND’s analysis of air quality impacts are inadequate.

Specifically, the commenter claims that there are issues with the Draft IS/MND’s DPM emissions analysis. Furthermore, the commenter states that an HRA should be prepared for project construction and that the Draft IS/MND incorrectly used the SCAQMD’s LSTs. 529
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Response to DRURY-18
See Response to DRURY-4. The air quality analysis provided in the Draft IS/MND adequately analyzes potential health risk impacts to nearby sensitive receptors due to construction activity and a separate HRA would not be warranted. The impacts associated with DPM have not been “underestimated” because potential impacts from construction were adequately addressed in the Draft IS/MND and the nature of the proposed project’s operations would not warrant or trigger the need for an operational HRA. As described in Response to DRURY-4, residential and commercial mixed-use developments are not typically associated with substantial sources of TAC emissions, and the project would not generate TAC emissions that expose sensitive receptors to substantial health risks during project construction or operations. Consistent with the OEHHA guidelines, the nominal quantity of TAC emissions from the proposed land uses do not trigger the need for an HRA for operational activities.

Comment DRURY-19
This commenter asserts that the Draft IS/MND’s analysis of hazardous material impacts are inadequate. Specifically, the commenter raises concerns that the Indoor Air Quality Assessment was not reviewed and approved by the DTSC, and the Draft IS/MND did not properly disclose the additional investigation activities performed on-site. The commenter recommends that the findings from the most recent environmental investigations be disclosed, and a mitigation measure be prepared to require the applicant to submit a copy of the DTSC letter of No Further Action prior to the issuance of building permits.

Response to DRURY-19
Assessment of the historical Cecilia’s Cleaners located on the proposed project property has been conducted under a Voluntary Cleanup Agreement with the DTSC since 2017. As stated in the Draft IS/MND, Indoor Air Quality Investigation Report indicated that a DTSC-approved workplan was prepared for the project site dated March 12, 2018, which concluded that PCE was not present in indoor air at concentrations above its residential or commercial/industrial DTSC-Recommended screening level (SL).

On December 21, 2022, SCS Engineers submitted to DTSC an Additional Investigation and Human Health Risk Assessment Report. This report summarizes the findings of soil, soil vapor, and groundwater sampling at the proposed project property. The investigation activities have addressed all DTSC requests for site characterization sampling. Based on communication with DTSC’s Project Manager, Mr. Nicholas Ta, and DTSC’s technical support staff assigned to the case, requests for further site investigation are not warranted and have not been requested.

The Additional Investigation and Human Health Risk Assessment Report documents that chemical concentrations in soil do not represent a risk to groundwater or human health. The report contains the results of a Screening Level Human Health Risk Assessment (SL-HHRA), which evaluated potential soil vapor exposure pathways to construction (trench) workers during the planned redevelopment project.

Based on the results of the SL-HHRA, no significant health risks to construction workers were identified.

The SL-HHRA also evaluated vapor intrusion risk scenarios for the proposed project. The proposed project calls for the construction of three levels of underground parking garage, which will entirely 530
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underlie the residential structures. The parking garages, which will be constructed in accordance with building code ventilation requirements, disrupt the pathway into the overlying structures.

Based on multiple lines of evidence, including soil sampling, evaluation of volatile organic compounds (VOCs) in soil vapor both vertically and laterally, groundwater sampling, and indoor air quality sampling at the existing building, SCS concluded that there was no significant risk to human health, risk to groundwater, or risk of vapor intrusion. According to the latest communication from DTSC, the project proponent expects that a conditional “No Further Action” (NFA) letter will be issued in the near future, and well before any building permits are to be issued. The only expected condition to the NFA is expected to be that the redevelopment project be constructed with the proposed multi-level underground parking garage. If the nature of the project were to change such that the project were not to include said parking garage, DTSC will require notification and additional consideration under the revised development plan would be required. Since a NFA findings is expected in the near future and the matter will be open for public comment prior to being finalized, and the finding of NFA under the sitespecific redevelopment plan does not call for mitigation measures outside of already-necessary building code measures with which the project must comply, the contention that a full EIR must be prepared to further evaluate and/or mitigate impacts related to hazardous materials should be rejected.

The commenter does not provide substantial evidence that future occupants would be exposed to substantial concentrations of hazardous chemicals from vapor intrusion. The site-specific redevelopment plan does not call for mitigation measures outside of already-necessary building code standards with which the project must comply, the contention that a full EIR must be prepared to further evaluate and/or mitigate impacts related to hazardous materials should be rejected. Compliance with applicable regulations would ensure indoor air quality impacts are less than significant. No additional mitigation measures are needed.

Comment DRURY-20
The commenter concludes that there is a fair argument that the project may have a significant effect on the environment related to GHG emissions, energy, air quality, and hazardous materials. The commenter concludes that the City of Orange prepare an EIR to address environmental concerns.

Response to DRURY-20
The Draft IS/MND determined that impacts to air quality, energy, GHG emissions, and hazardous materials would be less than significant with mitigation incorporated based on the technical analyses conducted for the project. Since the project would result in either no impacts or less than significant impacts to air quality, energy, GHG emissions, and hazardous materials, the level of impacts does not justify the preparation of an EIR. Comments relating to project approval will be forwarded to the City Council for consideration.
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Comment DRURY-21
The commenter highlights the importance of indoor air quality in buildings including adequate ventilation and reduction of indoor sources of contaminants.

Response to DRURY-21
The Draft IS/MND accurately determined that the project would not generate significant indoor air quality impacts with implementation of State and SCAQMD rules and regulations.

Comment DRURY-22
The commenter expresses concern for indoor formaldehyde concentration impacts. Specifically, the commenter states that the California New Home Study found that formaldehyde was the indoor air contaminant with the highest cancer risk in new homes, and all homes exceeded the daily intake level that would result in one excess case of cancer in an exposed population of 100,000. The commenter states that formaldehyde is primarily emitted from composite wood products used in building construction. The commenter states that while a follow-up study found that homes built with ARB Phase 2 Formaldehyde Airborne Toxic Control Measures (ATCM) materials had lower indoor formaldehyde concentrations, the median lifetime cancer risk is still 120 per million, which the commenter claims is more than 12 times the cancer risk threshold established by OEHHA.

Response to DRURY-22
See Response to DRURY-8.

Comment DRURY-23
The commenter expresses concern that residents will potentially have continuous exposure to formaldehyde released by the building materials and furnishing commonly found in residential construction which could result in significant cancer risks.

Response to DRURY-23
Please see Response to DRURY-8.

The comments provided in Exhibit B did not utilize standard modeling procedures provided by the ARB and OEHHA to calculate cancer risk, and did not account for the fact that all building products will need to meet both California Phase 2 formaldehyde compliant standards and the EPA TSCA Title VI formaldehyde regulations. In addition, the Exhibit B comments did not account for the fact that the proposed project is required, per Section 150.0(m)12.C of the 2022 Building Energy Efficiency Standards (also known as Title 24), to install in each residential unit a positive static pressure forced air heating, ventilation, and air conditioning (HVAC) system that is equipped with high efficiency Minimum Efficiency Reporting Values (MERV) 13 air filters, which will reduce the formaldehyde concentrations by an additional 15 to 52 percent over traditional air filters. Based on these modeling inputs reflecting State 532
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and federal requirements, the City appropriately determined that there would be a less than significant impact related to interior formaldehyde concentrations. The commenter’s claim is not supported by substantial evidence and does not constitute a fair argument that the proposed project would have an airborne cancer risk impacts caused by formaldehyde.

Comment DRURY-24
The commenter expresses concern for employees who work in commercial spaces may be exposed to significant levels of formaldehyde, which could result in a higher risk of cancer. The commenter suggests that an EIR should be conducted, and feasible mitigation measures should be implemented to reduce this risk.

Response to DRURY-24
Please see Response to DRURY-8 and DRURY-23.

Comment DRURY-25
The commenter notes that the indoor formaldehyde exposures will increase the pre-existing cancer risk resulting from outdoor formaldehyde exposures, as well as exacerbate the existing cancer risk at the project site due to high levels of vehicle traffic. The commenter claims that the use of ARB Phase 2 Formaldehyde ATCM materials does not ensure acceptable cancer risks, and only composite wood products made with NAF resins can ensure that the OEHHA cancer risk of 10 per million is met.

Response to DRURY-25
See Response to DRURY-8 and DRURY-23.

Comment DRURY-26
The commenter suggests a design analysis be conducted before construction to determine whether the formaldehyde emissions of specific building materials/furnishings selected exceed cancer and non-cancer guidelines. This would allow alternative lower-emitting materials/furnishings to be selected or higher minimum outdoor air ventilation rates to be increased as mitigation measures to achieve acceptable indoor concentrations and incorporated into the project prior to the completion of the City’s CEQA review and project approval.

Response to DRURY-26
See Response to DRURY-8 and DRURY-23. Based on the project’s analysis of indoor air quality impacts, additional assessment is not warranted.

Comment DRURY-27
The commenter suggests that an assessment of formaldehyde emissions should be used in the environmental review to assess indoor formaldehyde concentrations from proposed building 533
23 Responses to
Comments
materials/furnishings. This assessment should be used in the environmental review process to determine whether the emissions will exceed cancer and non-cancer guidelines, and if necessary, make changes to the material/furnishing selection or design minimum outdoor air ventilation rates to prevent guideline exceedance. This assessment should be conducted before finalizing material/furnishing selection, purchase, and installation.

Response to DRURY-27
See Responses to DRURY-8 and DRURY-23.

Comment DRURY-28
The commenter suggests dividing the building into Indoor Air Quality Zones (IAQ Zones) for effective assessment of formaldehyde emission rates from construction materials/furnishings.

The commenter proposes that each ventilation system with recirculating air should be considered as a single zone, and each room or group of rooms with 100 percent outdoor air as a separate zone. IAQ Zones with the same construction materials and design outdoor air ventilation rates can be assessed for formaldehyde emission rates for a single IAQ Zone of that type.

Response to DRURY-28
As detailed in Responses to DRURY-8 and DRURY-23, the comments provided in Exhibit B are not supported by substantial evidence and do not constitute a fair argument that the proposed project would have an airborne cancer risk impact caused by formaldehyde. Furthermore, the suggested assessment methods are not supported by standard modeling procedures established by the ARB or SCAQMD’s thresholds. Therefore, the suggested assessments are not warranted.

Comment DRURY-29
The commenter recommends determining the material and furnishing loadings for each IAQ Zone by conducting an inventory of potential indoor formaldehyde sources, including flooring, ceiling tiles, furnishings, finishes, insulation, sealants, adhesives, and any products constructed with composite wood products containing urea-formaldehyde resins.

Response to DRURY-29
See Response to DRURY-28.

Comment DRURY-30
The commenter suggests calculating the formaldehyde emission rate for each building material and furnishing by multiplying the area-specific or unit-specific formaldehyde emission rate with the area of material or the number of units in the IAQ Zone, respectively. 534
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Response to DRURY-30
See Response to DRURY-28.

Comment DRURY-31
The commenter notes that most manufacturers of building materials and furnishings in the United States conduct chemical emission rate tests using recognized testing methods and certifications, which provide data that the formaldehyde emission rates do not exceed the maximum allowed for the certification. The commenter claims that these certifications do not provide the actual area-specific formaldehyde emission rate but can be used as an initial estimate.

Response to DRURY-31
See Response to DRURY-8, DRURY-23, and DRURY-28.

Comment DRURY-32
The commenter claims that if the actual area-specific emission rates of a building material or furnishing is needed, the data can be acquired by requesting the complete chemical emission rate test report from the manufacturer. The commenter claims that the complete California Department of Public Health (CDPH) emission test report provides actual emission rates for a range of chemicals, including formaldehyde, listed in various safety guidelines.

Response to DRURY-32
See Response to DRURY-8, DRURY-23, and DRURY-28. The analysis provided in the Draft IS/MND was based on modeling inputs reflecting State and federal requirements. Therefore, no further analysis is required.

Comment DRURY-33
The commenter suggests an alternative to the complete CDPH emission test is to submit samples of building materials or furnishings to chemical emission rate testing laboratories.

Response to DRURY-33
See Response to DRURY-8, DRURY-23, and DRURY-28. As described previously, it has been appropriately determined that there would be a less than significant impact related to interior formaldehyde concentrations. Formaldehyde is regulated by both the EPA and the ARB and is required to comply with the applicable laws and regulations outlined in Response to DRURY-8. Therefore, no further analysis is required.
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Comment DRURY-34
The commenter suggests that for each IAQ Zone, the total formaldehyde emission rate should be calculated from the individual formaldehyde emission rates from each building materials or furnishings as determined in Response to DRURY-30.

Response to DRURY-34
See Response to DRURY-33. No further analysis of formaldehyde warranted.

Comment DRURY-35
The commenter suggests that for each IAQ Zone, the indoor formaldehyde concentration should be calculated from the total formaldehyde emission rates as determined in Response to DRURY-34.

Response to DRURY-35
See Response to DRURY-33. No further analysis of formaldehyde is warranted.

Comment DRURY-36
The commentor suggests that for each IAQ Zone, the indoor exposure cancer and non-cancer health risks should be calculated from the indoor formaldehyde concentrations as determined in Response to DRURY-35.

Response to DRURY-36
See Response to DRURY-33. No further analysis of formaldehyde is warranted.

Comment DRURY-37
The commenter suggests that for each IAQ Zone, source and/or ventilation mitigation should be provided for any formaldehyde exposure risk, as determined in Response to DRURY-36, that exceeds the CEQA cancer risk of 10 per million or the CEQA non-cancer Hazard Quotient of 1.0.

Response to DRURY-37
See Response to DRURY-33. No further analysis of formaldehyde is warranted.

Comment DRURY-38
The commenter notes the most cost-effective way to reduce formaldehyde emissions is by using fewer materials/furnishings or using those with lower emissions.

Response to DRURY-38
As detailed in Response to DRURY-23, it has been appropriately determined that there would be a less than significant impact related to interior formaldehyde concentrations. Therefore, additional action is not required.
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Comments
Comment DRURY-39
The commenter suggests during the design stage, builders should select composite wood materials based on the formaldehyde emission rates to ensure that the materials selected achieve acceptable cancer risks from material off-gassing of formaldehyde.

Response to DRURY-39
As detailed in Response to DRURY-8 and DRURY-23, formaldehyde is regulated by both the EPA and the ARB and is required to comply with the applicable laws and regulations outlined in Response to DRURY8. No further action is required.

Comment DRURY-40
The commenter states the California New Home Study (CNHS) found that outdoor air ventilation rates in homes were very low. The median 24-hour measurement was 0.26 air changes per hour (ach), with 67 percent of homes having outdoor air exchange rates below the minimum California Building Standards Code requirement of 0.35 ach, resulting in higher indoor air contaminant concentrations.

Response to DRURY-40
This comment does not raise any new concerns related to the proposed project’s air quality impacts or the analysis conducted as part of the Draft IS/MND. Therefore, this comment does not warrant any additional analysis.

Comment DRURY-41
The commenter states the project site is located near high traffic roads which make it a sound impacted site with noise levels ranging from 66.6 A-weighted decibel (dBA) to 68.3 dBA Community Noise Equivalent Level (CNEL). Because of the high noise levels, a mechanical supply of outdoor air ventilation will be required to maintain a habitable interior environment with closed windows and doors, enabling occupants to control exterior noise within the building interiors.

Response to DRURY-41
To analyze the project’s specific noise and groundborne vibration impacts, noise calculations were prepared for the proposed project and are included in Appendix H of the Draft IS/MND. The analysis determined that the project’s construction noise, construction traffic noise, operation traffic noise, and groundborne vibration impacts would be less than significant with mitigation incorporated and would not exceed any applicable thresholds. Therefore, the proposed project would not result in a significant noise impact.
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Comment DRURY-42
The commenter suggests that the nearby motor vehicle traffic associated with the project will impact the outdoor concentrations of PM2.5, which exceeds the California and National PM2.5 annual and 24-hour standards. The commenter recommends the installation of high efficiency air filters in all mechanically supplied outdoor air ventilation systems.

Response to DRURY-42
Potential impacts to future residents of the project due to existing air pollution is not a project impact for purposes of CEQA. (California Building Industry Association v. Bay Area Air Quality Management District (2015) 62 C4th 369, 377.

Further, the Air Quality and Greenhouse Gas Supporting Information provided in Appendix A of the Draft IS/MND provides an estimate of the PM2.5 concentration at the project site from all cumulative sources.

Pursuant to the 2022 Building Energy Efficiency Standards, the proposed project is required to install a positive static pressure forced air HVAC systems that are equipped with high efficiency MERV 13 air filters with an outside air intake that will be installed in each residential unit. As such, the commenter’s recommendation for the type of air filtration system to be installed in the proposed project is already required by State regulations.

Comment DRURY-43
The commenter recommends the use of ARB-approved NAF resins for all interior finish systems to mitigate indoor formaldehyde concentrations to ensure that the OEHHA cancer risk of 10 per million is met.

Response to DRURY-43
As detailed in the responses above, the commenter’s assertion that a significant impact would occur from formaldehyde is based upon flawed assumptions and calculations. Impacts related to formaldehyde emissions would be less than significant. As such, no reduction or mitigation measures for formaldehyde are required.

Comment DRURY-44
This commenter suggests an alternative to Response to DRURY-41 by conducting a PreConstruction Building Material/Furnishing Chemical Emissions Assessment to ensure that formaldehyde emissions from building materials and furnishings do not exceed CEQA cancer and non-cancer health risks. The commenter recommends selecting composite wood materials based on formaldehyde emission rates and conducting the assessment at the design stage to achieve acceptable cancer risks from material off-gassing of formaldehyde. 538
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Response to DRURY-44
As detailed in the responses above, the commenter’s assertion that a significant impact would occur from formaldehyde is based upon flawed assumptions and calculations. Impacts related to formaldehyde emissions would be less than significant. As such, no reduction or mitigation measures for formaldehyde are required.

Comment DRURY-45
The comment recommends providing each habitable room with a continuous mechanical supply of outdoor air that meets the California 2016 Building Energy Efficiency Standards, conducting testing and balancing to ensure the required amount of outdoor air is entering each room, and providing a manual for occupants or maintenance personnel that describes the purpose of the mechanical outdoor air system and its maintenance requirements.

Response to DRURY-45
Pursuant to the 2022 Building Energy Efficiency Standards, the proposed project is required to install a positive static pressure forced air HVAC systems that are equipped with high efficiency MERV 13 air filters with an outside air intake that will be installed in each residential unit. As such, the commenter’s recommendation for the type of air filtration system that should be installed in the proposed project is already required to be installed by State regulations.

Comment DRURY-46
The commenter suggests installing air filtration with a MERV 13 or higher to remove outdoor PM2.5 particles and reduce indoor concentrations to meet California and National standards. The air filters should be easily accessible and instructions on how to replace them should be included in the mechanical outdoor air ventilation system manual.

Response to DRURY-46
Pursuant to the 2022 Building Energy Efficiency Standards, the proposed project is required to install a positive static pressure forced air HVAC systems that are equipped with high efficiency MERV 13 air filters with an outside air intake that will be installed in each residential unit. As such, the commenter’s recommendation for the type of air filtration system that should be installed in the proposed project is already required to be installed by State regulations.
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Appendix A:

Comment Letter
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February 22, 2023
Via E-mail
Re: Planning Commission, Regular Session of February 23, 2023, Agenda Item No. 6.2; 840 The City Drive Apartments; Conditional Use Permit No. 3138-21; Major Site Plan Review No. 1040-21; Design Review No. 5030-21; Administrative Adjustment No. 0051-21; Mitigated Negative Declaration No. 1875-21 (City File No. 22-0718) Dear Honorable Members of the Planning Commission:

I am writing on behalf of Supporters Alliance for Environmental Responsibility (“SAFER”) regarding the Initial Study and Mitigated Negative Declaration (“IS/MND” or “MND”) prepared for the 840 The City Drive Apartments Project (“Project”), for Applicant SLR Orange Development, LLC (hereinafter the “Applicant”), including all actions related or referring to the demolition of an existing retail building and proposed construction of a new 225- unit mixed-use apartment development, open parking structure for the adjacent office complex use, related site improvements, and a reduction of 48 parking spaces and 670 square feet of open space, located at 840 The City Drive South.

SAFER is concerned that the MND prepared for the Project is legally inadequate.

SAFER’s review of the Project has been assisted by air quality experts Patrick Sutton, PE and Yilin Tian, Ph.D. of Baseline Environmental Consulting (“Baseline”), and certified industrial hygienist Francis “Bud” Offermann, PE, CIH. The expert comments of Baseline and Mr.

Offermann are attached as Exhibit A and Exhibit B, respectively.

After reviewing the MND, it is evident that it is inadequate and fails as an informational document. Also, there is a “fair argument” that the Project may have unmitigated adverse David Vazquez, Chair
Ernest Glasgow, Vice Chair
Davie Simpson, Commissioner
Rick Martinez, Commissioner
Jonathan Trapesonian, Commissioner
Planning Commission
City of Orange
300 E. Chapman Avenue
Orange, CA 92866
[email protected]
Monique Schwartz, Associate Planner
Community Development Department
City of Orange
300 E. Chapman Avenue
Orange, CA 92866
[email protected]
Pamela Coleman, City Clerk
City of Orange
300 E. Chapman Avenue
Orange, CA 92866
[email protected]
DRURY

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Orange City CouncilApril 11, 2023

Orange City Council
April 11, 2023