Final Initial Study/Mitigated Negative Declaration
840 The City Drive Apartments
City of Orange, Orange County, California
Prepared for:
City of Orange Planning Division
300 East Chapman Avenue
City of Orange, California 92866
714.744.7220
Contact: Monique Schwartz, Associate Planner
Prepared by:
FirstCarbon Solutions
250 Commerce, Suite 250
Irvine, CA 92602
714.508.4100
Contact: Mary Bean, Project Director
Cecilia So, Senior Project Manager
Date: January 26, 2023
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Table of Contents
Section 1 Introduction......................................................................................................... 1-1 Section 2 Responses to Written Comments ....................................................................... 2-1 List of Authors ........................................................................................................... 2-1 Responses to Comments ............................................................................................ 2-1 Introduction ........................................................................................................ 2-1 Comment Letters and Responses........................................................................ 2-1 Section 3 Errata.................................................................................................................... 3-1 Changes in Response to Specific Comments ............................................................. 3-1
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SECTION 1 INTRODUCTION
The City of Orange Planning Division has elected to prepare the following responses to environmental comments received on the 840 The City Drive Apartments Project Draft Initial Study/Mitigated Negative Declaration (Draft IS/MND). The Responses to Comments and Errata, which are included in this document, together with the Draft IS/MND, Draft IS/MND appendices, and the Mitigation Monitoring and Reporting Program (MMRP), comprise the Final IS/MND for use by the City of Orange Community Development Department Planning in its review and consideration of the 840 The City Drive Apartments Project. All public comments received during the public review period regarding the Draft IS/MND are included for consideration by the City of Orange, Orange County.
This document is organized into three sections:
• Section 1—Introduction.
• Section 2—Responses to Written Comments: Provides a list of the agencies, organizations, and individuals who commented on the Draft IS/MND . Copies of all of the letters received regarding the Draft IS/MND and responses thereto are included in this section.
• Section 3—Errata: Includes an addendum listing refinements and clarifications on the Draft IS/MND, which have been incorporated.
The Final IS/MND includes the following contents:
• Draft IS/MND (provided under separate cover)
• Draft IS/MND appendices (provided under separate cover) • Responses to Written Comments and Errata (Sections 2 and 3 of this document) • Mitigation Monitoring and Reporting Program (provided under separate cover)
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SECTION 2 RESPONSES TO WRITTEN COMMENTS
List of Authors
A list of public agencies, organizations, and individuals that provided comments on the Draft Initial Study/Mitigated Negative Declaration ( Draft IS/MND ) is presented below . Each comment has been assigned a code . Individual comments within each communication have been numbered so comments can be crossed-referenced with responses. Following this list, the text of the communication is reprinted and followed by the corresponding response.
Author Author Code
State Agencies
California Department of Transportation ................................................................ CALTRANS
Local Agencies
Orange County Health Care Agency Environmental Health Division ..........................OCHCA Orange County Transportation Authority ......................................................................... OCTA
Responses to Comments
Introduction
Although a lead agency is not required to provide written responses to comments on proposed Negative Declarations (NDs) or Mitigated Negative Declarations (MNDs) under the California Environmental Quality Act (CEQA), the City of Orange Community Development Department Planning Division has evaluated the comments received on the 840 The City Drive Apartments (proposed project) Draft IS/MND and has elected to provide responses to the following public comments. None of the comments received results in the need to recirculate the Draft IS/MND or to prepare an Environmental Impact Report (EIR).
Comment Letters and Responses
The comment letters reproduced in the following pages follow the same organization as used in the List of Authors.
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“Provide a safe and reliable transportation network that serves all people and respects the environment” STATE OF CALIFORNIA- - - - - - - CALIFORNIA STATE TRANSPORTATION AGENCY Gavin Newsom, Governor
DEPARTMENT OF TRANSPORTATION
DISTRICT 12
1750 EAST 4TH STREET, SUITE 100
SANTA ANA, CA 92705
PHONE (657) 328-6000
FAX (657) 328-6522
TTY 711
www.dot.ca.gov/caltrans-near-me/district12
Making Conservation
a California Way of Life.
Dec. 14, 2022
Ms. Monique Schwartz File: LDR/CEQA
Associate Planner 12-ORA-2022-02113
City of Orange SR 22 PM R9.729
300 East Chapman Ave. I-5 PM 34.267
Orange, CA. 92866 SR 57 PM 11.028
Dear Ms. Schwartz,
Thank you for including the California Department of Transportation (Caltrans) in the review of the Mitigated Negative Declaration (MND) for the 840 The City Drive Project. The Project proposes to demolish an existing 12,923 square foot multi-tenant retail building to construct a new 6-story, 225-unit vertical mixed-use apartment development with 9,000 square feet of ground floor retail/restaurant area, three-level subterranean parking beneath the footprint of the building, residential amenities, landscaping, and related site improvements. The project also includes the construction of a new two-story open-parking structure for use by the adjacent office complex to replace surface parking displaced by the project.
The Project is on a 5.86-acre site, located on the southeastern corner of a larger existing 15.10-acre multibuilding office complex at the northwest corner of Garden Grove Blvd. and The City Drive South. Regional access is provided by State Route 57 (SR-57) and SR 22 to the north, and Interstate 5 (I-5) to the east.
State Routes 57 and 22, as well as Interstate 5, are owned and operated by Caltrans. Therefore, Caltrans is a responsible agency on this project, and has the following comments:
Transportation and System Planning
1. New residential and commercial infill development offers an opportunity to encourage multimodal transportation options. Caltrans encourages the
CALTRANS
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City of Orange
Dec. 14, 2022
“Provide a safe and reliable transportation network that serves all people and respects the environment” design of Complete Streets that include high-quality pedestrian, bicycle, and transit facilities that are safe and comfortable for users of all ages and abilities. This may include safety measures such as physically separated sidewalks and bike lanes; pedestrian-oriented LED lighting; high-visibility continental crosswalk striping; raised crosswalks; refuge islands; wayfinding signage; and safe connections to existing and proposed bicycle, pedestrian, and transit facilities. Complete Streets improvements also promote regional connectivity, improve air quality, reduce congestion, promote improved first-/last-mile connections, and increase safety for all modes of transportation.
2. Caltrans supports the inclusion of bicycle parking/storage for residents, employees, visitors, and customers. With the growing popularity of electric bikes and cargo/utility bikes (which tend to be bigger and heavier), Caltrans recommends that bicycle storage facilities be designed to accommodate a range of bicycle styles, sizes, and weights. For additional guidance on providing secure short- and long-term bike parking for a range of bicycle styles & sizes, see the attached “Essentials of Bike Parking” guidance created by the Association of Pedestrian and Bicycle Professionals (link to online PDF: https://www.apbp.org/Publications
3. Please encourage the use of transit among future residents, visitors, and workers of the development. Increasing multimodal transportation will lead to a reduction to congestion, Vehicle Miles Traveled, and improve air quality.
Freight Operations and Planning
4. Please ensure that truck parking, ingress and egress, and staging will not interfere with vehicle parking, pedestrian paths, or bicycle lanes/bicycle parking.
CALTRANS
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5 City of Orange
Dec. 14, 2022
“Provide a safe and reliable transportation network that serves all people and respects the environment”
5. Establish freight pick up & drop off times that do not coincide with peak commute hours to reduce passenger vehicle conflicts and congestion for freight. Consider designating on-street freight-only parking and delivery time windows so trucks will not resort to double parking, thus causing street traffic congestion.
6. For the residential development proposed, consider how many individual packages will be delivered daily to individual residences. Amazon lockers or an equivalent shared drop-off location can help reduce the amount of driving done by delivery trucks and can increase the efficiency of deliveries.
7. Work with local partners and community representatives to mitigate any truck traffic routing onto residential streets or conflicting with other road users, including and especially bicyclists and pedestrians.
Traffic Operations
8. Please provide the storage lengths of the off-ramp and the storage lengths of the of right-turn/ left-turn lane(s) to the on-ramp at the intersections of The City Drive and the Eastbound SR 22 Ramps to determine if they have the storage lengths to accommodate the additional demands.
9. Also provide the storage lengths of the off-ramp and the storage lengths of the of right-turn/ left-turn lane(s) to the on-ramp at the intersections of Metropolitan Drive and the Westbound SR 22 Ramps to determine if they have the storage lengths to accommodate the additional demands.
10. Submit copies of all traffic related documents for review. The data used in the Traffic Impact Analysis (TIA) should not be more than 2 years old and
CALTRANS
6 7
8 9
10 11
City of Orange
Dec. 14, 2022
“Provide a safe and reliable transportation network that serves all people and respects the environment” shall be based on the Southern California Association of Governments Regional Transportation Plan Model. Use the Highway Capacity Manual methodology for all traffic analyses.
Caltrans’ mission is to provide a safe, sustainable, equitable, integrated, and efficient transportation system to enhance California’s economy and livability.
Please continue to coordinate with Caltrans for any future developments that could potentially impact State transportation facilities. If you have any questions, please do not hesitate to contact Julie Lugaro at [email protected].
Sincere
ly,
Scott Shelley
Branch Chief, Regional-IGR-Transit Planning
Caltrans, District 12
CALTRANS
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12 2-7
State Agencies
California Department of Transportation (CALTRANS)
Response to CALTRANS-1
This comment consists of introductory statements and does not raise any environmental issues related to the proposed project.
This comment is noted. Additionally, no discretionary approvals are currently required from Caltrans. As such, Caltrans is not considered a Responsible Agency at this time.
Response to CALTRANS-2
The commenter expresses support for the design of Complete Streets and encourages the City to incorporate Complete Streets in project development.
The comment does not identify any specific environmental concerns related to the project. The comment is noted.
Response to CALTRANS-3
The commenter expresses support for bicycle parking and storage and provides a link to guidance on providing bicycle parking.
The comment does not identify any specific environmental concerns related to the project. The comment is noted.
Response to CALTRANS-4
The commenter expresses support for encouraging multimodal transportation.
The comment does not identify any specific environmental concerns related to the project. The comment is noted.
Response to CALTRANS-5
The commenter requests that truck activities do not interfere with parking, pedestrian paths, or bicycle lanes or bicycle parking.
The comment does not identify any specific environmental concerns related to the project. As discussed in the Draft IS/MND, the proposed project would not result in any adverse impacts to public transit, bicycle, or pedestrian facilities. The comment is noted.
Response to CALTRANS-6
The commenter requests that freight pickup and drop-off times, parking, and delivery windows do not create passenger vehicle conflicts or congestion.
The comment does not identify any specific environmental concerns related to the project. As discussed in the Draft IS/MND, the proposed project would not support truck and freight operations. Furthermore, the Draft IS/MND concluded that motorists entering and exiting the project site would be able to do so comfortably, safely, and without undue congestion with implementation of MM TRANS -1, which would require installation of a five -phase traffic signal with protected left- turn phasing in the northbound and southbound directions and permissive phasing in the eastbound and westbound directions. The comment is noted.
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Response to CALTRANS-7
The commenter requests Amazon lockers or equivalent shared drop- off locations to increase the efficiency of deliveries. Delivery efficiency is not within the scope of CEQA.
The comment does not identify any specific environmental concerns related to the project. The comment is noted.
Response to CALTRANS-8
The commenter requests working with local partners and community representatives to mitigate truck traffic routing onto residential streets or conflicting with other road users such as bicyclists and pedestrians.
As discussed in the Draft IS/MND, the proposed project is mixed-use in nature and would not support truck and freight operations . Furthermore, according to the Traffic Impact Analysis (TIA), roadway segments near the project site are forecast to continue to operate at an acceptable service level on a daily basis with the addition of project -generated traffic and would not result in any adverse impacts to public transit, bicycle, or pedestrian facilities. No further analysis is required.
Response to CALTRANS-9
Table 1 presents the results of the Year 2024 Peak-Hour Freeway Ramp Queueing Analysis for the intersection of The City Drive at State Route ( SR) 22 east bound (EB) Ramps (i.e., key study intersection No. 3). As shown in Table 1, adequate storage is provided for all on- ramp and off-ramp turn pockets at the intersection of The City Drive at SR -22 EB Ramps (i.e., key study intersection No. 3) in the Year 2024, except for the northbound left-turn lane. Although the storage for the northbound left-turn lane is exceeded without and with the proposed project during the AM and PM peak- hours, it should be noted that the proposed project would only add 33 feet during the AM peak- hour and 16 feet during the PM peak -hour to the already deficient northbound left-turn pocket. Since the excess queueing only occurs on the City street (i.e., The City Drive), the proposed project is not anticipated to negatively influence safety on the State Highway System (i.e., SR-22).
Response to CALTRANS-10
Table 1 also presents the results of the Year 2024 Peak-Hour Freeway Ramp Queueing Analysis for the intersection of SR -22 westbound (WB) Ramps at Metropolitan Drive (i.e. , key study intersection No. 1). As shown in Table 1, adequate storage is provided for all on-ramp and off- ramp turn pockets at the intersection of SR -22 WB Ramps at Metropolitan Drive (i.e., key study intersection No. 1) in the Year 2024. Therefore, the proposed project is not anticipated to negatively influence safety on the State Highway System.
Response to CALTRANS-11
The Scope of Work for the traffic study, including the exiting traffic count data collection, was developed in conjunction with City of Orange Traffic Engineering staff. As stated in the traffic study, existing daily, AM peak-hour, and PM peak-hour traffic volumes for the six key study intersections, two existing project driveways and four key roadway segments evaluated in the traffic study report were conducted by Transportation Studies Inc. in August 2019. Given that
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current traffic patterns w ere not typical due to the COVID -19 Coronavirus Pandemic, use of the August 2019 traffic count data was deemed appropriate for use by City of Orange Traffic Engineering staff, as these traffic volumes would provide a conservative analysis.
Response to CALTRANS-12
The commenter provides general concluding remarks and requests continued coordination.
This general comment does not identify specific potentially adverse environmental impacts, nor does it address significant environmental issues within the purvi ew of CEQA Guidelines.
The City will consider all comments received on the proposed project as part of their review and consideration of the proposed project as a whole. No further analysis is warranted.
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Table 1: Year 2024 Peak-Hour Freeway Ramp Queueing Analysis Key Ramp Intersection
Estimated
Storage
Provided
(feet)
Year 2024 Without Project Traffic
Conditions
Year 2024 With Project Traffic
Conditions
AM Peak-hour PM Peak-hour AM Peak-hour PM Peak-hour
Max.
Queue
(feet)
Adequate
Storage
(Yes / No)
Max
Queue
(feet)
Adequate
Storage
(Yes / No)
Max.
Queue
(feet)
Adequate
Storage
(Yes / No)
Max.
Queue
(feet)
Adequate
Storage
(Yes / No)
SR-22 WB Ramps at Metropolitan Drive
Northbound Left-Turn 845 195 Yes 201 Yes 207 Yes 199 Yes Northbound Shared Left-Turn/Through 100 194 Yes2 202 Yes2 206 Yes2 199 Yes2 Northbound Right-Turns 845 127 Yes 26 Yes 146 Yes 28 Yes Eastbound Right-Turn 250 22 Yes 81 Yes 24 Yes 79 Yes
Westbound Left-Turns 320 151 Yes 332 Yes3 183 Yes 348 Yes3
The City Drive at SR-22 EB Ramps
Northbound Left-Turn 165 420 No
[a]
312 No
[a]
453 No
[a]
328 No
[a]
Southbound Right-Turn [b] 0 Yes 0 Yes 0 Yes 0 Yes
Eastbound Left-Turn 520 297 Yes 303 Yes 309 Yes 303 Yes Eastbound Shared Left-Turn/Through/Right-Turn 520 298 Yes 303 Yes 310 Yes 303 Yes Eastbound Right-Turn 135 67 Yes 106 Yes 73 Yes 112 Yes
Notes:
[a] = It should be noted that the deficient queueing only occurs on the City street (i.e., The City Drive) and not on SR-22. [b] = This movement is a free right-turn movement.
1 Queue is based on the 95th Percentile Queue and is reported in total queue length (feet) per lane for signalized intersections (refer to Appendices D-III and D-IV of the TIA). 2 Although the queue exceeds the specific lane movement storage, the excess queue can be accommodated within the northbound (NB) left-turn lane since the combined storage between the NB left-turn lane and the NB shared left-turn/through lane of 945 feet (i.e., 845 feet + 100 feet) is greater than those combined queues. 3 Although the queue exceeds the storage of the turn pocket, the excess queue can be accommodated within the turn pockets transition area without impacting westbound through traffic on Metropolitan Drive.
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PUBLIC HEALTH SERVICES
ENVIRONMENTAL HEALTH DIVISION
CLAYTON CHAU, MD, PhD, MASL
AGENCY DIRECTOR
MINDY WINTERSWYK, PT, DPT, PCS
ASSISTANT AGENCY DIRECTOR
MARG
ARET BREDEHOFT, DrPH
CHIEF PUBLIC HEALTH SERVICES
CHRISTINE LANE, REHS
DIRECTOR
ENVIRONMENTAL HEALTH
MAI
L: PO BOX 25400
SANTA ANA, CA 92799
O
FFICE: 1241 E. DYER RD, STE 120
SANTA ANA, CA 92705
TELEPHONE: (714) 433-6000
FAX: (714) 754-1732
E-MAIL: [email protected]
December 14, 2022
Mon
ique Schwartz, Associate Planner
City of Orange
Department of Community Development
Planning Division
300 East Chapman Avenue
Orange, CA 92866
Se
nt via email: [email protected]
Subje
ct: CITY OF ORANGE – NOTICE OF INTENT TO ADOPT MITIGATED NEGATIVE DECLARATION NO. 1875-21 AT 840 THE CITY DRIVE SOUTH, ORANGE, CA (APN Nos.: 231-261-13, -16, AND -17)
Dear
Ms. Schwartz:
The
Orange County Health Care Agency (OCHCA), Environmental Health Division is the certified local enforcement agency (LEA) for all cities and unincorporated areas of Orange County, and authorized and obligated to enforce solid waste l aws and regulations pursuant to California Public Resource Code (PRC) Sections 43209 and 45000 et seq., and Title 14 of the California Code of Regulations (hereinafter Title 14 Regulations) Section 18080 et seq. Pursuant to PRC Section 43200.5(b), in enforcing Part 4, 5 and 6 of Division 30 of the PRC and regulations that implement them, the LEA carries out a state function and thus its actions are independent from, and not subject to the authority of, the Orange County Board of Supervisors.
The
OC Environmental Health Division received the Initial Study/Mitigated Negative Declaration (MND) No. 1875-21 – 840 The City Drive Apartments prepared for the City of Orange as the lead agency to evaluate the potential environmental impacts of mixed-use apartment development in accordance with the California Environmental Quality Act (CEQA). The project proposes to demolish an existing 12,923 sq.-ft. retail building to construct a new six-story, 225-unit vertical mixed-use apartment development with 9,000 sq.-ft. of ground floor retail/restaurant area with subterranean parking beneath the footprint of the building, residential amenities, landscaping, and other related site improvements. The project also includes construction of a new two-story open parking structure for use by adjacent office complex to replace surface parking displaced by the proposed project. The proposed project site includes three parcels totaling 5.86 acres. Based on the review of the MND, the LEA provides the following comments for consideration:
The
proposed development is within 1,000 feet of former Orange City Dump #3 (a.k.a. Orange City Landfill) with Solid Waste Information System (SWIS) ID # 30 -CR-0078 located to the east side of The City Drive, between Garden Grove Blvd. and Garden Grove 22 Freeway that is under the oversight of the LEA. This is OCHCA
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Ms. Monique Schwartz
December 14, 2022
an unconfirmed disposal site with the exact extent unknown and undefined. Based on historic records review, a reduction in the frequency of inspections of the landfill site was approved by CalRecycle (formerly California Integrated Waste Management Board) in August 2001.
In t
he MND, Section 5.9 – Hazards and Hazardous Materials, there is a mention of Phase I Environmental Site Assessments conducted for residential and parking garage sites. It is unclear if the Phase I report s identified the presence of a former disposal site near the proposed development project. Under Section 5.9 – Hazards and Hazardous Materials Impact Analysis , it neither identifies the presence of a landfill nor identif ies CalRecycle SWIS database review with the SWIS No. listed for the disposal site.
Unde
r Section 5.9 – Hazards and Hazardous Materials Impact Analysis, Mitigation Measures – HAZ-1 of the MND it states that during property development , the owner/developer shall retain a hazards specialist to conduct biweekly site visits to observe for areas of possible contamination, such as, but not limited to, the presence of underground facili ties, buried debris, waste drums, and tanks, stained soil, or odorous soil. If hazardous materials are encountered, further investigation and analysis shall be necessary as deemed appropriate by City staff and/or Orange County Health Care Agency (OCHCA). A lthough t he subject document indicates the proposed project site is not on the footprint of the former landfill; however, it should be noted that if previously unknown contamination or solid waste are encountered during site development, the Orange County Solid Waste – LEA Supervisor at (714) 433-6270 or the Environmental Health Main Line at (714) 433-6000 should be contacted.
The f
ormer disposal site is currently not inspected by the LEA and has had no gas probes installed. It is the intent of the LEA to ensure public health, safety, and the environment are protected from hazards through the enforcement of Title 14 and Title 27 Regulations, as applicable to active and closed solid waste facilities. For landfills and disposal sites adjacent to developments, an understanding of the location of residential or commercial buildings, structures, utilities, and other subsurface features are necessary to ensure gas monitoring networks detect lateral migration of methane and protect public health and safety with r espect to Title 27 Regulations. The LEA recommends for any residential developments that are about 1,000 feet distance from a landfill boundary, to consider installing landfill gas monitoring protection system and/or structural monitoring as defined in Tit le 27 Regulations, Division 2, §20931 to ensure landfill gas buildup, if any, will not cause adverse impacts to the public health or safety and the environment.
Tha
nk you for the opportunity to provide input and comments on the MND. If you have any questions, please contact me by email at [email protected] or by phone at (714) 433-6270.
Si
ncerely,
R. Shyamala
Sh
yamala Rajagopal
Supervising Hazardous Materials Specialist
Solid Waste Local Enforcement Agency
Environmental Health Division
cc: La
uren Robinson, Orange County Health Care Agency, Environmental Health Division Abel Martinez, CalRecycle
Cindy Li, Santa Ana Regional Water Quality Control Board CalRecycle/LEA Portal
OCHCA
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Local Agencies
Orange County Health Care Agency Environmental Health Division (OCHCA) Response to OCHCA-1
This comment consists of introductory statements and does not raise any environmental issues related to the proposed project. This comment is noted.
Response to OCHCA-2
The commenter states that a former landfill, Orange City Dump No. 3, is located within 1,000 feet of the project site.
The Phase I Environmental Site Assessments ( ESAs) prepared for the proposed project were included in Appendix F of the Draft IS/MND. The Phase I ESAs included a database search of the Solid Waste Information System (SWIS) database and determined that there were no on- site Recognized Environmental Conditions ( RECs), Controlled Recognized Environmental Conditions (CRECs), Historical Recognized Environmental Conditions ( HRECs), or off-site RECs associated w ith the project site. On December 23, 2022, FirstCarbon Solutions ( FCS) conducted an additional search of the California Department of Resources Recycling and Recovery (CalRecycle) website using the SWIS ID No. 30- CR-0078, a search of the facility name, and an address search using the CalRecycle website’s interactive map. Based on these searches, the CalRecycle website failed to identify the presence of a current or former landfill within 1,000 feet of the project site. Based on discussions between FCS and OCHCA staff that occurred on January 19, 2023, it has been determined that the former landfill has been archived and no longer appears on CalRecycle’s website. Furthermore, the former landfill is no longer active. Additionally, based on documents CalRecycle provided to the Applicant and FCS on January 23, 2023, CalRecycle approved discontinuation of inspections for this suspected, unconfirmed landfill on August 31, 2001. According to files maintained by CalRecycle, inspections were discontinued because the Solid Waste Local Enforcement Agency (LEA) found no evidence of the existence of a landfill on this site, and subsequently recommended discontinuation of site inspections. Additionally, on April 12, 2001, OCHCA determined that the site posed very minimal if any risk to public health and safety or the environment, and that none of the characteristics of a disposal site were observed during LEA inspections that were conducted between 1996 and 2001. Based on the information provided, the presence of the suspected, unconfirmed landfi ll would not pose a health or safety risk to occupants of the proposed project or to the environment.
Nevertheless, MM HAZ-1 would require a hazards specialist to conduct biweekly site visits to monitor for possible contamination, including the presence of underground facilities, buried debris, waste drums, and tanks, stained soil, or odorous soil . Any hazardous materials or conditions on the project site, included those associated with a ny former landfill, would be addressed by MM HAZ -1, which requires further investigation and analysis as deemed appropriate by City staff and/or OCHCA Environmental Health Division. The Owner/Developer would be required to coordinate with the City staff and/or OCHCA Environmental Health Division to address any contamination.
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Response to OCHCA-3
The commenter suggests that in addition to the requirements set forth by Mitigation Measure (MM) HAZ-1, if previously unknown contamination or solid waste are encountered during site development, the Orange County Solid Waste – LEA Supervisor at 714.433.6270 or the Environmental Health Main Line at 714.433.6000 should be contacted.
This addition provides further direction regarding reporting and monitoring to ensure impacts remain less than significant and does not result in any changes to the analysis or conclusions in the Draft IS/MND. Accordingly, this addition has been included in the Errata and is also reflected in the Mitigation Monitoring and Reporting Program (MMRP).
Response to OCHCA-4
Please refer to Response to OCHCA -2, the developer has been working with the California Department of Toxic Substances Control (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.
AFFILIATED AGENCIES
Orange County
Transit District
Local Transportation
Authority
Service Authority for
Freeway Emergencies
Consolidated Transportation
Service Agency
Congestion Management
Agency
Orange County Transportation Authority
550 South Main Street / P.O Box 14184 / Orange / California 92863-1584 / (714) 560-OCTA (6282) December 14, 2022
Ms. Monique Schwartz
Associate Planner
City of Orange – Planning Division
300 East Chapman Avenue
Orange, CA 92866
Subject: Notice of Intent to Adopt Mitigated Negative Declaration (MND No. 1875-21) for the Street Lights Mixed -Use Apartment Development at 840 The City Drive South
Dear Ms. Schwartz:
Thank you for providing the Orange County Transportation Authority (OCTA) with the Notice of Intent for the Street Lights Mixed -Use Project (Project). The following comments are provided for your consideration:
• In Section 5.6 of the MND, ‘Operational Impacts’ (page 87), please rename the bus stop named as “Garden Grove-Memory” to “The City- Memory”.
o Please note that the Garden Grove-The City bus route has two stops, along Garden Grove Blvd., one eastbound and one
westbound. Refer to the attached satellite map.
Throughout the development of this project, we encourage communication with OCTA on any matters discussed herein. If you have any questions or comments, please contact me at (714)-560-5907 or at [email protected].
Sincerely,
Dan Phu
Manager, Environmental Programs
Attachment: Google Satellite Image of Bus Stops
OCTA
1 2
Ms. Monique Schwartz
December 14, 2022
Orange County Transportation Authority
550 South Main Street / P.O Box 14184 / Orange / California 92863-1584 / (714) 560-OCTA (6282) Satellite Image of Bus Stops
OCTA
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Organizations
Orange County Transportation Authority (OCTA)
Response to OCTA-1
The commenter suggests renaming the bus stop in Section 5.6, Page 87 of the Draft IS/MND, from “Garden Grove-Memory” to “The City-Memory.”
This correction has been added to the Errata.
Response to OCTA-2
The commenter states that the Garden Grove -The City bus route has two stops along Garden Grove Boulevard, one eastbound and one westbound.
This comment is noted.
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SECTION 3 ERRATA
The following are revisions to the Draft IS/MND for the 840 The City Drive Apartments Project.
These revisions are minor modifications and clarifications to the document, and do not change the significance of any of the environmental issue conclusions within the Draft IS/MND. The revisions are listed by page number . All additions to the text are underlined ( underlined) and all deletions from the text are stricken (stricken).
Changes in Response to Specific Comments
Section 5.6, Energy
Regional access is provided via SR-22, which is approximately 0.2 mile from the project site.
In addition, the project site is less than 0.1 mile from the Garden Grove -Memory The City- Memory, Garden Grove-The City, and The City-Park Central bus stops for various OCTA bus routes. Thus, transportation fuel consumption would not be wasteful, inefficient, or unnecessary. Impacts would be less than significant.
Section 5.9, Hazards and Hazardous Materials
Mitigation Measures:
MM HAZ-1 During property development, the Owner/Developer shall retain a hazards specialist to conduct biweekly site visits to observe for areas of possible contamination, such as, but not limited to, the presence of underground facilities, buried debris, waste dru ms, and tanks, stained soil, or odorous soil.
Should hazardous materials be encountered, further investigation and analysis shall be necessary as deemed appropriate by City staff and/or Orange County Health Care Agency (OCHCA). Documentation and site visit notes shall be provided to City staff for review. Additionally, if previously unknown contamination or solid waste are encountered during site development, the Owner/Developer shall contact Orange County Solid Waste – LEA Supervisor at 714.433.6270 or the Environmental Health Main Line at 714.433.6000.
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