Agenda packet — Orange City Council, June 24, 2025 (part 4 of 7)

Based on the findings presented in the Paleontological Resources Assessment prepared for the proposed project, the potential exists for the proposed project to impact scientifically significant paleontological resources due to the presence of soils within the project limits with high paleontological sensitivity. To ensure that potential impacts to undiscovered paleontological resources remain less than significant, preparation of a monitoring program, monitoring of construction activities, appropriate treatment of newly discovered resources, and preparation of a final monitoring report would be required, as outlined in the following MM GEO-2:

Mitigation Measures:

MM GEO-2 Paleontological Resources Impact Mitigation Program (PRIMP). A paleontologist who meets the qualifications established by the Society of Vertebrate Paleontology (SVP) shall be retained to develop a Paleontological Resources Impact Mitigation Program (PRIMP) for this project. The PRIMP shall be consistent with the standards of the SVP and include the methods that will be used to protect paleontological resources that may exist within the project limits, as well as procedures for monitoring, fossil preparation and identification, curation into a repository, and preparation of a report at the conclusion of grading. Paleontological monitoring and the preparation of a Report of Findings will be included as part of the PRIMP in order to monitor excavation and grading activities in deposits with high paleontological sensitivity (i.e., Old Alluvial Fan Deposits, Unit 3 and the Sespe and Vaqueros Formations, Undifferentiated) shall be monitored by a qualified paleontological monitor following a PRIMP. No monitoring is required for excavations in deposits with no or low paleontological sensitivity.

If paleontological resources are encountered during the course of ground disturbance, the paleontological monitor shall have the authority to temporarily redirect construction away from the area of the find. In the event that paleontological resources are encountered when a paleontological monitor is not present, work in the immediate area of the find shall be redirected, and the paleontologist or paleontological monitor shall be contacted to assess the find for scientific significance. If determined to be scientifically significant, the fossil shall be collected from the field.

Significance Determination: Potentially Significant Impact Mitigation Measures: As noted in MM GEO-2.

Significance Determination After Mitigation: Less Than Significant Impact 687

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4.8 GREENHOUSE GAS EMISSIONS
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the
environment?
b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of
greenhouse gases?
Technical Background
The analysis presented in the following section is based upon the Air Quality and Greenhouse Gas Emissions Technical Memorandum (AQ/GHG Memo) prepared for the proposed project, which involved emissions modeling using the California Emissions Estimator Model version 2022.1 (CalEEMod) computer program. The AQ/GHG Memo is included within this IS/MND as Appendix A.

Greenhouse Gases (GHGs) are present in the atmosphere naturally, are released by natural sources, or form from secondary reactions taking place in the atmosphere. Over the last 200 years, humans have caused substantial quantities of GHGs to be released into the atmosphere. These extra emissions are increasing GHG concentrations in the atmosphere and enhancing the natural greenhouse effect, which is believed to be causing global warming. Although manmade GHGs include naturally occurring GHGs such as carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O), some gases like hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), nitrogen trifluoride (NF3), and sulfur hexafluoride (SF6) are completely new to the atmosphere.

Certain gases, such as water vapor, are short-lived in the atmosphere. Others remain in the atmosphere for significant periods of time, contributing to climate change in the long term. Water vapor is excluded from the list of GHGs above because it is short-lived in the atmosphere and its atmospheric concentrations are largely determined by natural processes, such as oceanic evaporation.

These gases vary considerably in terms of Global Warming Potential (GWP), which is a concept developed to compare the ability of each GHG to trap heat in the atmosphere relative to another gas.

The GWP is based on several factors, including the relative effectiveness of a gas to absorb infrared radiation and length of time that the gas remains in the atmosphere (“atmospheric lifetime”). The GWP of each gas is measured relative to CO2, the most abundant GHG; the definition of GWP for a particular GHG is the ratio of heat trapped by one unit mass of the GHG to the ratio of heat trapped by one unit mass of CO2 over a specified time period. GHG emissions are typically measured in terms of pounds or tons of “CO2 equivalents” (CO2e).

State CEQA Guidelines Section 15064(b) provides that the “determination of whether a project may have a significant effect on the environment calls for careful judgment on the part of the public agency involved, based to the extent possible on scientific and factual data,” and further states that an “ironclad definition of significant effect is not always possible because the significance of an activity may vary with the setting.” Currently, there is no Statewide GHG emissions threshold that has been used to 688

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4 \\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) -48 determine the potential GHG emissions impacts of a project. Threshold methodology and thresholds are currently developed and revised by air districts in California.

GHG Thresholds for Construction and Operational Emissions To provide guidance to local lead agencies on determining significance for GHG emissions in their California Environmental Quality Act (CEQA) documents, the South Coast Air Quality Management District (SCAQMD) convened a GHG CEQA Significance Threshold Working Group (Working Group). The Working Group has identified a tiered approach for evaluating GHG emissions for development projects where SCAQMD is not the lead agency:
• Tier 1. If a project is exempt from CEQA, project-level and cumulative GHG emissions are less than significant.
• Tier 2. If the project complies with a GHG emissions reduction plan or mitigation program that avoids or substantially reduces GHG emissions in the project’s geographic area (i.e., city or county), project-level and cumulative GHG emissions are less than significant. • Tier 3. If GHG emissions are less than the screening-level threshold, project-level and cumulative GHG emissions are less than significant. For projects that are not exempt or where no qualifying GHG reduction plans are directly applicable, the SCAQMD requires an assessment of GHG emissions. The SCAQMD is using a “bright-line” screening-level threshold of 3,000 metric tons (MT) of CO2e annually for commercial land use types. Therefore, projects that do not exceed the bright-line threshold would have a nominal, and therefore, less than cumulatively considerable impact related to GHG emissions.
• Tier 4. If emissions exceed the screening threshold, a more detailed review of the project’s GHG emissions is warranted.

Individual GHGs have varying global warming potentials and atmospheric lifetimes. Because it is not possible to tie specific GHG emissions to actual changes in climate, this evaluation focuses on the project’s emissions of GHGs. CO2e is a consistent methodology for comparing GHG emissions because it normalizes various GHGs to the same metric. GHG emissions are typically measured in terms of MT CO2e. Therefore, for the purpose of this technical analysis, the concept of CO2e is used to describe how much GCC a given type and amount of GHG may cause, using the functionally equivalent amount or concentration of CO2 as the reference.

The City of Orange does not currently have formal GHG emissions reduction plans or recommended emissions thresholds for determining significance associated with GHG emissions from development projects. However, the City Community Development Department has provided a Guidance memorandum on how to address GHG emissions in CEQA documents for which the City is the Lead Agency. In addition, the City published guidance for GHG emissions analysis in CEQA documents.

In its Guidance for Greenhouse Gas Emissions Analysis, the City of Orange accepts the “Tier III” quantitative interim significance thresholds recommended by the SCAQMD for commercial, industrial, mixed-use, and industrial development projects as follows:
• Industrial Projects—10,000 metric tons of carbon dioxide equivalents (MT CO2e) per year 689

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Impact Analysis
a) Would the project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
To quantify GHG emissions, LSA utilized CalEEMod, Version 2022.1 to generate the quantitative output changes in air quality and GHG emissions based on the proposed project widening. As discussed further in Section 4.17, Transportation, upon completion of construction activities, operation of the proposed project would not result in an induced travel demand and would not lead to a substantial increase in vehicle travel. The proposed project would add an additional through lane in one direction and widen sections of the roadway, thus improving the level of service and reducing delay. These changes are not expected to generate new vehicular traffic trips.

Construction Greenhouse Gas Emissions. Construction activities associated with the proposed project would produce combustion emissions from various sources. Construction would emit GHGs through the operation of construction equipment and from worker and builder supply vendor vehicles for the duration of the approximately 250-day construction period. The combustion of fossil-based fuels creates GHGs such as CO2, CH4, and N2O. Furthermore, the fueling of heavy equipment emits CH4.

Exhaust emissions from on-site construction activities would vary daily as construction activity levels change.

As indicated above, SCAQMD does not have an adopted threshold of significance for constructionrelated GHG emissions. However, lead agencies are required to quantify and disclose GHG emissions that would occur during construction. The SCAQMD then requires the construction GHG emissions to be amortized over the life of the project (which is defined as 30 years), added to the operational emissions, and compared to the applicable interim GHG significance threshold tier. Based on CalEEMod, it is estimated that the project would generate 1,767.2 MT CO2e during construction of the project. When amortized over the 30-year life of the project, annual emissions would be 58.9 MT CO2e.

Construction emissions are temporary and would cease to occur after the construction period; therefore, the proposed project would not result in the generation of substantial GHG emissions during construction. Therefore, construction activities would not generate a significant amount of GHG emissions. Table 4.8.A, below, further details the different pollutant emissions that are expected to be emitted within the project limits during construction. Construction impacts would be less than significant, and mitigation is not required.

Table 4.8.A: Project Construction Greenhouse Gas Emissions Source Pollutant Emissions (lbs/day)
NOx CO PM10 PM2.5
On-Site Emissions 87.6 95.1 6.5 3.9
Localized Significant Threshold 183.0 1,253.0 13.0 7.0
Significant? No No No No
Source: Compiled by LSA (April 2024).

Note: Source Receptor Area 17, based on a 5.0-acre construction disturbance daily area, at a distance of 82 feet from the project boundary.

CO = carbon monoxide
lbs/day = pounds per day
NOX = nitrogen oxides
PM2.5 = particulate matter less than 2.5 microns in size PM10 = particulate matter less than 10 microns in size
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As described previously in Section 2.0, Project Description, the proposed project will widen the roadway to accommodate a third northbound lane on Cannon Street to improve traffic operations.

Furthermore, the proposed project would improve pedestrian and bicyclist facilities by constructing a new bridge just west of the existing vehicular bridge.

As discussed in the Proposed Improvements to Cannon Street Traffic Assessment Memorandum (Traffic Assessment Memo)
38 prepared for the proposed project by LSA in October 2024 (included as Appendix F to this IS/MND), upon completion of construction activities, operation of the proposed project would not result in an induced travel demand and would not lead to a substantial increase in vehicle travel. The proposed project would add an additional through lane in one direction and widen sections of the roadway, thus improving the level of service and reducing delay. These changes are not expected to generate new vehicular traffic trips. Additionally, the proposed project would improve conditions for pedestrians and cyclists (widening of the west side of Cannon Street where pedestrian and bicycle facilities narrow and providing a new bridge over Santiago Creek). As such, the proposed project would not result in an increase in the generation of vehicle trips or VMT that would result in an increase GHG emissions.

Utilities, traffic signals and street lighting would be relocated outside the project limits, as necessary.

Therefore, the proposed project would also not be a substantial source of energy, area waste, or water source emissions and would not generate GHG emissions that would have a significant impact on the environment. Operational impacts would be less than significant, and mitigation is not required.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: Less Than Significant Impact b) Would the project conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
The City, as a lead agency, may assess the significance of GHG emissions by determining a project’s consistency with a local GHG reduction plan that qualifies under Section 15183.5 of the State CEQA Guidelines. The City of Orange has not adopted a GHG reduction plan. In addition, the City has not completed the GHG inventory, benchmarking, and goal-setting process required to identify a reduction target and to take advantage of the streamlining provisions contained in the CEQA Guidelines amendments adopted for Senate Bill (SB) 97. Since no other local or regional climate action plan is in place, the project is assessed for its consistency with the California Air Resources Board’s (CARB) adopted Scoping Plan and the 2024 Southern California Association of Governments (SCAG) Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), also known as Connect SoCal 2024. This would be achieved with an assessment of the project’s compliance with the Scoping Plan and SCAG Connect SoCal 2024 measures.
38 LSA Associates, Inc. (LSA). 2024. Proposed Improvements to Cannon Street Traffic Vehicle Miles Traveled Memo. October 2024.
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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-51 In 2008, CARB approved a Climate Change Scoping Plan as required by AB 32. The Climate Change Scoping Plan proposed a “comprehensive set of actions designed to reduce overall carbon GHG emissions in California, improve our environment, reduce our dependence on oil, diversify our energy sources, save energy, create new jobs, and enhance public health.” The 2008 Climate Change Scoping Plan has a range of GHG reduction actions, which include direct regulations, alternative compliance mechanisms, monetary and non-monetary incentives, voluntary actions, market-based mechanisms (e.g., a cap-and-trade system), and an Assembly Bill (AB) 32 implementation fee to fund the program.

The 2022 Scoping Plan39 was approved in December 2022 and assesses progress toward the statutory 2030 target while laying out a path to achieving carbon neutrality no later than 2045. The 2022 Scoping Plan Update focuses on outcomes needed to achieve carbon neutrality by assessing paths for clean technology, energy deployment, natural and working lands, and others, and is designed to meet the State’s long-term climate objectives and support a range of economic, environmental, energy security, environmental justice, and public health priorities.

On April 4, 2024, SCAG adopted Connect SoCal: 2024 Regional Transportation Plan/Sustainable Communities Strategy (Connect SoCal 2024).40 In general, Connect SoCal 2024 outlines a development pattern for the region, which, when integrated with the transportation network and other transportation measures and policies, would reduce VMT from automobiles and light-duty trucks and thereby reduce GHG emissions from these sources. For the SCAG region, the CARB has set GHG reduction targets at 8 percent below 2005 per-capita emissions levels by 2020 and 19 percent below 2005 per capita emissions levels by 2035. Connect SoCal 2024 lays out a strategy for the region to meet these targets.

Overall, Connect SoCal 2024 is meant to provide growth strategies that will achieve the regional GHG emissions reduction targets. Land use strategies to achieve the region’s targets include planning for new growth around high-quality transit areas and livable corridors, and creating neighborhood mobility areas to integrate land use and transportation and plan for more active lifestyles. 41 However, Connect
SoCal 2024 does not require that local General Plans, Specific Plans, or zoning be consistent with the SCS; instead, it provides incentives to governments and developers for consistency.

Overall, GHG emissions released during construction of the proposed project are estimated to be minimal and would not be cumulatively considerable. Once constructed, operational emissions would be similar to existing conditions. Therefore, implementation of the proposed project would not conflict with the State’s GHG emissions reductions objectives embodied in the 2022 Scoping Plan and Connect SoCal 2024 and is also consistent with State-level plans. Less than significant impacts would result from the proposed project, and no mitigation is required.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: Less Than Significant Impact 39 California Air Resources Board (CARB). 2022. 2022 Scoping Plan Update. May 10. Website:
https://ww2.arb.ca.gov/sites/default/files/2022-12/2022-sp.pdf (accessed December 2023). 40 Southern California Association of Governments (SCAG). 2024. Connect SoCal: Regional Transportation Plan/Sustainable Communities Strategy. April 4. Website: https://scag.ca.gov/sites/main/files/fileattachments/23-2987-connect-socal-2024-final-complete-040424.pdf?1714175547 (accessed July 18, 2024). 41 Ibid.
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4.9 HAZARDS AND HAZARDOUS MATERIALS
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Create a significant hazard to the public or the
environment through the routine transport, use, or
disposal of hazardous materials?
b) Create a significant hazard to the public or the
environment through reasonably foreseeable upset
and accident conditions involving the release of
hazardous materials into the environment?
c) Emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste
within one-quarter mile of an existing or proposed
school?
d) Be located on a site which is included on a list of
hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and, as a result,
would it create a significant hazard to the public or
the environment?
e) For a project located within an airport land use plan or, where such a plan has not been adopted, within 2
miles of a public airport or public use airport, would
the project result in a safety hazard or excessive noise for people residing or working in the project area?
f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency
evacuation plan?
g) Expose people or structures, either directly or
indirectly, to a significant risk of loss, injury or death involving wildland fires?
Impact Analysis
a) Would the project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? Hazardous materials are chemicals that could potentially cause harm during an accidental release or mishap, and are defined as being toxic, corrosive, flammable, reactive, and an irritant or strong sensitizer.42 Hazardous substances include all chemicals regulated under the United States Department of Transportation’s (USDOT) “hazardous materials” regulations and the United States Environmental Protection Agency (USEPA) “hazardous waste” regulations. Hazardous wastes require special handling and disposal because of their potential to damage public health and the environment. The probable frequency and severity of consequences from the routine transport, use, or disposal of hazardous 42 A “sensitizer” is a chemical that can cause a substantial proportion of people or animals to develop an allergic reaction in normal tissue after repeated exposure to a chemical (United States Department of Labor 2017). 693

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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-53 materials are affected by the type of substance, the quantity used or managed, and the nature of the activities and operations.

The proposed project is a roadway improvement project and would not involve the routine transport, use, or dispose of hazardous materials. No manufacturing, industrial, or other uses utilizing large amounts of hazardous materials would occur within the project limits. Operations of the proposed project would be limited to vehicular use of the roadway, which would involve minimal amounts of hazardous materials.

During construction of the proposed project, hazardous materials such as fuel, lubricants, paint, sealants, and adhesives would be transported and used at the project limits. The proposed project would be required to comply with federal, State, and local regulations regarding the transportation, use, and disposal of hazardous materials, including compliance with appropriate pollution prevention control practices in accordance with the current edition of the “Green Book” Standard Specifications for Public Works Construction and the provisions of Section A-8. Further, pursuant to requirements set forth in the City of Orange LIP, the proposed project would be required to implement Erosion and Sediment Control Plans (ESCPs). These requirements are specified in RCM HYD-1. Compliance with existing regulations and implementation of ESCPs during construction would ensure that potential impacts associated with hazardous material use, transport, and disposal are considered less than significant, and no mitigation is required.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: Less Than Significant Impact b) Would the project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
The potential for releasing hazardous materials into the environment would be limited to construction of the proposed project as well as vehicles on the roadway during operations. As previously stated, compliance with existing regulations and implementation of the ESCPs pursuant to RCM HYD-1 would reduce the potential for the release of hazardous materials during construction of the proposed project. Regardless, if a hazardous release were to occur, it would not be anticipated to result in a significant hazard to the public, surrounding land uses, or environment due to the small quantities of these materials associated with construction activities.

The potential associated with vehicular use of the roadway exists under current conditions and would not be substantially greater under the proposed project. Vehicles and trucks may transport hazardous substances that could spill and impact the roadway, adjacent properties, or resources. However, transport of hazardous materials is subject to strict regulations established by local police and fire departments trained in emergency response procedures for safely responding to accidental spills of hazardous substances on public roads, which further reduces impacts. Therefore, impacts of the proposed project associated with hazards from reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment would be similar to existing conditions and are considered less than significant.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
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4 \\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) -54 Significance Determination After Mitigation: Less Than Significant Impact c) Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? The proposed roadway improvements would not produce hazardous emissions or handle a significant amount of acutely hazardous materials, substances, or wastes during either construction or operations.

The nearest school to the project limits is Linda Vista Elementary School, which is located approximately

0.14 mile south of the project limits at 1200 N. Cannon Street. As discussed in Response 4.9(a), the proposed project is not anticipated to release hazardous emissions or handle acutely hazardous materials, substances, or wastes in significant quantities. The amount of hazardous chemicals present during construction is limited and would be in compliance with existing government regulations.

During operation, the roadway would not require the use, storage, disposal, or transport of large volumes of hazardous materials that could cause serious environmental damage in the event of an accident. Therefore, impacts related to hazardous emissions or handling of hazardous or acutely hazardous materials, substances, or waste within 0.25 mile of an existing or proposed school would be less than significant, and no mitigation is required.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: Less Than Significant Impact d) Would the project be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
Government Code Section 65962.5, or the Cortese List Statute, states that the California Department of Toxic Substances Control (DTSC) shall compile and maintain annually a list (Cortese List) of hazardous waste facilities subject to corrective action as part of the Health and Safety Code. This list is commonly referred to as the Cortese List. Cortese List data resources include the DTSC EnviroStor database, the State Water Resources Control Board (SWRCB) GeoTracker database, and other resources identified by the California Environmental Protection Agency (CalEPA).43 According to the DTSC EnviroStor database, the project limits are not located on a federal Superfund site, State response site, voluntary cleanup site, evaluation site, school or military investigation site, tiered permit site, or corrective action site.44 Further, no sites are listed on the EnviroStor database within a 1-mile radius of the project limits.

A review of the SWRCB GeoTracker database45 indicated that no active Leaking Underground Storage Tank (LUST) cleanup sites, cleanup program sites, military cleanup sites, military privatized sites, or military Underground Storage Tank (UST) sites exist within the project limits or its vicinity. The 43 California Environmental Protection Agency (CalEPA). 2024. Cortese List Data Resources. Website:
https://calepa.ca.gov/sitecleanup/corteselist/ (accessed April 9, 2024). 44 California Department of Toxic Substances Control (DTSC). n.d. EnviroStor Database. Website:
https://www.envirostor.dtsc.ca.gov/public/ (accessed April 9, 2024). 45 State Water Resources Control Board (SWRCB). n.d. GeoTracker Database. Website: https://geotracker. waterboards.ca.gov/ (accessed April 9, 2024).
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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-55 nearest site listed on GeoTracker to the project limits is the Irvine Lake Boat and Tackle site, located approximately 0.12 mile west of the project limits at 4261 Santiago Canyon Road. This site was listed as a LUST cleanup site, but was marked as “completed – case closed” as of July 8, 1997.

The project limits are also not located on a list of solid waste disposal sites identified by the SWRCB with waste constituents above hazardous waste levels outside the waste management unit46 or active cease and desist orders and cleanup and abatement orders.47 Based on the information presented above, the proposed project would not result in an impact related to a known hazardous materials site pursuant to Government Code Section 65965.5 and would not create a significant hazard to the public or the environment. No mitigation is required.

Significance Determination: No Impact
Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: No Impact
e) Would the project be located within an airport land use plan or, where such a plan has not been adopted, within 2 miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area? The closest airports to the project limits are the John Wayne Airport and the Fullerton Municipal Airport, which are located approximately 9.6 miles southwest and 10.8 miles northwest of the project limits, respectively. As such, the project limits are not located within 2 miles of a public airport or public use airport. The project limits are located outside the Airport Environs Land Use Plan for both John Wayne Airport48 and Fullerton Municipal Airport.
49 The proposed project is a transportation
project and would not involve the introduction of new hazards or excessive noise. Therefore, the project would not expose people residing or working in the vicinity to aviation-related safety hazards or excessive noise levels, and no impact would occur. No mitigation is required.

Significance Determination: No Impact
Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: No Impact
46 California Environmental Protection Agency (CalEPA). n.d.-b. Sites Identified with Waste Constituents Above Hazardous Waste Levels Outside the Waste Management Unit. Website: https://calepa.ca.gov/wpcontent/uploads/sites/6/2016/10/SiteCleanup-CorteseList-CurrentList.pdf (accessed April 9, 2024). 47 California Environmental Protection Agency (CalEPA). n.d.-a. List of “Active” CDO and CAO from Water Board (accessed April 9, 2024).
48 Orange County Airport Land Use Commission (OCALUC). 2008. Airport Environs Land Use Plan for John Wayne Airport. April 17. Website: https://files.ocair.com/media/2021-02/JWA_AELUP-April-17-2008.pdf? VersionId=cB0byJjdad9OuY5im7Oaj5aWaT1FS.vD (accessed April 9, 2024). 49 Orange County Airport Land Use Commission (OCALUC). 2019. Airport Environs Land Use Plan for Fullerton Municipal Airport. February 21. Website: https://files.ocair.com/media/202102/AELUP%20for% 20FMA%2005092019.pdf (accessed April 9, 2024).
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4 \\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) -56 f) Would the project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
The City’s General Plan Public Safety Element50 outlines goals and policies aimed at adequately preparing for future emergency situations, including the components of the City’s Emergency Operations Plan and procedures for emergency access and evacuation. According to Figure PS-4, Generalized Evacuation Corridors, of the Public Safety Element, Cannon Street is not designated as an evacuation corridor. Cannon Street does intersect with the Chapman Avenue evacuation corridor, but this intersection falls outside of the project limits and therefore is not anticipated to be affected by the proposed project. As noted by the City’s Emergency Operations Plan, evacuation routes for emergency situations are contingent upon the scale and location of the emergency, and would change depending on the direction of evacuation required by the situation.

The proposed project does not include any characteristics (e.g., permanent road closures or long-term blocking of road access) that would physically impair or otherwise conflict with an emergency response plan or emergency evacuation plan. The proposed project would not result in any substantial traffic impacts or queueing on nearby streets during short-term construction activities with utilization of lane shifts, and all construction equipment would be staged within the project limits or within nearby temporary construction easements. Long-term operations of the proposed project would result in improved movement along the Cannon Street roadway, particularly in the northbound direction, thus improving the mobility of emergency vehicles along Cannon Street when necessitated by an emergency event.

Further, the improvements and pedestrian bridge proposed under the project would be reviewed and approved by the Orange City Fire Department and the City as part of the City’s Design Review process to ensure compliance with all applicable codes and ordinances for emergency vehicle access. Therefore, with Fire Department review of the project plans, the proposed project’s impacts related to emergency response and evacuation plans would be less than significant, and no mitigation would be required.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: Less Than Significant Impact g) Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires? Please refer to Section 4.20, Wildfire, for a detailed analysis of the proposed project’s potential impacts related to wildfire. The California Department of Forestry and Fire Protection (CAL FIRE) has mapped areas of significant fire hazards in the State through its Fire and Resources Assessment Program (FRAP). These maps place areas of California into different fire hazard severity zones (FHSZ), based on a hazard scoring system using subjective criteria for fuels, fire history, terrain influences, housing densities, and occurrence of severe fire weather where urban conflagration could result in catastrophic losses. As part of this mapping system, CAL FIRE is responsible for wildland fire protection for land areas that are generally unincorporated and they are classified as State Responsibility Areas (SRAs). In areas where local fire protection agencies (e.g., Orange County Fire Authority [OCFA]) are responsible for wildfire protection, the lands are classified as Local Responsibility Areas (LRAs). CAL FIRE 50 City of Orange. 2015. Orange General Plan Public Safety Element. Website: https://www. .org/home/ showpublisheddocument/214/637698172567530000 (accessed February 9, 2024). 697

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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-57 currently identifies the proposed project limits, and the City of Orange in its entirety, as a Local Responsibility Area.

According to CAL FIRE’s Fire and Resource Assessment Program Fire Hazard Severity Viewer, the project limits are not located within a Very High Fire Hazard Severity Zone (VHFHSZ), or within a SRA.51 However, the land directly to the east of the project limits is considered a VHFHSZ within an LRA. Despite this proximity to a VHFHSZ, the proposed project would utilize land shifts in order to maintain through access during short-term construction activities and therefore is not anticipated to result in any substantial traffic impacts or queueing on nearby streets during construction of the proposed project, as discussed in Section 4.17, Transportation. In addition, all construction equipment would be staged within temporary construction easements and would not interfere with movement along the Cannon Street corridor. Therefore, the proposed project would not expose any individuals or structures to risk of wildland fire throughout the construction phase.

The proposed project consists of roadway improvements and the construction of a pedestrian bridge which would not introduce any new inhabitable structures with the potential to place people at increased risk of wildfire hazards. Operations of the proposed project would consist of improved mobility conditions and would not expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires. Impacts would be less than significant, and no mitigation is required.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: Less Than Significant Impact 51 California Department of Forestry and Fire Protection (CAL FIRE). 2022. Fire and Resource Assessment Program Fire Hazard Severity Viewer. Website: https://egis.fire.ca.gov/FHSZ/ (accessed February 6, 2024). 698

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4.10 HYDROLOGY AND WATER QUALITY
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Violate any water quality standards or waste
discharge requirements or otherwise substantially
degrade surface or groundwater quality?
b) Substantially decrease groundwater supplies or
interfere substantially with groundwater recharge
such that the project may impede sustainable
groundwater management of the basin?
c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the
course of a stream or river or through the addition of
impervious surfaces, in a manner which would:
i. Result in substantial erosion or siltation on- or
off-site;
ii. Substantially increase the rate or amount of
surface runoff in a manner which would result in
flooding on- or offsite;
iii. Create or contribute runoff water which would
exceed the capacity of existing or planned
stormwater drainage systems or provide
substantial additional sources of polluted runoff;
or
iv. Impede or redirect flood flows?
d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
e) Conflict with or obstruct implementation of a water
quality control plan or sustainable groundwater
management plan?
Impact Analysis
a) Would the project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality? The proposed project consists of widening an existing 0.6-mile portion of the Cannon Street roadway to accommodate a third northbound auxiliary lane, as well as the construction of a new pedestrian bridge over Santiago Creek and a traffic signal modification. As noted from this description, Santiago Creek is located within central portion of the project limits which perpendicularly crosses beneath Cannon Street and is tributary to the Santa Ana River. The Santiago Creek conveys perennial flows of water from the eastern portion of the project limits to the western portion of the project limits, where it flows into Santiago Creek Recharge Basin.

Pollutants of concern during construction include, but are not limited to: solid or liquid chemical spills; wastes from paints, stains, sealants, glues, lime, pesticides, herbicides, wood preservatives and solvents, asbestos fibers, paint flakes or stucco fragments; fuels, oils, lubricants, and hydraulic, radiator or battery fluids; concrete, detergent or floatable wastes; wastes from any engine/equipment steam cleaning or 699

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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-59 chemical degreasing; and super-chlorinated potable water line flushing. Each of these pollutants on its own or in combination with other pollutants can have a detrimental effect on water quality. During construction activities, excavated soil would be exposed, and there would be an increased potential for soil erosion and sedimentation compared to existing conditions. In addition, chemicals liquid products, petroleum products (e.g., paints, solvents, and fuels), and concrete-related waste may be spilled or leaked and have the potential to be transported via stormwater runoff into receiving waters (i.e., the municipal storm drain system which discharges into the Santa Ana River, and ultimately into the Pacific Ocean). Stormwater runoff is regulated by the National Pollutant Discharge Elimination System (NPDES) Program (established through the federal Clean Water Act [CWA]). The objective of the NPDES Program is to control and reduce pollutant discharges to surface water bodies. Compliance with NPDES permits is mandated by State and federal statutes and regulations. Locally, the NPDES Program is administered by the Santa Ana Regional Water Quality Control Board (RWQCB).

Construction activities can be subject to the SWRCB NPDES General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities, Order No. 2022-0057- DWQ, NPDES No. CAS000002 (Construction General Permit) depending on soil disturbance. Any construction activity, including grading, that would result in the disturbance of 1 acre or more would require compliance with SWRCB’s Construction General Permit, which requires preparation of a Stormwater Pollution Prevention Program (SWPPP) and implementation of Construction Best Management Practices (BMPs) to address water quality concerns during construction activities.

Construction BMPs would include, but not be limited to, Erosion Control and Sediment Control BMPs designed to minimize erosion and retain sediment on site as well as Good Housekeeping BMPs to prevent spills, leaks, and discharge of construction debris and waste into receiving waters.

The proposed project’s operational activities are subject to the NPDES Permit and Waste Discharge Requirements for Discharges from the Municipal Separate Storm Sewer Systems (MS4s) Draining the Watersheds Within the Orange County Region, Order No. R8-2009-0030, NPDES No. CAS618030 as amended by Order No. R8-2010-0062 (MS4 Permit). The MS4 Permit prohibits discharges, sets limits on pollutants being discharged into receiving waters, and requires implementation of technology-based standards. The MS4 Permit requires co-permittees, including the City, to develop and implement standard design and post-development BMP guidance to guide application of Low Impact Development (LID) BMPs to the maximum extent practicable. The MS4 Permit also requires preparation of a Water Quality Management Plan (WQMP), implementation of post-construction BMPs, and hydromodification requirements for new development and significant redevelopment projects that qualify as “Priority Development” projects.

Section 7.01 of the City of Orange Municipal Code codifies requirements related to water quality and stormwater discharges, and is intended to enhance and protect water quality by prescribing requirements for all new development and significant redevelopment projects in order to reduce pollution in surface runoff. Chapter 7.01 includes, but is not limited to, general provisions, prohibited discharges, BMP requirements, and monitoring and inspection procedures. Section 7.01.050 of the City’s Municipal Code requires that new development projects and significant redevelopment projects adhere to the City’s Local Implementation Plan (LIP) prepared as part of a compliance program to satisfy the requirement of the area-wide Drainage Area Management Plan (DAMP) and the Santa Ana RWQCB municipal storm water permit issued to the City. The LIP outlines protocols for citywide projects to implement in order to contribute to regional stormwater pollution control efforts and adhere to the requirements of applicable NPDES permits described above. In addition, all projects requiring discretionary and some requiring ministerial City approval are required to prepare a WQMP in 700

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4 \\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) -60 accordance with the Orange County DAMP and City of Orange LIP. 52 Therefore, all development
projects, regardless of priority status, would be required to implement these features where applicable and feasible.

Construction. The proposed project would include a variety of roadway improvements along an

0.6-mile segment of the Cannon Street roadway including curb realignment, lane restriping, median modification, tree and streetlight relocation, and construction of the new pedestrian bridge over Santiago Creek. Pollutants of concern during construction include, but are not limited to: solid or liquid chemical spills; wastes from paints, stains, sealants, glues, lime, pesticides, herbicides, wood preservatives and solvents, asbestos fibers, paint flakes or stucco fragments; fuels, oils, lubricants, and hydraulic, radiator or battery fluids; concrete, detergent or floatable wastes; wastes from any engine/equipment steam cleaning or chemical degreasing; and super-chlorinated potable water line flushing. Each of these pollutants on its own or in combination with other pollutants can have a detrimental effect on water quality. During construction activities, excavated soil would be exposed, and there would be an increased potential for soil erosion and sedimentation compared to existing conditions. In addition, chemicals, liquid products, petroleum products (e.g., paints, solvents, and fuels), and concrete-related waste have the potential to be transported via stormwater runoff into receiving waters if spilled or leaked during construction activities.

Because construction of the proposed project is expected to disturb 0.62 acre of soil, the project is not subject to the requirements of the Construction General Permit, as described earlier. As such, the preparation of a SWPPP is not required for the proposed project. However, the City’s LIP sets forth requirements for public works construction projects not subject to the Construction General Permit.

According to the LIP, the proposed project shall comply with appropriate pollution prevention control practices in accordance with the current edition of the “Green Book” Standard Specifications for Public Works Construction and the provisions of Section A-8, and shall develop and implement ESCPs. The proposed project’s adherence to these requirements is specified in Regulatory Compliance Measure (RCM) HYD-1. Further, in the event that circumstances change and construction of the proposed project disturbs greater than 1 acre of soil, the requirements of the Construction General Permit, including preparation of a SWPPP and implementation of construction BMPs during construction activities, would be required pursuant to NPDES guidelines.

The proposed project would also be required to comply with the City of Orange’s Local Implementation Plan (LIP),53 which was adopted by the City in July 2003 as part of a compliance program to satisfy the requirement of the area-wide DAMP. The LIP outlines protocols for citywide projects to implement in order to contribute to regional stormwater pollution control efforts and adhere to the requirements of applicable NPDES permits required for the project. In addition, all projects requiring discretionary and some requiring ministerial City approval are required to prepare a WQMP in accordance with the Orange County DAMP and City of Orange LIP. These City requirements are classified as RCM HYD1, which is intended to enhance and protect water quality by prescribing requirements for all new development and redevelopment projects designed to reduce pollution in surface runoff. This will require the inclusion of project features such as: general provisions, prohibited discharges, BMPs, monitoring and inspection procedures, including implementation of construction BMPs to manage the 52 City of Orange. Storm Water Program – Water Quality Management Plans. Website: https://www.cityof orange.org/our-city/departments/public-works/engineering-division/storm-water (accessed April 19, 2024). 53 City of Orange. 2011. Storm Water Local Implementation Plan (LIP). July. Website: https://www.cityof orange.org/home/showpublisheddocument/500/637702460732200000 (accessed April 25, 2024). 701

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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-61 surface runoff from the construction site. As specified in RCM HYD-1, the Construction Contractor would be required to implement ESCPs.

According to the Cannon Street Widening Improvement Project Foundation Report prepared by Earth Mechanics, Inc. (January 2024), groundwater was encountered in all borings at depths ranging from 16 to 25 feet below ground surface (bgs) during a field investigation. The maximum depth of excavation to construct project features is anticipated to reach approximately up to 40-ft bgs for cast-in-drilled hole (CIDH) piles associated with the new Santiago Creek Bridge Foundation. As such, groundwater dewatering may be required during construction of the proposed project. Groundwater dewatering activities could affect surface water quality through the discharge of polluted groundwater to surface water bodies. As specified in RCM HYD-2, groundwater dewatering activities would comply with the Waste Discharge Requirements (WDR) Permit for Discharges to Surface Waters That Pose an Insignificant (De Minimis) Threat to Water Quality (Groundwater Discharge Permit) (Order No. R8- 2020-0006, NPDES No. CAG998001). In compliance with the requirements of the Groundwater Discharge Permit, groundwater would be tested and treated (if necessary) prior to discharge to surface waters. With adherence to RCM HYD-2, groundwater dewatering, if necessary during construction activities, would not introduce pollutants to receiving waters at levels that would violate water quality standards or water discharge requirements, degrade water quality, or alter the quality of the receiving water.

As discussed in RCM HYD-2, dewatered groundwater would be subject to water sampling, analysis, and treatment (if required) prior to discharge in order to minimize any potential to introduce pollutants to groundwater. Infiltration of stormwater has the potential to affect groundwater quality in areas of shallow groundwater. As discussed above, groundwater could occur at depths from 16 to 25 feet bgs.

Pollutants in stormwater are generally removed by soil through absorption as water infiltrates. In areas of deep groundwater, there is more absorption potential and, as a result, less potential for pollutants to reach groundwater. Due to the potential to impede on groundwater quality for the construction of the Santiago Creek bridge foundation, it is imperative to adhere to the regulations outlined in the NPDES Groundwater Discharge Permit in order to not affect any potential direct path for pollutants to reach groundwater. With the implementation of RCM HYD-2, project construction activities would not substantially degrade groundwater quality.

With implementation of RCM HYD-1 and RCM HYD-2, which require adherence to the City’s Local Implementation Plan, and Groundwater Discharge Permit, construction impacts related to surface water quality standards, waste discharge requirements, and surface water quality would be less than significant, and no mitigation is required.

Operation. The proposed project consists of widening an existing 0.6-mile portion of the Cannon Street roadway to accommodate a third northbound auxiliary lane, as well as a new pedestrian bridge over Santiago Creek and a traffic signal modification. As noted from this description, the pedestrian bridge over Santiago Creek is located within central portion of the project limits which perpendicularly crosses beneath Cannon Street and is tributary to the Santa Ana River. Pollutants of concern from long-term operations of the proposed project include suspended solids/sediment, nutrients, oil and grease, metals, and trash and debris.

As previously stated, operational activities are subject to the NPDES MS4 Permit. The MS4 Permit prohibits discharges, sets limits on pollutants being discharged into receiving waters, and requires implementation of technology-based standards. The MS4 Permit requires co-permittees, including the City, to develop and implement standard design and post-development BMP guidance to guide 702

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4 \\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) -62 application of LID BMPs to the maximum extent practicable. The MS4 Permit also requires preparation of a WQMP, implementation of post-construction BMPs, and hydromodification requirements for new development and significant redevelopment projects that qualify as “Priority Development” projects.

Therefore, as specified in RCM HYD-3, the proposed project would adhere to prepare a WQMP pursuant to the guidance provided in the City’s Non-Priority Projects WQMP Preparation Guidance Manual (Non-Priority Manual).54 As stated in the Non-Priority Manual, the WQMP must incorporate structural and non-structural Source Control BMPs as well as Site Design BMPs. Source Control BMPs are preventative measures that are implemented to prevent the introduction of pollutants into stormwater, while Site Design BMPs are stormwater management strategies that emphasize conservation and use of existing site features to reduce the amount of runoff and pollutant loading generated from a site. The requirement to prepare a WQMP in conformance with the DAMP and LIP is also reiterated in Section 7.01 of the City’s Municipal Code. As specified in RCM HYD-4, the proposed project shall adhere to applicable provisions of Section 7.01 of the City’s Municipal Code, including WQMP and BMP requirements.

In addition, the City’s LIP requires development projects to comply with all applicable BMPs set forth in the area-wide DAMP. The DAMP is the principal guidance and compliance document for the countywide implementation of the Stormwater Program. It is the foundation for each Orange County Stormwater Permittee to implement programs designed to prevent pollutants from entering receiving waters to the maximum extent practicable. The City’s LIP provides the description and details of the City's water quality program implementation activities and provides examples of Source Control and LID BMP requirements for development projects, such as storm drain signage, street construction to minimum widths necessary, landscaping with native or drought tolerant species, and landscaped areas designed to infiltrate and/or treat runoff.55 As detailed in RCM HYD-1, the proposed project would be required to implement these features during project operations where applicable and feasible.

As mentioned previously, the Cannon Street Widening Improvement Project Foundation Report prepared by Earth Mechanics, Inc. (January 2024), groundwater was encountered in all borings at depths ranging from 16 to 25 feet below the proposed bridge grading during a field investigation. The maximum depth of excavation to construct project features is anticipated to reach approximately up to 40-ft bgs for cast-in-drilled hole (CIDH) piles associated with the new Santiago Creek Bridge and groundwater dewatering is not anticipated during project excavation and construction activities.

Further, construction impacts related to depletion of groundwater supplies or interference with groundwater recharge would be less than significant. No mitigation would be required. However, in the event that groundwater or perched groundwater is encountered during project construction, it would be necessary to obtain coverage under the Santa Ana RWQCB’s NPDES General Waste Discharge Requirements for Discharges to Surface Waters That Pose an Insignificant (De Minimis) Threat to Water Quality (Groundwater Discharge Permit), Order No. R8-2020-0006, NPDES No. CAG998001, as specified in RCM HYD-2. With adherence to RCM HYD-2, groundwater dewatering as a result of operational activities, would not introduce pollutants to receiving waters at levels that would violate water quality standards or water discharge requirements, degrade water quality, or alter the quality of the receiving water.
54 City of Orange. 2005. Non-Priority Projects WQMP Preparation Guidance Manual. December. Website:
https://www.cityoforange.org/home/showpublisheddocument/182/637698164909270000 (accessed April 25, 2024).
55 City of Orange. 2011. Storm Water Local Implementation Plan (LIP). July. Website: https://www.cityof orange.org/home/showpublisheddocument/500/637702460732200000 (accessed April 25, 2024). 703

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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-63 With implementation of RCM HYD-1 and RCM HYD-3, which requires adherence to City’s Local Implemental Plan and the MS4 Permit including implementing site design and source control LID BMPs where applicable to address pollutants of concern in stormwater runoff, impacts associated with the violation of water quality standards or waste discharge requirements, or degradation of surface water or groundwater quality, during project operation would be less than significant, and no mitigation is required.

Regulatory Compliance Measures
RCM HYD-1 City of Orange Local Implementation Plan. During and post-construction, the Construction Contractor shall comply with the City of Orange’s (City) Local Implementation Plan (LIP) prepared as part of a compliance program to satisfy the requirement of the area-wide Drainage Area Management Plan (DAMP) and the Santa Ana Regional Water Quality Control Board (RWQCB) municipal storm water permit issued to the City. The LIP outlines protocols for citywide projects to implement in order to contribute to regional stormwater pollution control efforts and adhere to the requirements of applicable National Pollutant Discharge Elimination System (NPDES) permits described above.

During construction, the Construction Contractor shall comply with appropriate pollution prevention control practices in accordance with the current edition of the “Green Book” Standard Specifications for Public Works Construction. The proposed project shall also implement Erosion and Sediment Control Plans (ESCPs) and Best Management Practices (BMPs) to manage the surface runoff from the construction site and prevent or reduce the discharge of pollutants directly or indirectly into surface waters consistent with the requirements of City’s LIP.

Post construction, the City shall ensure that all applicable BMPs set forth in the Orange County DAMP and the City’s LIP are being properly implemented, such as storm drain signage, landscaping with native or drought tolerant species, and landscaped areas designed to infiltrate and/or treat runoff.

RCM HYD-2 Groundwater Discharge Permit. If groundwater dewatering is required during construction of the proposed project, the City of Orange Public Works Department shall submit a Notice of Intent (NOI) for coverage under the permit to the Santa Ana RWQCB at least 60 days prior to the start of excavation activities and anticipated discharge of dewatered groundwater to surface waters in order to obtain coverage under the General Waste Discharge Requirements for Discharges to Surface Waters That Pose an Insignificant (De Minimis) Threat to Water Quality (Groundwater Discharge Permit), Order No. R8-2020-0006, NPDES No. CAG998001. The construction contractor shall comply with the requirements of Order No. R8-2020- 0006, NPDES No. CAG998001. Groundwater dewatering activities shall comply with all applicable provisions in the Groundwater Discharge Permit, including water sampling, analysis, treatment (if required), and reporting of dewatering-related discharges. Upon completion of groundwater dewatering activities, a Notice of Termination shall be submitted to the Santa Ana RWQCB.

RCM HYD-3 MS4 Permit. Prior to construction, the Construction Contractor shall prepare a Water Quality Management Plan (WQMP) using the City’s Non-Priority Projects WQMP 704

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4 \\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) -64 Preparation Guidance Manual (Non-Priority Manual), detailing the range of BMPs to be implemented as part of project operations, in accordance with the NPDES Permit and Waste Discharge Requirements for Discharges from the Municipal Separate Storm Sewer Systems (MS4s) Draining the Watersheds Within the Orange County Region, Order No. R8-2009-0030, NPDES No. CAS618030 as amended by Order No. R8- 2010-0062 (MS4 Permit). The City shall ensure the implementation of all applicable Source Control and Site Design BMPs included in the Non-Priority Manual. The City shall implement, maintain and operate all such BMPs in a timely and reasonably diligent manner.

RCM HYD-4 City of Orange Municipal Code Chapter 7.01. During and post-construction, the Construction Contractor shall comply with Section 7.01, Water Quality and Stormwater Discharge, of the City of Orange Municipal Code.

Prior to the issuance by the City of a grading permit, the Public Works Director shall review the project plans and impose terms, conditions and requirements as deemed necessary, which the proposed project shall comply with.

During construction, the Construction Contractor shall implement BMPs set forth in the WQMP, the Orange County DAMP, and the City’s Water Quality LIP in order to manage the surface runoff from the construction site and prevent or reduce the discharge of pollutants directly or indirectly into surface waters.

Post-construction, the City shall ensure that all applicable BMPs as identified under the WQMP are being properly implemented, such as storm drain signage, landscaping with native or drought tolerant species, and landscaped areas designed to infiltrate and/or treat runoff.

Overall, because the proposed project would be required to comply with existing regulations including the LIP, the DAMP, the Groundwater Discharge Permit, the MS4 Permit, and the City of Orange Municipal Code, as specified in RCM HYD-1 through RCM HYD-4, the proposed project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality. Impacts would be less than significant, and no mitigation is required.

Significance Determination: Less Than Significant Impact Mitigation Measures: No mitigation is required, but adherence to RCM HYD-1 through RCM HYD4 is required.

Significance Determination After Mitigation: Less Than Significant Impact b) Would the project substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
As mentioned previously, the Cannon Street Widening Improvement Project Foundation Report prepared by Earth Mechanics, Inc. (January 2024), groundwater was encountered in all borings at depths ranging from 16 to 25 feet below the proposed bridge grading during a field investigation. The maximum depth of excavation to construct project features is anticipated to reach approximately up to 40-ft bgs for cast-in-drilled hole (CIDH) piles associated with the new Santiago Creek Bridge and groundwater dewatering is not anticipated during project excavation and construction activities. In the 705

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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-65 event that groundwater or perched groundwater is encountered during project construction, it would be necessary to obtain coverage under the Santa Ana RWQCB’s NPDES General Waste Discharge Requirements for Discharges to Surface Waters That Pose an Insignificant (De Minimis) Threat to Water Quality (Groundwater Discharge Permit), Order No. R8-2020-0006, NPDES No. CAG998001, as specified in RCM HYD-2. Adherence to RCM HYD-2, groundwater dewatering as a result of construction and operational project activities would be required in order to avoid introducing pollutants to receiving waters at levels that would violate water quality standards or water discharge requirements, degrade water quality, or alter the quality of the receiving water.

Construction. Overall, construction of the proposed project would not generate a substantial demand for groundwater. As discussed in Response 4.10(a) above, the Cannon Street Widening Improvement Project Foundation Report prepared by Earth Mechanics, Inc. (January 2024) reported that groundwater was encountered in all borings at depths ranging from 16 to 25 feet below the proposed bridge grading during a field investigation. The maximum depth of excavation to construct project features is anticipated to reach approximately up to 40-ft bgs for cast-in-drilled hole (CIDH) piles associated with the new Santiago Creek Bridge. In the event that groundwater or perched groundwater is encountered during project construction, it would be necessary to obtain coverage under the Santa Ana RWQCB’s NPDES General Waste Discharge Requirements for Discharges to Surface Waters That Pose an Insignificant (De Minimis) Threat to Water Quality (Groundwater Discharge Permit), Order No. R8-2020-0006, NPDES No. CAG998001, as specified in RCM HYD-2, which sets forth procedures to follow that would reduce potential impacts related to groundwater dewatering to a less than significant level. In addition, if groundwater dewatering is required during construction of the proposed project, dewatering activities would be temporary, and the volume of groundwater removed would not be substantial. Please refer to Section 4.19, Utilities and Service Systems, for a detailed discussion of groundwater supply and demand. Therefore, construction of the proposed project would not substantially decrease groundwater supplies such that the project may impede sustainable groundwater management or recharge of the basin. Construction impacts associated with substantial decrease in groundwater supplies or interference with groundwater recharge would be less than significant, and no mitigation is required.

Operation. The proposed project would improve an existing roadway and would require minimal water service associated with irrigation of landscaped areas. As detailed in RCM HYD-1, the proposed project would be required to comply with all applicable BMPs set forth in the City’s LIP, which would require the use of native or drought tolerant species for landscaping within the median and curb areas, thus reducing the amount of water needed for irrigation. Under existing conditions, the project limits consist of a paved road and is predominantly comprised of impervious pavement. Therefore, the project limits are not considered a significant source of groundwater recharge. The addition of landscaped areas under the proposed project is expected to result in a net increase of pervious surface area of 0.1 acre.

Therefore, operation of the proposed project would not interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin.

For the reasons listed above, and with implementation of RCM HYD-2 if construction dewatering is required and RCM HYD-1 requiring BMPs such as the use of native or drought tolerant species in landscaped areas, impacts related to the decrease of groundwater supplies or interference with groundwater recharge would be less than significant, and no mitigation is required.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required, but adherence to RCM HYD-1 and RCM HYD-2 is required.
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4 \\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) -66 Significance Determination After Mitigation: Less Than Significant Impact c) Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
i. Result in substantial erosion or siltation on- or off-site? Construction. Under existing conditions, storm water from the project limits drains to various drainage features along each side of Cannon Street. Along the western edge of Cannon Street, stormwater from the project limits drains to one curb inlet south of Santiago Creek or three curb inlets north of Santiago Creek. Along the eastern edge of Cannon Street, storm water from the project limits drains to a V-ditch concrete channel south of Santiago Creek and one curb inlet north of Santiago Creek. This stormwater eventually discharges to the Santa Ana River and ultimately into the Pacific Ocean.

Construction activities associated with the proposed project would result in the total disturbance of 0.62 acre of soil. During grading and other construction activities, soil would be exposed and drainage patterns temporarily altered, and there would be an increased potential for soil erosion and siltation compared to existing conditions. Additionally, during a storm event, soil erosion and siltation could occur at an accelerated rate.

In compliance with RCM HYD-1, the proposed project would be subject to the construction-level requirements for public works construction projects not subject to the Construction General Permit set forth in the City’s LIP. According to the LIP, the proposed project shall comply with appropriate pollution prevention control practices in accordance with the current edition of the “Green Book” Standard Specifications for Public Works Construction and the provisions of Section A-8, and shall develop and implement ESCPs. The proposed project’s adherence to these requirements is specified in RCM HYD-1. Compliance with RCM HYD-1, which requires compliance with the LIP and implementation of construction BMPs and ESCPs, would ensure temporary impacts related to on- or off-site erosion or siltation would be less than significant.

Operation. After the completion of project construction, the proposed project would not significantly alter the existing drainage pattern of the site. Operation of the proposed project would provide safety and other travel improvements to existing roadway uses along Cannon Street or at Santiago Creek which would involve reconfigurations of existing pervious (i.e., landscaped areas) and impervious surfaces (i.e., roadway and median). As part of the proposed improvements, the general roadway alignment would remain the same, though widening and median/curb modifications would occur. These modifications would not significantly alter the existing drainage pattern of the project limits as existing drainage features would be realigned with the proposed As previously stated, implementation of the proposed project would result in a net increase of 0.1 acre of pervious surface area. This change would be expected to result in a potential net decrease in stormwater runoff. Further, compliance with the City’s LIP and MS4 Permit, as specified to RCM HYD-1 and RCM HYD-3, would require the proposed project to incorporate applicable BMPs pertaining to stormwater control and treatment to reduce the potential for erosion or siltation on- or off-site during operation of the proposed project. BMPs identified in the City’s LIP that are relevant to the proposed project include but are not limited to disconnection of impervious surfaces through distributed pervious areas, street trees, and efficient irrigation systems and landscape design. Through compliance with applicable regulations and incorporation of BMPs as required by RCM HYD-1 and RCM HYD-3, operational impacts related to on- or off-site erosion or siltation would be less than significant, and no mitigation is required. 707

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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-67 Significance Determination: Less than Significant Impact Mitigation Measures: No mitigation is required, but adherence to RCM HYD-1 and RCM-HYD-3 is required.

Significance Determination After Mitigation: Less than Significant Impact ii. Increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite;
Construction. The proposed project would comply with appropriate pollution prevention control practices in accordance with the current edition of the “Green Book” Standard Specifications for Public Works Construction and the provisions of Section A-8, and shall develop and implement ESCPs. The proposed project’s adherence to these requirements is specified in RCM HYD-1. The LIP also requires compliance with all applicable construction BMPs set forth in the Orange County DAMP and the City’s LIP. Under these requirements, fill slopes at the construction site perimeter must drain away from the top of the slope that the conclusion of each working day, which would reduce the volume of surface runoff beyond the project limits. With adherence to RCM HYD-1, construction impacts related to a substantial increase in the rate or amount of surface runoff that would result in on- or off-site flooding would be less than significant, and no mitigation is required.

Operation. Operation of the proposed project is expected to result in a slight increase in the pervious surface area within the project limits which could have the potential to slightly decrease the volume and rate of stormwater runoff discharged from the project limits. In the post-project condition, stormwater would continue to be directed to curb inlets along both outermost curbs of Cannon Street Drive and eventually discharge to the Pacific Ocean, similar to existing conditions. As specified in RCM HYD-3, the proposed project would be required to adhere to the City’s Non-Priority Manual, which provides guidance on feasible BMP requirements for developers of Non-Priority Development projects consistent with the MS4 Permit. In addition, as specified in RCM HYD-1, the proposed project would also be required to comply with all applicable BMPs set forth in the Orange County DAMP and the City’s LIP. As such, applicable BMPs would be appropriately incorporated and sized to accommodate the rate and amount of stormwater runoff in the post-project condition to prevent on- or off-site flooding. With implementation of BMPs in compliance with the MS4 Permit as required by RCM HYD-1 and RCM HYD-3, operation of the proposed project would not substantially increase the rate or amount of surface runoff in a manner that would result in flooding on- or off site. Impacts would be less than significant, and no mitigation is required Significance Determination: Less Than Significant Impact Mitigation Measures: No mitigation is required, but adherence to RCM HYD-1 and RCM HYD-3 is required.

Significance Determination After Mitigation: Less Than Significant Impact iii. Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or
Stormwater Drainage System Capacity. As previously stated, under existing conditions, stormwater from the project limits drains to various drainage features along each side of Cannon Street. Along the western edge of Cannon Street, stormwater from the project limits drains to one curb inlet south of Santiago Creek or three curb inlets north of Santiago Creek. Along the eastern edge of Cannon Street, storm water from the project limits drains to a V-ditch concrete channel south of Santiago Creek and 708

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4 \\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) -68 one curb inlet north of Santiago Creek. This stormwater eventually discharges to the Santa Ana River and ultimately into the Pacific Ocean.

As a co-permittee of the Santa Ana RWQCB, the City of Orange is responsible for ensuring that existing infrastructure is capable of supporting new development within the City. With implementation of the proposed project, any curb inlets affected by the proposed curb shift or road widening would be replaced along the new alignment to ensure that drainage properties within the project limits is not adversely affected. Therefore, the proposed project would not decrease the capacity of the existing stormwater drainage system through the permanent removal of any drainage facilities. As such, both outermost curbs of Cannon Street would continue to accommodate runoff water originating from the project limits. As previously discussed, the project limits currently consist of a roadway developed with predominantly impervious surface area and the proposed project would slightly increase the pervious surface area within the project limits in comparison to existing conditions. Therefore, the proposed project would not create additional runoff in excess of the City’s existing stormwater drainage system.

Polluted Runoff. As discussed in Response 4.10(a), pollutants of concern during construction include sediments, trash, petroleum products, concrete waste (dry and wet), sanitary waste, and chemicals, and each of these pollutants on its own or in combination with other pollutants can have a detrimental effect on water quality. Drainage patterns would be temporarily altered during grading and other construction activities, and construction-related pollutants could be spilled, leaked, or transported via storm runoff into adjacent drainages and downstream receiving waters. The proposed project would be required to contain runoff from construction equipment and vehicle washing within the project limits unless treated to remove sediment and other pollutants. As previously discussed, the proposed project must comply with City’s LIP, as specified in RCM HYD-1, which requires the adoption of all feasible and applicable ESCPs and BMPs presented in the Orange County DAMP and City’s LIP, and would ensure the proposed project would not discharge substantial sources of polluted runoff from the project limits during construction activities.

Expected pollutants of concern from long-term project operations include suspended solids/sediment, nutrients, oil and grease, metals, and trash and debris. As previously discussed, the proposed project’s compliance with City’s LIP and the MS4 Permit, as specified in RCM HYD-1, RCM HYD-3, and RCM HYD-4, which require the implementation of applicable BMPs to target pollutants of concern during operations of the proposed project, would ensure that the proposed project would not discharge substantial sources of polluted runoff from the project limits during project operations.

With compliance with applicable regulations, including the City’s LIP, MS4 Permit, and Municipal Code Section 7.01, as specified in RCM HYD-1, RCM HYD-3, and RCM HYD-4, impacts associated with creating or contributing runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff would be less than significant, and no mitigation is required.

Significance Determination: Less Than Significant Impact Mitigation Measures: No mitigation is required, but adherence to RCM HYD-1, RCM HYD-3, and RCM HYD-4 is required.

Significance Determination After Mitigation: Less Than Significant Impact iv. Impede or redirect flood flows?
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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-69 The project limits are not located within a Federal Emergency Management Agency (FEMA) designated 100-year floodplain. According to the FEMA Flood Insurance Rate Map (FIRM) No. 06059C0161J (Updated December 2021), the project limits are located within Zone X, Area of Minimal Flood Hazard. Because the project would not place improvements or structures directly within a 100- year floodplain, the project would not impede or redirect flood flows. Therefore, no impact would occur related to impeding or redirecting of flood flows, and no mitigation is required.

Significance Determination: No Impact
Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: No Impact
d) In flood hazard, tsunami, or seiche zones, would the project risk release of pollutants due to project inundation?
As discussed in Response 4.10(c)(iv), the project is not located within a 100-year flood hazard area and would therefore not risk release of pollutants during flooding as a result of a storm event. However, according to the Safety Element of the County of Orange General Plan (2010), the project limits are located within both the Santiago Reservoir Inundation Area and the Prado Dam Inundation Area.

Therefore, the potential for inundation of the project limits in the unlikely event of failure or Prado Dam or Santiago Dam cannot be ruled out. As stated in Section 4.9, Hazards and Hazardous Materials, potentially hazardous substances such as chemical agents, solvents, and paints would be used during construction. Potentially hazardous materials from routine project maintenance may also be used during operation of the proposed project. However, the amount of these chemicals present during project construction and operation is limited and would be in compliance with existing government regulations.

Therefore, in the unlikely event of inundation from Santiago Reservoir or Prado Dam, the proposed project would not increase the risk of release of pollutants, and a less than significant impact would occur. No mitigation is required.

Tsunamis are ocean waves generated by tectonic displacement of the seafloor associated with shallow earthquakes, seafloor landslides, rock falls, and exploding volcanic islands. Tsunamis can have wave lengths of up to 120 miles and travel as fast as 500 miles per hour (mph) across hundreds of miles of deep ocean. Upon reaching shallow coastal waters, the waves can reach up to 50 ft in height, causing great devastation to near-shore structures. The project limits are located approximately 11.5 miles from the Pacific Ocean shoreline and is not in a tsunami inundation area.56 Therefore, the project limits are not subject to inundation from tsunamis, and there is no risk of release of pollutants due to inundation from tsunami. No mitigation is required.

Seiching occurs when seismic ground shaking induces standing waves (seiches) inside water retention facilities (e.g., reservoirs and lakes). Such waves can cause retention structures to fail and flood downstream properties. Because there are no large lakes, reservoirs, or other water retention facilities in the vicinity of the project limits, the project limits are not subject to inundation from seiche waves, and there is no risk of release of pollutants due to inundation from seiche. No mitigation is required.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
56 California Department of Conservation (DOC). 2019. Orange County Tsunami Inundation Maps. Website:
https://www.conservation.ca.gov/cgs/tsunami/maps/orange (accessed April 19, 2024). 710

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The project is within the jurisdiction of the Santa Ana RWQCB. The Santa Ana RWQCB adopted a Water Quality Control Plan (i.e., Basin Plan) that designates beneficial uses for all surface and groundwater within their jurisdiction and establishes the water quality objectives and standards necessary to protect those beneficial uses. As summarized below, the project would comply with the applicable NPDES permits and would implement construction and operational BMPs to reduce pollutants of concern in stormwater runoff.

As discussed in Response 4.10(a), during construction activities, excavated soil would be exposed, and there would be an increased potential for soil erosion and sedimentation compared to existing conditions. In addition, chemicals, liquid products, petroleum products (e.g., paints, solvents, and fuels), and concrete-related waste may be spilled or leaked and have the potential to be transported via stormwater runoff into receiving waters. As specified in RCM HYD-1, the proposed project would be required to comply with appropriate pollution prevention control practices in accordance with the current edition of the “Green Book” Standard Specifications for Public Works Construction and the provisions of Section A-8, and shall develop and implement ESCPs.

As discussed in Response 4.10(a), the primary pollutants of concern during project operations are suspended solids/sediments, nutrients, heavy metals, pathogens (bacteria/virus), pesticides, oil and grease, and trash and debris. As discussed in RCM HYD-2 and RCM HYD-4, a final WQMP would be prepared as part of the City’s LIP for the project and in compliance with the North Orange County MS4 Permit as discussed in RCM-3. The final WQMP will detail the Site Design, the LID, and the Source Control and/or Treatment Control BMPs that would be implemented to treat stormwater runoff and reduce impacts to water quality during operation. The proposed biotreatment BMPs (stormwater planter boxes and trash filter) would treat stormwater runoff.

The proposed project would comply with applicable NPDES provisions, including preparation of a final WQMP, and includes implementation of construction and operational BMPs to reduce pollutants of concern in stormwater runoff. As such, the project would not result in water quality impacts that would conflict with Santa Ana RWQCB’s Basin Plan.

As discussed in Response 4.10(a), due to the depth to groundwater and the presence of a hard clay layer at a depth of 16 to 25 feet below proposed bridge grade, it is not expected that any stormwater that may infiltrate during construction would affect groundwater quality because there is not a direct path for pollutants to reach the groundwater table. In addition, the project would be required to implement operational BMPs to treat stormwater before it could reach groundwater. Lastly, it is unlikely that stormwater infiltration currently occurs within the project limits. However, any potential decrease in infiltration would be minimal in comparison to the size of the Coastal Plain of Orange County Groundwater Basin. Additionally, groundwater extraction would not occur during operation. Therefore, the proposed project does not have the potential to impact groundwater quality, interfere with groundwater recharge, or decrease groundwater supplies. For the reasons outlined above and with implementation of RCM HYD-1 through RCM HYD-4, a less than significant impact would occur related to conflict with or obstruction implementation of water quality control plans or sustainable groundwater management plans, and no mitigation is required. 711

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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-71 Significance Determination: Less Than Significant Impact Mitigation Measures: No mitigation is required, but adherence to RCM HYD-1 through RCM HYD4 is required.

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4.11 LAND USE AND PLANNING
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Physically divide an established community?
b) Cause a significant environmental impact due to a
conflict with any land use plan, policy, or regulation
adopted for the purpose of avoiding or mitigating an
environmental effect?
Impact Analysis
a) Would the project physically divide an established community? The physical division of an established community typically refers to the construction of a feature or removal of a means of access that would impair mobility within an existing community, or between a community and outlying areas.

In its existing condition, the project segment consists of approximately 0.6-mile of Cannon Street, classified as a Major Arterial Roadway by the City of Orange General Plan Circulation and Mobility Element.57 This roadway segment generally runs in the north-south orientation and eventually crosses into the City of Anaheim, thereby connecting the two cities. The proposed improvements to Cannon Street would improve roadway operations, thus contributing to the improvement of mobility between the two communities.

The project segment is located within a mostly developed portion of the City of Orange consisting of residential and recreational uses. Single-family residential neighborhoods border Cannon Street on both sides north of Santiago Creek. The residential neighborhood west of Cannon Street, north of Taft Avenue, is located in the City of Villa Park, while the remainder of adjacent residential uses are located within the City of Orange. South of Santiago Creek, undeveloped parcels owned by the County of Orange border the roadway. The proposed improvements to Cannon Street would not introduce a new physical barrier that would divide an existing community because the project limits already consist of Cannon Street, and proposed changes would be limited to improvements serving the existing roadway use. Further, the proposed project would occur within existing right-of-way of the City of Orange and the City of Villa Park and would not result in any changes to the existing configuration of adjacent parcels. Therefore, the proposed project would have less than significant impacts associated with access and mobility within the existing community and between the community and outlying areas, and no mitigation is required.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: Less Than Significant Impact 57 City of Orange. 2015. Orange General Plan Circulation and Mobility Element. Website: https://www.cityof orange.org/home/showpublisheddocument/192/637698172525970000 (accessed April 10, 2024). 713

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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-73 b) Would the project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
The Southern California Association of Governments (SCAG), the regional planning agency for the six-county Southern California region that includes Los Angeles, Orange, Riverside, San Bernardino, Ventura, and Imperial Counties, is responsible for preparing a regional growth forecast in conjunction with its efforts to prepare a Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) for its regional planning area. In April 2024, SCAG adopted an updated RTP/SCS (Connect SoCal 2024), which integrates regional transportation and land use considerations. Connect SoCal 2024 includes visions, policies, and performance measures that align with SCAG’s vision for future growth within the Southern California region. As shown in Table 4.11.A, the proposed project would be consistent with applicable policies set forth by SCAG in Connect SoCal 2024.

Table 4.11.A: 2024 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) Policy Consistency Analysis
Regional Planning Policy Consistency Analysis
Mobility Policy 01: Prioritize
repair, maintenance and
preservation of the SCAG
region's existing transportation
assets, following a "Fix-ItFirst" principle
Consistent. The proposed project would consist of modifications and improvements to an existing roadway in order to improve traffic operations rather than the development of a new roadway. Therefore, the proposed project is consistent with SCAG’s “Fix-It-First” principle, and would be consistent with Mobility Policy 01 of Connect SoCal 2024.

Complete Streets 03: Pursue
the development of Complete
Streets that comprise a safe,
multimodal network with
flexible use of public rights-ofway for people of all ages and abilities using a variety of
modes (e.g., people walking,
biking, rolling, driving, taking
transit)
Consistent. The proposed project consists of roadway enhancements that would improve traffic conditions for vehicular travel, as well as provide new right-of-way for pedestrian use. Under existing conditions, the bicycle lanes on southbound Cannon Street within the project limits are directly adjacent to vehicular travel lanes, which could present a potential safety hazard. The proposed project would introduce a degree of separation between vehicular traffic and bicyclists with the development of a new bridge serving southbound bicycle traffic, as well as both directions of pedestrian traffic. With this proposed separate bridge, the proposed project would promote a safer and more flexible multimodal network. As such, the proposed project would be consistent with Complete Streets Policy 03 of Connect SoCal 2024.

Complete Streets 04: Ensure
the implementation of
Complete Streets that are
sensitive to urban, suburban or
rural contexts and improve
transportation safety for all, but
especially for vulnerable road
users (e.g., people, especially
older adults and children,
walking and biking)
Consistent. As previously stated, the proposed project would introduce a degree of separation between vehicular traffic and pedestrians/bicyclists with the development of a new bridge serving southbound bicycle traffic and both directions of pedestrian traffic, which would improve transportation safety for every mode of travel. As such, the proposed project would be consistent with Complete Streets Policy 04 of Connect SoCal 2024.

Source: Southern California Association of Governments (SCAG). 2024. Connect SoCal: Regional Transportation Plan/Sustainable Communities Strategy. April 4. Website: https://scag.ca.gov/sites/main/files/file-attachments/23-2987-connect-socal-2024-final-complete040424.pdf?1714175547 (accessed July 18, 2024).

General Plan. The City of Orange General Plan is the City’s most fundamental planning document.

The General Plan establishes a vision for the City’s future growth and change, and contains goals and policies designed to provide decision-makers with a solid basis for decisions related to land use and development. It provides a blueprint for development throughout the community and is the vehicle 714

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The proposed project also would be required to comply with the City’s General Plan goals and policies addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. While these are mostly contained within the Circulation and Mobility Element, several other elements contain applicable goals and policies. Table 4.11.B provides a consistency analysis of the proposed project with the applicable goals and policies of the City’s General Plan. As indicated in Table 4.11.B, the proposed project is consistent with the applicable General Plan goals and policies. Impacts related to conflicts with a land use plan are less than significant, and no mitigation is required.

Table 4.11.B: General Plan Consistency Analysis
Goal Consistency Analysis
Land Use Element
Policy 6.6: Enhance the
walkability of both new and
current development.

Consistent. The proposed project would include the development of a new bridge structure just west of the existing vehicular bridge, which would carry two-way traffic for pedestrians and southbound traffic for bicyclists. By dedicating this new route exclusively to pedestrians and bicyclists, the proposed project would enhance the walkability of Cannon Street within the project limits. As such, the proposed project would be consistent with Policy 6.6 of the City’s General Plan Land Use Element.

Policy 7.3: Coordinate
planning efforts with
adjacent cities, special
purpose agencies, utilities,
and community service
providers.

Consistent. As discussed in Section 2.0, Project Description, a portion of the proposed widening efforts would occur within the City of Villa Park’s jurisdiction. As such, the City of Orange has been coordinating with the City of Villa Park and will continue coordination efforts. Additionally, because the proposed project could potentially result in traffic signal and street lighting conflicts, the City of Orange will also coordinate with the appropriate utility providers. As such, the proposed project would be consistent with Policy 7.3 of the City’s General Plan Land Use Element.

Urban Design Element
Policy 1.1: Enhance the
streetscape along the City’s
major commercial corridors
and other major streets
through coordinated public
and private improvements to
convey a positive image of
the district, contribute to its
economic vitality and
perception of the City, and
improve visual and physical
transitions into adjacent
neighborhoods. Streetscape
designs should include wide
sidewalks to accommodate
unified landscaping, trees,
lighting, paving, street
furniture, and other public
improvements appropriate
to the scale of the streets.

Consistent. As stated in Section 2.0, Project Description, the project limits are designated as a Major Arterial roadway in the City’s Circulation and Mobility Element. The proposed project would enhance the Cannon Street streetscape within the project limits by introducing new landscaped median and curb areas containing visually appealing trees, shrubs, boulders, and other design elements. In addition, the proposed project would include a pedestrian bridge fitted with architecturally advanced prefabricated steel truss accents, which would enhance the visual appeal of the proposed bridge. As such, the proposed project would be consistent with Policy 1.1 of the City’s General Plan Urban Design Element.

Policy 1.3: Ensure that
streetscape improvements
provide for an environment
that offers a pleasant
experience for motorists,
pedestrians, and transit
riders.

Consistent. As previously stated, the proposed project would enhance the Cannon Street streetscape within the project limits by introducing new landscaped median and curb areas containing visually appealing trees, shrubs, boulders, and other design elements. These improvements would be experienced by all users of the roadway including vehicles, pedestrians, and bicyclists. Further, the proposed pedestrian bridge would enhance the pedestrian and vehicular experience through its visually appealing architectural design. As such, the proposed project would be consistent with Policy 1.3 of the City’s General Plan Urban Design Element.
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Goal Consistency Analysis
Policy 4.3: Create an
attractive, walkable
pedestrian environment
within and between
commercial districts and
neighborhoods through
careful site planning,
architectural design, and
provision of pedestrian
amenities such as sidewalks,
benches, plaza areas,
information kiosks, and
other street furniture.

Consistent. The project limits are located adjacent to several single-family residential neighborhoods. As previously stated, the proposed project would improve the walkability of the project limits with the development of a new bridge structure over Santiago Creek specifically dedicated to pedestrians and bicyclists. Further, the architectural design of the proposed pedestrian bridge would include visually appealing prefabricated steel truss accents.

As such, the proposed project would be consistent with Policy 4.3 of the City’s General Plan Urban Design Element.

Infrastructure Element
Policy 3.3: Continue to
design, install, and maintain
signals, signage, street
lights, and traffic control
devices within rights-ofway.

Consistent. As discussed in Section 2.0, Project Description, the improvements proposed under the project would necessitate a traffic signal modification at Taft Avenue, which would be included under the proposed project. In addition, the proposed project may result in traffic signals and street lighting relocations, the replacements of which would be strategically located within the project limits. As such, the proposed project would be consistent with Policy

3.3 of the City’s General Plan Infrastructure Element.

Policy 3.5: Preserve and
improve existing on-street
bike paths within rights-ofway.

Consistent. As previously stated, the proposed project would include the development of a new bridge structure across Santiago Creek just west of the existing vehicular bridge, which would carry two-way traffic for pedestrians and southbound traffic for bicyclists. As such, the proposed project would introduce a physical barrier between bicyclist traffic and vehicular traffic, which would improve bicyclist safety. Therefore, the proposed project would mark an improvement of existing bike paths within the project limits, and would be consistent with Policy 3.5 of the City’s General Plan Infrastructure Element.

Noise Element
Policy 2.3: Encourage the
use of alternative
transportation modes such
as walking, bicycling, mass
transit, and alternative fuel
vehicles to minimize traffic
noise.

Consistent. As discussed throughout this IS/MND, one of the improvements under the proposed project would be a new bridge structure crossing over Santiago Creek, just west of the existing vehicular bridge. The proposed bridge would be specifically dedicated to southbound bicyclist traffic and both directions of pedestrian traffic. These improved bicyclist and pedestrian conditions would encourage more users of the roadway to opt for these alternative modes of transportation. As such, the proposed project would be consistent with Policy 2.3 of the City’s General Plan Noise Element.

Policy 7.1: Schedule City
maintenance and
construction projects so that
they generate noise during
less sensitive hours.

Consistent. Please refer to Section 4.13, Noise, for a detailed analysis of the proposed project’s potential impacts as they pertain to noise. As stated in Section 4.13, the proposed project’s compliance with Regulatory Compliance Measure (RCM) NOI-1 would ensure that construction noise is limited to between the hours of 7:00 a.m. and 8:00 p.m. Monday through Friday and between the hours of 8:00 a.m. and 8:00 p.m. on Saturday. Construction is prohibited outside these hours and on Sundays and federal holidays. As such, construction of the proposed project would not generate substantial noise during sensitive hours. As such, the proposed project would be consistent with Policy 7.1 of the City’s General Plan Noise Element.
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Goal Consistency Analysis
Public Safety Element
Policy 9.1: Enhance and
maintain safe pedestrian and
bicycle movement through
the integration of traffic
control devices, crosswalks,
and pedestrian-oriented
lighting, into the design of
streets, sidewalks, trails, and
school routes throughout
Orange.

Consistent. As previously stated, the proposed project would introduce a new pedestrian and bicyclist-oriented bridge structure adjacent to the existing vehicular bridge, which would physically separate these alternative modes of transportation from vehicular traffic and thus improve safety. In addition, the proposed bridge structure would include adequate lighting features to ensure safe passage during nighttime hours. As such, the proposed project would be consistent with Policy 9.1 of the City’s General Plan Public Safety Element.

Policy 9.2: Support creation
of safe routes that encourage
children to walk or bike to
schools and recreational
facilities.

Consistent. As previously stated, the proposed project is located adjacent to single-family residential neighborhoods. Linda Vista Elementary School is located approximately 0.14 mile south of the project limits at 1200 N. Cannon Street. Therefore, it is reasonable to assume that school-age children residing within the surrounding neighborhoods may utilize the pedestrian and bicyclist facilities within the project limits to reach Linda Vista Elementary School, other schools, or recreational facilities because the proposed project would enhance the safety of pedestrians and bicyclists within the project limits by physically separating them from vehicular traffic and routing them on the proposed separate bridge crossing over Santiago Creek. As such, the proposed project would be consistent with Policy 9.2 of the City’s General Plan Public Safety Element.

Policy 9.3: Identify and
attempt to remove
impediments to pedestrian
and bicycle access including
those associated with rail,
street, freeway, and
waterway crossings and
poorly marked or
maintained pathways and
sidewalks.

Consistent. As previously stated, pedestrians and bicyclists utilizing Cannon Street under existing conditions share the existing bridge overcrossing with vehicular traffic. The proposed project would provide a separate bridge exclusively for bicycle and pedestrian use, which would improve mobility for these forms of transportation across the Santiago Creek waterway.

As such, the proposed project would be consistent with Policy 9.3 of the City’s General Plan Public Safety Element.

Growth Management Element
Policy 1.7: Promote the
expansion and development
of alternative methods of
transportation.

Consistent. The separate pedestrian and bicyclist bridge adjacent to the existing vehicular bridge would represent an expansion of pedestrian and bicyclist facilities within the project limits as they currently utilize the same bridge as vehicular traffic. This expansion would encourage increased alternative transportation (i.e., bicycle use and walking) along the project limits. As such, the proposed project would be consistent with Policy 1.7 of the City’s General Plan Growth Management Element.

Circulation Element
Policy 1.1: Plan, build, and
maintain an integrated,
hierarchical, and multimodal system of roadways,
pedestrian walkways, and
bicycle paths throughout the
City.

Consistent. The proposed project represents the maintenance and improvement of an existing roadway, Cannon Street, within the City’s circulation network. Through the proposed pedestrian/bicyclist bridge development, the proposed project would also integrate an improved pedestrian walkway and bicycle path within the project limits. As such, the proposed project would be consistent with Policy 1.1 of the City’s General Plan Circulation Element.

Policy 1.2: Identify key
intersections and streets
with historical or projected
traffic congestion problems
and apply creative traffic
management measures to
improve overall circulation.

Consistent. Please refer to Section 4.17, Transportation, for a detailed description of existing circulation conditions within the project limits. According to Section 4.17, there are several identified traffic congestion problems within the project limits, including an insufficient LOS (LOS E) operation of the Cannon Street/Taft Avenue intersection in the p.m. peak hour and turning lane queue spillover along northbound Cannon Street as it intersects with Serrano Avenue. As stated in Section 2.0, Project Description, the proposed project would function as an auxiliary lane to improve traffic conditions within the roadway, which could include the two congestion problems identified previously. As such, the proposed project would be consistent with Policy 1.2 of the City’s General Plan Circulation Element. 717

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Goal Consistency Analysis
Policy 4.4: Encourage use
of the bikeway system by
providing adequate signage,
trail markings, and other
amenities.

Consistent. The proposed pedestrian bridge would maintain connectivity between Cannon Street and the Santiago Creek Trail and the staging area and provide a separate facility for bicyclists and pedestrians over Santiago Creek.

Policy 4.5: Ensure that
pedestrian sidewalks, trails,
and bikeways are safe
environments through the
use of crime preventionoriented trail design
features, lighting where
appropriate, pedestrian and
bicycle safety
improvements at at-grade
rail crossings, access for
emergency vehicles, and
links to the roadway signal
system.

Consistent. The new pedestrian and bicyclist bridge proposed under the project would improve safety for those opting for these modes of transportation by physically separating them from vehicular traffic. Further, the proposed bridge structure would contain adequate guardrails and lighting fixtures to ensure the safety of those utilizing the bridge. As such, the proposed project would be consistent with Policy 4.5 of the City’s General Plan Circulation Element.

Source: Orange General Plan (City of Orange 2010).

Zoning Ordinance. Title 17 (Zoning Ordinance) of the City’s Municipal Code is the primary implementation tool for the General Plan Land Use Element and the goals and policies contained therein. For this reason, the Zoning Map must be consistent with the General Plan Land Use Map. The Land Use Policy Map indicates the general location and extent of future land use in the City. The Zoning Ordinance, which includes the Zoning Map, contains more detailed information about permitted land uses, building intensities, and required development standards.

Since the project limits consist of a roadway, the proposed project does not belong to a zone established by the City. As discussed in Section 2.0, Project Description, the zoning of parcels directly adjacent to the project limits includes Sand and Gravel Extraction District and Single Family Residential: 8,000 square feet (R-1-8).58 The proposed project would involve the continuation and improvement of an existing roadway land use and does not propose any new land uses that would conflict with the zoning of adjacent parcels. Therefore, the proposed project would be consistent with the City’s Zoning Code, and no mitigation is required.

Summary. The proposed project is consistent with the City’s General Plan and all other applicable land use documents pertaining to circulation systems. Because part of the project limits border the City of Villa Park, the City of Orange will engage in coordination efforts to ensure that the proposed project is consistent with all applicable land use documents set forth by the City of Villa Park. Therefore, the proposed project would result in less than significant impacts related to conflicts with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. No mitigation would be required.
58 City of Orange. 2020. Zoning Map. September. Website: https://www.cityoforange.org/home/show publisheddocument/40/637707607413300000 (accessed April 10, 2024). 718

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Significance Determination After Mitigation: Less Than Significant Impact 719

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4.12 MINERAL RESOURCES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Result in the loss of availability of a known mineral resource that would be of value to the region and the
residents of the state?
b) Result in the loss of availability of a locallyimportant mineral resource recovery site delineated on a local general plan, specific plan or other land use plan?
Impact Analysis
a) Would the project result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
In 1975, the California Legislature enacted the Surface Mining and Reclamation Act (SMARA), which, among other things, provided guidelines for the classification and designation of mineral lands. Areas are classified on the basis of geologic factors without regard to existing land use and land ownership.

The areas are categorized into four Mineral Resource Zones (MRZs):
• MRZ-1: An area where adequate information indicates that no significant mineral deposits are present, or where it is judged that little likelihood exists for their presence. • MRZ-2: An area where adequate information indicates that significant mineral deposits are present, or where it is judged that a high likelihood exists for their presence. • MRZ-3: An area containing mineral deposits, the significance of which cannot be evaluated. • MRZ-4: An area where available information is inadequate for assignment to any other MRZ zone.

Of the four categories, lands classified as MRZ-2 are of the greatest importance. Such areas are underlain by demonstrated mineral resources or are located where geologic data indicate that significant measured or indicated resources are present. MRZ-2 areas are designated by the State of California Mining and Geology Board as being “regionally significant.” Such designations require that a Lead Agency’s land use decisions involving designated areas are to be made in accordance with its mineral resource management policies and that it considers the importance of the mineral resource to the region or the State as a whole, not just to the Lead Agency’s jurisdiction.

According to a map of aggregate mineral resources published by the California Department of Conservation, Division of Mines and Geology, now known as the California Geological Survey (CGS),59 the project limits exist within Plate 4 of the Orange County-Temescal Valley Production/ Consumption Region, which is classified as 'Designated Areas Urbanized'. This map shows the project 59 Miller, R.V. 1995. Update of Mineral Land Classification of Portland Cement Concrete Aggregate in Ventura, Los Angeles, and Orange Counties, California, Part III - Orange County. 720

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4 \\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) -80 limits as being located within an MRZ-2 zone, or a zone where adequate information indicates the presence of significant mineral deposits. This classification is consistent with the City’s General Plan Natural Resources Element, which states that mineral resources within the City are primarily limited to the sand and gravel resources contained near the Santa Ana River and Santiago Creek. 60 Cannon Street
provides an above-grade crossing over Santiago Creek within the project limits, which would explain the potential presence of aforementioned sand and gravel resources.

As previously stated, the proposed project consists of the addition of a third northbound lane and new pedestrian bridge to the existing Cannon Street roadway, which would involve widening and repavement efforts. The project proposes to improve traffic operations of an existing roadway and does not propose any new land uses that would result in the extraction or loss of mineral resources. Further, these improvements would occur above-grade from Santiago Creek, and do not propose to encroach upon the waterway or its potential mineral deposits.

Under the proposed project, the Santiago Creek riverbed would not experience the loss of availability of any known mineral resource that is valuable to the region or the State residents. Therefore, impacts related to mineral resources would be less than significant, and no mitigation is required.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: Less Than Significant Impact b) Would the project result in the loss of availability of a locally-important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan? While the California Department of Conservation Division of Mine Reclamation Mines Online (MOL) interactive map
61 does not show any mines within the City of Orange, the United States Geological Survey (USGS) online Mineral Resources Data System (MRDS) map62 shows two D-level records of past mines located within an 0.5-mile radius of the project limits. MRDS records are classified from A to E based on completeness and consistency, indicating that D-level records are poor in both aspects.

Regardless, these records show that two former mines existed within the project limits’ proximity:
• Gravel Pit: 600 feet west of the project limits; formerly providing sand and gravel for construction uses.
• R.C. 1 Orange Plant: 0.44 mile east of the project limits; providing sand and gravel for construction uses.
60 City of Orange. 2015. Orange General Plan Natural Resources Element. Website: https://www.cityof orange.org/home/showpublisheddocument/210/637698172559270000 (accessed February 5, 2024). 61 California Department of Conservation Division of Mine Reclamation. 2016. Mines Online. Website:
https://maps.conservation.ca.gov/mol/index.html (accessed February 6, 2024). 62 United States Geological Survey (USGS). 2011. Mineral Resources Data System (MRDS). Website:
https://mrdata.usgs.gov/mrds/ (accessed February 6, 2024). 721

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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-81 While the Gravel Pit is categorized as a “Past Producer” and is therefore no longer operational, the R.C. 1 Orange Plant is considered a current producer of aggregate materials for construction-related uses.

However, due to its distance from the project limits, this mine would not be affected by the proposed project. Therefore, the proposed project is not located within the immediate vicinity of a locally important mineral resource recovery site, and would not result in the loss of availability of any such sites. Therefore, impacts related to locally important mineral resource recovery sites would be less than significant, and no mitigation is required.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: Less Than Significant Impact 722

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4.13 NOISE
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project result in:
a) Generation of a substantial temporary or permanent
increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable
standards of other agencies?
b) Generation of excessive groundborne vibration or
groundborne noise levels?
c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within 2 miles of a public airport or public use airport, would the project expose people
residing or working in the project area to excessive
noise levels?
The following section is based on information presented in the Noise and Vibration Impact Analysis Memorandum (Noise Memo) prepared for the proposed project in April 2024, which is included as Appendix E to this IS/MND.

Technical Background
The following provides an overview of the characteristics of sound and the regulatory framework that applies to noise within the vicinity of the project limits.

Characteristics of Sound
Noise is usually defined as unwanted sound. Noise consists of any sound that may produce physiological or psychological damage and/or interfere with communication, work, rest, recreation, or sleep. Several noise measurement scales exist that are used to describe noise in a particular location. A decibel (dB) is a unit of measurement that indicates the relative intensity of a sound. Sound levels in decibels are calculated on a logarithmic basis. An increase of 10 dB represents a tenfold increase in acoustic energy, while 20 dB is 100 times more intense, and 30 dB is 1,000 times more intense. Each 10 dB increase in sound level is perceived as approximately a doubling of loudness; similarly, each 10 dB decrease in sound level is perceived as half as loud. Sound intensity is normally measured through the A-weighted sound level (dBA). This scale gives greater weight to the frequencies of sound to which the human ear is most sensitive. The A-weighted sound level is the basis for 24-hour sound measurements, which better represent how humans are more sensitive to sound at night. Ambient sounds generally range from 30 dB (very quiet) to 100 dB (very loud).

Sound levels are generated from a source, and their decibel level decreases as the distance from that source increases. Sound dissipates exponentially with distance from the noise source. For a single point source, sound levels decrease approximately 6 dB for each doubling of distance from the source. This drop-off rate is appropriate for noise generated by stationary equipment. If noise is produced by a line source (e.g., highway traffic or railroad operations), the sound decreases 3 dB for each doubling of 723

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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-83 distance in a hard site environment; however, line source noise in a relatively flat environment with absorptive vegetation decreases 4.5 dB for each doubling of distance.

There are many ways to rate noise for various time periods, but an appropriate rating of ambient noise affecting humans also accounts for the annoying effects of sound. The equivalent continuous sound level (Leq) is the total sound energy of time-varying noise over a sample period. However, the predominant rating scales for human communities in the State of California are the Leq, the community noise equivalent level (CNEL), and the day-night average level (Ldn) based on A-weighted decibels. CNEL is the time-varying noise over a 24-hour period, with a 5 dBA weighting factor applied to the hourly Leq for noises occurring from 7:00 p.m. to 10:00 p.m. (defined as relaxation hours), and a 10 dBA weighting factor applied to noises occurring from 10:00 p.m. to 7:00 a.m. (defined as sleeping hours). Ldn is similar to the CNEL scale but without the adjustment for events occurring during the evening hours. CNEL and Ldn are within 1 dBA of each other and are normally interchangeable.

The City of Orange uses the CNEL noise scale for long-term noise impact assessment.

Other noise rating scales of importance when assessing the annoyance factor include the maximum instantaneous noise level (Lmax), which is the highest exponential time-averaged sound level that occurs during a stated time period. The noise environments discussed in this analysis for short-term noise impacts are specified in terms of maximum levels denoted by Lmax, which reflects peak operating conditions and addresses the annoying aspects of intermittent noise.

Noise impacts can be described in three categories. The first category includes audible impacts that refer to increases in noise levels noticeable to humans. Audible increases in noise levels generally refer to a change of 3 dB or greater because this level has been found to be barely perceptible in exterior environments. The second category, potentially audible, refers to a change in the noise level between 1 dB and 3 dB. This range of noise levels has been found to be noticeable only in laboratory environments.

The last category includes changes in noise levels of less than 1 dB, which are inaudible to the human ear. Only audible changes in existing ambient or background noise levels (3 dB or greater) are considered potentially significant.

Characteristics of Vibration
Vibration refers to ground-borne noise and perceptible motion. Ground-borne vibration is almost exclusively a concern inside buildings and is rarely perceived as a problem outdoors where the motion may be discernible. However, without the effects associated with the shaking of a building, there is less adverse reaction. Vibration energy propagates from a source through intervening soil and rock layers to the foundations of nearby buildings. The vibration then propagates from the foundation throughout the remainder of the structure. Building vibration may be perceived by occupants as motion of building surfaces, the rattling of items on shelves or hanging on walls, or a low-frequency rumbling noise. The rumbling noise is caused by the vibrating walls, floors, and ceilings radiating sound waves. Building damage is not a factor for normal operation and construction activities with the occasional exception of blasting and pile driving during construction.

Typical sources of ground-borne vibration are construction activities (e.g., blasting, pile driving, and operating heavy-duty earthmoving equipment), steel-wheeled trains, and occasional traffic on rough roads. Impacts with ground-borne vibration and noise from these sources are usually localized to areas within approximately 100 feet of the vibration source, although there are examples of ground-borne vibration causing interference out to distances greater than 200 feet (Federal Transit Administration 724

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4 \\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) -84 [FTA] Transit Noise and Vibration Impact Assessment Manual (FTA Manual).63 When roadways are smooth, vibration from traffic, even heavy trucks, is rarely perceptible. For most projects, it is assumed that the roadway surface will be smooth enough that ground-borne vibration from street traffic will not exceed the impact criteria; however, construction activities have the potential to result in ground-borne vibration that could be perceptible and annoying. Ground-borne noise is not likely to be a problem because noise arriving via the normal airborne path usually will be greater than ground-borne noise.

Ground-borne vibration has the potential to disturb people as well as damage buildings. Although it is very rare for ground-borne vibration to cause even cosmetic building damage, it is not uncommon for construction processes such as blasting and pile driving to cause vibration of sufficient amplitudes to damage nearby buildings (FTA 2018). Ground-borne vibration is usually measured in terms of vibration velocity, either the root-mean-square (RMS) velocity or peak particle velocity (PPV). RMS is best for characterizing human response to building vibration, and PPV is used to characterize the potential for damage. Decibel notation acts to compress the range of numbers required to describe vibration.

Vibration velocity level in decibels is defined as:

LV = 20 log10 [V/Vref]
where LV is the velocity in decibels (VdB), “V” is the RMS velocity amplitude, and “Vref” is the reference velocity amplitude, or 1 x 10-6 inches per second (in/sec) used in the United States.

Applicable Noise Standards
The applicable noise standards governing the project limits include the criteria in the City of Orange General Plan Noise Element and Section 8.24 of the City of Orange Municipal Code.

City of Orange
General Plan Noise Element. The City of Orange General Plan Noise Element64 has established noise standards for various land uses and has goals and policies to meet the City’s noise-related goals. The City’s exterior noise standard for residential uses is 65 dBA CNEL. Applicable goals and policies for the project are listed below:
• Goal 7.0: Minimize construction, maintenance vehicle, and nuisance noise in residential areas and near noise-sensitive land uses.
○ Policy 7.1: Schedule City maintenance and construction projects so that they generate noise during less sensitive hours.
○ Policy 7.2: Require developers and contractors to employ noise minimizing techniques during construction and maintenance operations.
63 Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment Manual. FTA Report No. 0123. September. Website: https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/researchinnovation/118131/transit-noise-and-vibration-impact-assessment-manual-fta-report-no-0123_0.pdf (accessed March 2024).
64 City of Orange. 2015. Orange General Plan Noise Element. December. Website: https://www.cityof orange. org/home/showpublisheddocument/212/637698172563500000 (accessed April 8, 2024). 725

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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-85 ○ Policy 7.3: Limit the hours of construction and maintenance operations located adjacent to noise-sensitive land uses.
○ Policy 7.4: Encourage limitations on the hours of operations and deliveries for commercial, mixed-use, and industrial uses abutting residential zones.

City of Orange Municipal Code. The City addresses noise in Chapter 8.24, Noise Control, of the Municipal Code. Section 8.24.050(E) of the City’s Municipal Code exempts construction, repair, remodeling, or grading of any real property between the hours of 7:00 a.m. and 8:00 p.m., Monday through Saturday, or between the hours of 9:00 a.m. to 8:00 p.m. on Sundays and federal holidays.

In addition, Section 8.24.050(K) of the Municipal Code exempts any maintenance or construction activity undertaken by a public agency or utility within street right-of-way.

City of Villa Park
Because the residential neighborhood west of Cannon Street, north of Taft Avenue, is located in the City of Villa Park, its noise standards would also be relevant to the proposed project.

General Plan Noise Element. The City of Villa Park General Plan Noise Element65 has established the acceptable noise levels for noise-sensitive land uses and has goals and policies to meet the City’s noise-related goals. Noise-sensitive land uses include residences, rest homes, hospitals, places of worship, and schools. The City’s acceptable noise level for noise-sensitive land uses is 60 dBA CNEL. Applicable goals and policies for the project are listed below:
• Noise Goal #1: Continue to provide acceptable noise environments for residential land use. ○ Policy N #1: Continue to apply noise considerations into the community planning process to prevent noise/land use conflicts.
○ Policy N #2: Minimize through traffic in residential areas by promoting peripheral routing. ○ Policy N #3: Promote, where appropriate, sound attenuation measures. These may include the use of berms and wall barriers, the placement of buildings away from the noise source, or a combination of sound attenuation measures.

City of Villa Park Municipal Code. Section 6-6.7(e) of the City of Villa Park Municipal Code exempts construction, repair, remodeling, or grading of any real property between the hours of 7:00 a.m. and 8:00 p.m., Monday through Friday or between the hours of 8:00 a.m. to 8:00 p.m. on Saturday. Construction is prohibited on Sunday or on a federal holiday.

Existing Noise Environment
The primary existing noise sources in the project area are transportation facilities. Traffic on Cannon Street, Serrano Avenue, Taft Avenue, and Santiago Canyon Road is a steady source of ambient noise 65 City of Villa Park. 2010. Villa Park General Plan Noise Element. Website: http://villapark.org/Portals/0/ Documents/Departments/Planning/General%20Plan/Noise%20Element/VII.%20Noise.pdf?ver=SeS8ZAY Puu6mBDm4nrU4Vw%3d%3d&timestamp=1712616513224 (accessed April 8, 2024). 726

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4 \\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) -86 in the project vicinity. Uses located adjacent to the project include residential uses, a parking lot for the Santiago Creek Trail and Bike Path, a pump station site, and a former landfill (vacant land).

Existing Noise Level Measurements
Two long-term (24-hour) noise level measurements were conducted within the limits of the project limits using Larson Davis Spark 706RC dosimeters to document the existing noise environment. The long-term noise level measurements at LT-1 were conducted from Thursday, February 22, to Friday, February 23, 2024, and at LT-2 were conducted from Tuesday, March 19, to Wednesday, March 20, 2024. Please refer to Figure 4.13-1, Noise Monitoring Locations, for the locations of LT-1 and LT-2 within the project limits. Table 4.13.A summarizes the results of the long-term noise level measurements along with a description of the measurement locations and noise sources that occurred during the measurements.

Table 4.13.A: Long-Term Ambient Noise Level Measurements Monitoring
No. Location Description
Noise Levels (dBA)
Daytime1 Evening2 Nighttime3 Noise Sources CNEL Leq Lmax Leq Lmax Leq Lmax LT-1
1854 N Carlsbad Street,
Orange, CA. Near the
center of a backyard on
a tree.

55.6-

60.1 69.2-

80.5 54.7-

55.7 68.4-

70.5 43.5-

55.4 59.5-

69.0 59.2
Traffic on
Cannon Street.

LT-2
1732 N Williamsburg
Street, Orange, CA. In
the backyard.

55.3-

58.1 67.3-

79.6 52.5-

55.6 69.5-

76.0 42.3-

57.6 57.8-

77.5 58.8
Traffic on
Cannon Street.

Source: Compiled by LSA (2024).
1 Daytime = Hours between 7:00 a.m. and 7:00 p.m.
2 Evening = Hours between 7:00 p.m. and 10:00 p.m.
3 Nighttime = Hours between 10:00 p.m. and 7:00 a.m.

CNEL = Community Noise Equivalent Level
dBA = A-weighted decibel(s)
Leq = equivalent continuous sound level
Lmax = maximum instantaneous noise level
Existing Traffic Noise Contours
The Federal Highway Administration (FHWA) Highway Traffic Noise Prediction Model (FHWA RD77-108) was used to evaluate existing traffic-related noise conditions in the vicinity of the project limits.

This model requires various parameters (including traffic volumes, vehicle mix, vehicle speed, and roadway geometry) to compute typical equivalent noise levels during daytime, evening, and nighttime hours. The resultant noise levels are weighted and summed over 24-hour periods to determine the CNEL values. The existing average daily traffic (ADT) volumes were obtained from the Traffic Assessment Memo, included as Appendix F to this IS/MND. The standard vehicle mix for Southern California roadways was used for traffic on these roadway segments. Table 4.13.B provides the existing traffic noise levels adjacent to roadway segments in the project vicinity. These noise levels represent worst-case scenarios, which assume that no shielding is provided between the traffic and the locations where the noise contours are drawn.
727
City of Villa Park
City of Orange
C
a
n
n
o
n
St
E Taft Ave
N Modoc St
N Yurok St
E Shoshone Ave
E Crater Lake Ave
Serrano Ave
E Santiago Canyon Rd
E Mountain
Ave
E Bryce Ave
Leatrice Dr
Mabury Ave
N Zion St
N Chumash St
Crestview Cir
E Brookside Ave
Carpenter Cir
N
Ca
rlsbad St
La
rso
n
Ci
r
Santiago Blvd
N Cabrillo St
E Playano Ave
Parker Cir
E Lakeside Ave
E Hillside Ave
N Williamsburg St
N Pala Pl
N Klamath Pl
E Valencia Dr
Serrano Ave
E Santiago Canyon Rd
LT-2
LT-1
SOURCE: Nearmap (5/2023)
J:\20230893\GIS\Pro\Cannon Street Widening Project.aprx (4/25/2024) FIGURE 4.13-1
Cannon Street Widening Project 0 200 400
FEET
Project Location
City Boundaries
Long-Term Noise Monitoring Locations
Noise Monitoring Locations
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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-89 Table 4.13.B: Existing Traffic Noise Levels
Roadway Segment ADT
Centerline
to
70 CNEL
(ft)
Centerline
to
65 CNEL
(ft)
Centerline
to
60 CNEL
(ft)
CNEL (dBA)
50 ft from
Roadway
Centerline
Cannon Street between Serrano
Avenue and Taft Avenue 33,096 81 167 356 72.8
Cannon Street between Taft Avenue
and Santiago Canyon Road 30,297 76 157 335 72.5
Source: Compiled by LSA (2024).

Note: Traffic noise within 50 ft of the roadway centerline should be evaluated with site-specific information.

ADT = average daily traffic
CNEL = Community Noise Equivalent Level
dBA = A-weighted decibels
ft = foot/feet
Impact Analysis
a) Would the project result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? Short-Term Construction Noise Impacts. Two types of short-term noise impacts would occur during construction of the proposed project. The first type would be from construction crew commutes and the transport of construction equipment and materials to the project limits and would incrementally raise noise levels on roadways leading to the site. The pieces of construction equipment for construction activities would move on site, would remain for the duration of each construction phase, and would not add to the daily traffic volume in the project vicinity. Although there would be a relatively high singleevent noise exposure potential causing intermittent noise nuisance (passing trucks at 50 feet would generate up to a maximum of 84 dBA), the effect on longer-term ambient noise levels would be small because the daily construction-related vehicle trips are small when compared to the existing daily traffic volume on Cannon Street. The grubbing and land clearing phase would generate the most trips out of all of the construction phases, at 777 trips per day based on the California Emissions Estimator Model (CalEEMod, Version 2022.1) output detailed in the AQ/GHG Memo included as Appendix A to this IS/MND. According to the Traffic Assessment Memo (Appendix F to this IS/MND), Cannon Street has an existing ADT volume of 33,096 ADT between Serrano Avenue and Taft Avenue and 30,297 ADT between Taft Avenue and Santiago Canyon Road Based on the information above, construction‐ related traffic would increase noise by up to 0.2 dBA. A noise level increase of less than 3 dBA would not be perceptible to the human ear in an outdoor environment. Therefore, no short-term constructionrelated impacts associated with worker commutes and transport of construction equipment and material to the project limits would occur, and no noise reduction measures would be required.

The second type of short-term noise impact is related to noise generated from construction activities.

Construction is performed in discrete steps, each of which has its own mix of equipment and, consequently, its own noise characteristics. The proposed project anticipates site preparation, grading, building construction, paving, and architectural coating phases of construction. These various sequential phases change the character of the noise generated on a project site. Therefore, the noise levels vary as construction progresses. Despite the variety in the type and size of construction equipment, similarities in the dominant noise sources and patterns of operation allow constructionrelated noise ranges to be categorized by work phase. Table 4.13.C lists the Lmax recommended for 730

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4 \\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) -90 Table 4.13.C: Typical Construction Equipment Noise Levels Equipment Description Acoustical Usage Factor1
(%)
Maximum Noise Level (Lmax) at
50 ft2
Backhoe 40 80
Compactor (ground) 20 80
Compressor 40 80
Crane 16 85
Dozer 40 85
Dump Truck 40 84
Excavator 40 85
Flatbed Truck 40 84
Man Lift (Forklift) 20 85
Front-End Loader 40 80
Generator 50 82
Generator (<25KVA, VMS signs) 50 70
Grader 40 85
Jackhammer 20 85
Pavement Scarifier 20 85
Paver 50 85
Pickup Truck 40 55
Pneumatic Tools 50 85
Pump 50 77
Rock Drill 20 85
Roller 20 85
Scraper 40 85
Tractor 40 84
Welder/Torch 40 73
Source: FHWA Highway Construction Noise Handbook, Table 9.1 (FHWA 2006).

Note: The noise levels reported in this table are rounded to the nearest whole number. 1 Usage factor is the percentage of time during a construction noise operation that a piece of construction equipment is operating at full power.
2 Maximum noise levels were developed based on Specification 721.560 from the CA/T program to be consistent with the City of Boston, Massachusetts, Noise Code for the “Big Dig” project.

CA/T = Central Artery/Tunnel
FHWA = Federal Highway Administration
ft = foot/feet
Lmax = maximum instantaneous noise level
noise impact assessments for typical construction equipment included in the FHWA Highway Construction Noise Handbook (2006), based on a distance of 50 feet between the equipment and a noise receptor.

The site preparation phase, which includes excavation and grading of the site, tends to generate the highest noise levels because the noisiest construction equipment is earthmoving equipment.

Earthmoving equipment includes excavating machinery, such as backfillers, bulldozers, draglines, and front loaders. Earthmoving and compacting equipment includes compactors, scrapers, and graders.

Typical operating cycles for these types of construction equipment may involve 1 or 2 minutes of fullpower operation, followed by 3 or 4 minutes at lower power settings.

Construction of the proposed project is expected to require on-site use of bulldozers, front-end loaders, and water/pickup trucks. Noise associated with the use of construction equipment is estimated to be between 55 and 85 dBA Lmax at a distance of 50 feet from the active construction area during 731

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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-91 grading/excavation. As shown in Table 4.13.C, the maximum noise level generated by each bulldozer is assumed to be approximately 85 dBA Lmax at 50 feet from the bulldozer. Each front-end loader would generate approximately 80 dBA Lmax at 50 feet. The maximum noise level generated by water trucks/pickup trucks is approximately 55 dBA Lmax at 50 feet from these vehicles. Each doubling of the sound source with equal strength increases the noise level by 3 dBA. Assuming that each piece of construction equipment operates at some distance from the other equipment, the worst-case combined noise level during this phase of construction would be 86 dBA Lmax at a distance of 50 feet from the active construction area. Based on a usage factor of 40 percent, the worst-case combined noise level during this phase of construction would be 82 dBA Leq at a distance of 50 feet from the active construction area.

The closest residence is located within 50 feet of the project construction area. Therefore, receptor locations analyzed in the Noise Memo may be subject to short-term noise reaching 86 dBA Lmax (82 dBA Leq) or higher generated by construction activities in the project limits. Although the noise generated by project construction activities would be higher than the ambient noise levels and would result in a temporary increase in the ambient noise levels, construction noise would stop once project construction is completed. Construction activities shall be limited to between the hours of 7:00 a.m. and 8:00 p.m., Monday through Friday, and between the hours of 8:00 a.m. and 8:00 p.m. on Saturday pursuant to Section 6-6.7(e) of the City of Villa Park Municipal Code because construction activities during these hours are exempt by the City of Villa Park, and the City of Orange exempts construction activities undertaken by a public agency within street right-of-way pursuant to Section 8.24.050(K) of the City of Orange Municipal Code. The implementation of construction hour limits, as summarized in Regulatory Compliance Measure (RCM) NOI-1, would minimize disturbance to nearby residential land uses. Therefore, noise generated from project construction activities would be less than significant. No mitigation measures are required.

Long-Term Operational Impacts. The FHWA Highway Traffic Noise Prediction Model (FHWARD-77 108)66 was used to evaluate traffic-related noise conditions along the roadway segments of Cannon Street. This model requires various parameters, including traffic volumes, vehicle mix, vehicle speed, and roadway geometry to compute typical equivalent noise levels during daytime, evening, and nighttime hours. The resultant noise levels are weighted and summed over 24-hour periods to determine the CNEL values. The existing ADT volumes were obtained from the Traffic Assessment Memo, included as Appendix F to this IS/MND. The standard vehicle mix for Southern California roadways was used for traffic on these roadway segments. Table 4.13.D provides the traffic noise levels for the existing (2023) with and without project scenario. These noise levels represent worst-case scenarios, which assume that no shielding is provided between the traffic and the location where the noise contours are drawn. The specific assumptions used in developing these noise levels and the model printouts are provided as Attachment D to the Noise Memo.

As shown in Table 4.13.D, project-related traffic noise would increase by up to 0.1 dBA. Noise level increases below 3 dBA would not be perceptible to the human ear in an outdoor environment.

Therefore, no traffic noise impacts from project-related traffic on off-site sensitive receptors would occur. No mitigation measures are required.
66 Federal Highway Administration (FHWA). Highway Traffic Noise Prediction Model (FHWA-RD-77 108). 732

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4 \\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) -92 Table 4.13.D: Existing (2023) Traffic Noise Levels Without and With Project Roadway Segment
Without Project Traffic Conditions With Project Traffic Conditions ADT
Centerline to
70 dBA
CNEL (ft)
Centerline to
65 dBA
CNEL (ft)
Centerline to
60 dBA
CNEL (ft)
CNEL (dBA)
50 ft from
Roadway
Centerline
ADT
Centerline to
70 dBA
CNEL (ft)
Centerline to
65 dBA
CNEL (ft)
Centerline to
60 dBA
CNEL (ft)
CNEL
(dBA) 50 ft
from
Roadway
Centerline
Increase
from
Baseline
Conditions
Cannon Street between Serrano
Avenue and Taft Avenue 33,096 81 167 356 72.8 33,096 82 167 356 72.9 0.1 Cannon Street between Taft
Avenue and Santiago Canyon
Road
30,297 76 157 335 72.5 30,297 78 158 336 72.5 0.0
Source: Compiled by LSA (2024).

Note: Traffic noise within 50 ft of the roadway centerline should be evaluated with site-specific information.

ADT = average daily traffic
CNEL = Community Noise Equivalent Level
dBA = A-weighted decibels
ft = foot/feet
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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-93 Regulatory Compliance Noise Reduction Measures. The proposed project’s adherence to the following regulatory compliance measure would reduce construction noise to the extent feasible and reasonable:

RCM NOI-1 Construction Noise and Vibration. The construction contractor shall limit construction activities to between the hours of 7:00 a.m. and 8:00 p.m., Monday through Friday, and between the hours of 8:00 a.m. and 8:00 p.m. on Saturday.

Construction is prohibited outside these hours and on Sundays and federal holidays.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is required, but adherence to RCM NOI-1 is required.

Significance Determination After Mitigation: Less Than Significant Impact b) Would the project result in generation of excessive groundborne vibration or groundborne noise levels?
Short-Term Construction Impacts. Vibration generated by construction equipment can result in varying degrees of ground vibration, depending on the equipment. The operation of construction equipment causes ground vibrations that spread through the ground and diminish in strength with distance. Buildings on soil near an active construction area respond to these vibrations, which range from imperceptible to low rumbling sounds with perceptible vibrations and slight damage at the highest vibration levels. Typically, construction-related vibration does not reach vibration levels that would result in damage to nearby structures.

The Caltrans’ Transportation and Construction Vibration Guidance Manual (Caltrans 2020) shows that the vibration damage threshold for continuous/frequent intermittent sources is 0.25 PPV (in/sec) for historic and old buildings. The manual shows the vibration annoyance potential criteria to be barely perceptible at 0.01 PPV (in/sec), distinctly perceptible at 0.04 PPV (in/sec), and strongly perceptible at

0.10 PPV (in/sec) for continuous/frequent intermittent sources. These thresholds were used to evaluate the potential for short-term construction-related ground-borne vibration during construction of the proposed project.

Table 4.13.E shows the reference vibration levels at a distance of 25 feet for each type of standard construction equipment from the Transportation and Construction Vibration Guidance Manual (Caltrans 2020). Project construction is expected to require the use of large bulldozers and loaded trucks, which would generate ground-borne vibration levels of up to 0.089 PPV (in/sec) and 0.076 PPV (in/sec), respectively, when measured at 25 feet.

The formula for vibration transmission is provided below:

PPVequip = PPVref x (25/D)1.5
Bulldozers and trucks used for construction of the proposed project would generate the highest groundborne vibration levels. Based on the Caltrans Transportation and Construction Vibration Guidance Manual, a large bulldozer and loaded trucks would generate vibration levels of 0.089 PPV (in/sec) and

0.076 PPV (in/sec), respectively, when measured at 25 ft. The closest building structure is a residential building (19231 Parker Circle, Villa Park, California), approximately 20 feet from the project construction boundary, and this structure would experience vibration levels of up to 734

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4 \\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) -94 Table 4.13.E: Vibration Source Amplitudes for
Construction Equipment
Equipment Reference PPV (in/sec) at 25 ft
Vibratory roller 0.210
Large bulldozer1 0.089
Caisson drilling 0.089
Loaded trucks1 0.076
Jackhammer 0.035
Small bulldozer 0.003
Source: Transportation and Construction Vibration Guidance Manual (Caltrans 2020). 1 The equipment shown in bold is expected to be used on site. ft = foot/feet
in/sec = inches per second
PPV = peak particle velocity

0.124 PPV (in/sec). Although this vibration level would be strongly perceptible, vibration levels would not exceed the damage threshold of 0.3 PPV (in/sec) because the condition of the residential building would be equivalent to or better than older residential structures. Other building structures adjacent to the project would experience lower vibration levels because they are farther away and would be constructed equivalent to or better than older residential structures. Therefore, short-term construction impacts related to ground-borne vibration or ground-borne noise would be less than significant. No mitigation measures are required.

Long-Term Operational Impacts. Roads with smooth surfaces are not typically major sources of ground-borne noise or vibration. Ground-borne vibration is mostly associated with passenger vehicles and trucks traveling on roads with poor conditions, such as potholes, bumps, expansion joints, or other discontinuities in the road surface. Passenger vehicles and trucks would cause effects such as rattling of windows, and the sources are almost always airborne noise. The proposed project would include new asphalt pavement with proper maintenance. As a result, there would be no potholes, bumps, or other discontinuities in the road surface that would generate ground-borne vibration or noise impacts from vehicular traffic traveling on Cannon Street within the project limits. Therefore, ground-borne vibration impacts generated by vehicles traveling on Cannon Street within the project limits would be less than significant. No mitigation measures are required.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: Less Than Significant Impact c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within 2 miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
Airport-related noise levels are primarily associated with aircraft engine noise made while aircraft are taking off, landing, or running their engines while still on the ground. The closest airports to the project area are the John Wayne Airport and the Fullerton Municipal Airport, which are located approximately

9.6 miles southwest and 10.8 miles northwest of the project limits, respectively. The project limits are outside the 60 dBA CNEL noise contour of John Wayne Airport and Fullerton Municipal Airport based 735

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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-95 on the Airport Environs Land Use Plan for John Wayne Airport67 and Fullerton Municipal Airport,68 respectively. In addition, the proposed project is not located in the vicinity of a private airstrip. The proposed project is a transportation project and would not involve the introduction of residential or employment uses in the project area. Therefore, the project would not expose people residing or working in the vicinity to aviation-related excessive noise levels, and no impact would occur.

Significance Determination: No Impact
Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: No Impact
67 Orange County Airport Land Use Commission (OCALUC). 2008. Airport Environs Land Use Plan for John Wayne Airport. April 17. Website: https://files.ocair.com/media/2021-02/JWA_AELUP-April-17- 2008.pdf?VersionId=cB0byJjdad9OuY5im7Oaj5aWaT1FS.vD (accessed March 2024). 68 Orange County Airport Land Use Commission (OCALUC). 2019. Airport Environs Land Use Plan for Fullerton Municipal Airport. February 21. Website: https://files.ocair.com/media/202102/AELUP%20for %20FMA%2005092019.pdf (accessed March 2024).
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4.14 POPULATION AND HOUSING
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Induce substantial unplanned population growth in
an area, either directly (for example, by proposing
new homes and businesses) or indirectly (for
example, through extension of roads or other
infrastructure)?
b) Displace substantial numbers of existing people or
housing, necessitating the construction of
replacement housing elsewhere?
Impact Analysis
a) Would the project induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
The proposed project includes the addition of a third northbound lane to a segment of the existing Cannon Street roadway, as well as the construction of a new pedestrian bridge west of the existing vehicular bridge where Cannon Street crosses Santiago Creek. In order to accommodate these improvements, the proposed project would involve the construction of additional pavement, widening of the roadway, addition of a raised landscaped median, and a traffic signal modification at Taft Avenue.

Implementation of the proposed project would improve existing roadway uses and would not introduce any new structures for residential use, employment, or permanent occupancy to the project limits, though it would provide temporary employment throughout the duration of project construction.

Additionally, though the project would include infrastructure improvements (such as a new pedestrian bridge), the project does not propose to expand surrounding utility infrastructure in the project limits vicinity, nor does the project include roadway expansions or improvements that would indirectly induce population growth.

For the reasons stated above, the proposed project would not result in substantial unplanned population growth, nor would the project indirectly induce population growth through utility or circulation improvements. Therefore, no impacts would occur related to the inducement of unplanned population growth, either directly or indirectly. No mitigation is required.

Significance Determination: No Impact
Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: No Impact
b) Would the project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
As previously stated, the project proposes an additional lane and pedestrian bridge, as well as related improvements, along Cannon Street within the project limits. A majority of the proposed improvements 737

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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-97 are expected to take place within existing City right-of-way with the exception of the new pedestrian and bike bridge/trail, which would require temporary construction easements from the County of Orange to construct the new pedestrian bridge, which would occur outside of City right-of-way.

Temporary construction easements would also be needed from the County of Orange to construct the pedestrian bridge, but would cease upon completion of construction. Neither the permanent nor temporary easements would result in the acquisition of any residential properties.

There are no existing housing units or people currently living on the project limits, and the proposed project would not result in the demolition or repurposing of any existing structures. Therefore, the proposed project would not displace housing or persons, nor require or necessitate the development of replacement housing elsewhere. No impacts would occur, and no mitigation would be required.

Significance Determination: No Impact
Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: No Impact
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4.15 PUBLIC SERVICES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Result in substantial adverse physical impacts
associated with the provision of new or physically
altered governmental facilities, need for new or
physically altered governmental facilities, the
construction of which could cause significant
environmental impacts, in order to maintain
acceptable service ratios, response times or other
performance objectives for any of the public services:
i. Fire protection?
ii. Police protection?
iii. Schools?
iv. Parks?
v. Other public facilities?
Impact Analysis
a) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered government facilities, or the need for new or physically altered government facilities, the construction of which would cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
i. Fire protection?
The Orange City Fire Department (OCFD) provides fire protection, emergency medical, urban search and rescue, water rescue, and hazardous materials response services in the City. The Fire Department operates eight stations located within the City.69 In the year 2023, the OCFD responded to 17,927 calls for service. The number of incidents within the City’s jurisdiction decreased by 0.82 percent since 2022, but the number of incidents outside of the City’s jurisdiction increased by 11.44 percent since 2022. 70 The closest fire station to the project limits is Station No. 8, located at 5725 Carver Lane, approximately

0.53 mile north of the northernmost project limits. Station No. 8 would likely be the first to respond to a call for service in the project limits and would, therefore, be designated the “first-in” station. 69 Orange City Fire Department (OCFD). 2023. 2023 Orange City Fire Annual Report. December. Website:
https://static1.squarespace.com/static/62c47583a67bd82b35d529e7/t/6657e4b428576c38703866f6/171703 6216155/2023+Orange+City+Fire+Annual+Report+-+%28Website%29.pdf (accessed July 31, 2024). 70 Ibid.
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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-99 The Fire Department is staffed by 115 sworn personnel and 25 non-sworn personnel.71 Given the City’s estimated population of 139,063 as of January 1, 2023,72 the Fire Department provides approximately

0.8 fire personnel per 1,000 residents.73
Because the project limits consist of a segment of the Cannon Street Roadway, the project limits would provide emergency access. As discussed in Section 4.17, Transportation, the proposed project would not result in a substantial increase in traffic congestion or significant impacts to the local circulation system that would delay emergency response vehicles. Therefore, the proposed project would not impair emergency response vehicles or increase response times.

The proposed project consists of roadway improvements and the construction of a pedestrian bridge which would not introduce any new inhabitable structures to the project limits. Therefore, the proposed project would not introduce any new permanent residents or employees to the project limits or the City.

As such, the project is not anticipated to result in a significant increase in the demand for fire protection services nor would the project affect emergency response times in the long run. Construction and operation of the proposed project would not trigger the need for new or altered fire facilities.

Consequently, the OCFD would be able to maintain current levels of service provided to the project limits following project implementation. Impacts would be less than significant, and no mitigation is required.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: Less Than Significant Impact ii. Police protection?
The City of Orange Police Department (Police Department) would provide police protection services to the project limits. The Police Department contains the Supportive Services Division, Investigative Services Division, Field Services Division, Bike Team, Canine Unit, Homeless Engagement Assistance and Resource Team, SWAT Team, and Traffic Bureau.

The Police Department is staffed by 170 sworn full time personnel and 78 non-sworn personnel.74 Given the City’s estimated population of 139,063 as of January 1, 2023,75 the Police Department provides approximately 1 officer per 1,000 residents.76 As stated above in Response 4.15(a)(i), the proposed project consists of roadway improvements and the construction of a pedestrian bridge which would not introduce any new inhabitable structures to the project limits capable of increasing the 71 City of Orange. 2023. Fiscal Year 2023-24 Budget. June 27. Website: https://www.cityoforange.org/home/ showpublisheddocument/4662/638302921366700000 (accessed February 19, 2024). 72 State of California Department of Finance. 2023. Population and Housing Estimates for Cities, Counties, and the State - January 1, 2022, and 2023. May. Website: https://dof.ca.gov/forecasting/demographics/estimatese1/ (accessed February 19, 2024). 73 139,063 / 1,000 = 139.06. 115/139.06 = 0.827 or 0.8. 74 City of Orange. 2023. Fiscal Year 2023-24 Budget. June 27. Website: https://www.cityoforange.org/home/ showpublisheddocument/4662/638302921366700000 (accessed February 19, 2024). 75 State of California Department of Finance. 2023. Population and Housing Estimates for Cities, Counties, and the State - January 1, 2022, and 2023. May. Website: https://dof.ca.gov/forecasting/demographics/estimatese1/ (accessed February 19, 2024). 76 139,063 / 1,000 = 139.06. 170 / 139.06 = 1.222 or approximately 1 officer. 740

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4 \\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) -100 number of employees or permanent residents within the City. Therefore, the project is not anticipated to result in a significant increase in the demand for police services nor would the project affect emergency response times. As such, construction and operation of the proposed project would not trigger the need for new or altered police facilities. Consequently, the Police Department would be able to maintain current levels of service provided to the project limits following project implementation.

Impacts would be less than significant, and no mitigation is required.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: Less Than Significant Impact iii. Schools?
The Orange Unified School District (OUSD) provides school services to the City of Orange. Cannon Street serves as the school boundary between several elementary, middle, and high schools in the OUSD. The residential neighborhoods in the immediate project limits vicinity are served by Linda Vista Elementary School, Villa Park Elementary School, or Serrano Elementary School. The OUSD middle schools serving these neighborhoods are Cerro Villa Middle School and Santiago Middle School. The OUSD high schools serving these neighborhoods are Villa Park High School and El Modena High School.77
As previously stated, the proposed project consists of roadway improvements and the construction of a pedestrian bridge would not result in an increase in employees or permanent residents within the project limits or the City because no new inhabitable structures are proposed as part of the project. Therefore, the proposed project would not result in an increase in the student population at the schools serving the project limits or surrounding neighborhoods. The proposed project is not anticipated to result in a significant increase in the demand for schools, nor would the project affect performance objectives for local schools. As such, construction and operation of the proposed project would not trigger the need for new or altered school facilities. Impacts would be less than significant, and no mitigation is required.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: Less Than Significant Impact iv. Parks?
According to the Orange General Plan Natural Resources Element, the City contains approximately 256 acres of parks, City open space areas, and joint-use recreation facilities that can be used for recreational purposes.
78 In addition to parks, the City also contains equestrian and multi-purpose trails providing recreational opportunities to residents and guests.

The nearest recreational facility to the project limits is the Santiago Creek Trail and Bike Path, a paved trail spanning 6 miles from Hart Park to Cannon Street, with one branch continuing north from Walnut Avenue to Collins Avenue and connecting to the adjacent City of Villa Park. The Santiago Creek Bike 77 Orange Unified School District (OUSD). n.d. School Locator. Website: https://portal.schoolsitelocator. com/apps/ssl/?districtcode=57964# (accessed February 19, 2024). 78 City of Orange. 2015. Orange General Plan Natural Resources Element. Website: https://www.cityof orange. org/home/showpublisheddocument/210/637698172559270000 (accessed February 19, 2024). 741

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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-101 Trail provides connections to three of the City’s parks: Grijalva Park, Yorba Park, and Hart Park. A parking lot for the Santiago Creek Trail and Bike Path is located along the western edge of Cannon Street, just before it crosses over Santiago Creek. As stated above, Cannon Street serves as one endpoint of the Santiago Creek Trail and Bike Path.

Given the City’s estimated population of 139,063 as of January 1, 2023,79 the City currently provides

1.8 acres of parkland per 1,000 residents.80 This represents a shortfall from the City’s minimum level of 3 acres per 1,000 persons and goal of 5 acres per 1,000 persons, as set forth in Policy 5.6 of the Natural Resources Element. However, the City also contains approximately 1,187 acres of County regional parks. When considering the regional park space available to City residents, the ratio improves to approximately 10.3 acres per 1,000 persons,
81 which achieves applicable goals and policies.

The proposed project includes the addition of a third northbound lane to a segment of the existing Cannon Street roadway, as well as the construction of a new pedestrian bridge west of the existing vehicular bridge where Cannon Street crosses over Santiago Creek. In order to accommodate these improvements, the proposed project would involve the construction of additional pavement, widening of the roadway, addition of a raised landscaped median, and a traffic signal modification at Taft Avenue.

The proposed project would not include any new structures that could accommodate permanent residents and would therefore not result in a direct population increase. Construction workers would be temporarily present within the project limits throughout the duration of the proposed project’s construction, but these workers are likely to have their recreation needs met in their current area of residence.

The construction of the new pedestrian bridge adjacent to the existing Santiago Canyon would re-route existing bike and pedestrian traffic that currently utilizes the existing bridge overcrossing, and would not result in increased usage of existing recreational facilities. During construction of the proposed project, Cannon Street would remain open to traffic, and access to the Santiago Creek Trail and Bike Path is anticipated to remain open throughout the approximate 8-month construction period. Access to the Santiago Creek Trail and Bike Path parking lot may be temporarily affected, but ample street parking would be available within adjacent residential neighborhoods. Any delays to through pedestrian and bicycle traffic would be temporary in nature and would resolve upon completion of the proposed project’s construction.

Implementation of the proposed project would not contribute to substantial physical deterioration of existing parks or recreational facilities or cause deterioration to accelerate, thereby generating a need for additional neighborhood and regional parks or recreational facilities. Impacts to parks and other recreational facilities would be less than significant, and no mitigation is required.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: Less Than Significant Impact 79 State of California Department of Finance. 2023. Population and Housing Estimates for Cities, Counties, and the State - January 1, 2022, and 2023. May. Website: https://dof.ca.gov/forecasting/demographics/estimatese1/ (accessed February 19, 2024). 80 139,063 / 1,000 = 139.06. 256 / 139.06 = 1.841 or approximately 1.8 acres. 81 1,187 + 256 = 1,443. 1,443/139.06 = 10.377 or approximately 10.3 acres. 742

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The City of Orange Public Library system provides library services within the City, and is comprised of one main library and three branch libraries. The El Modena Branch Library is the closest library to the project limits, located approximately 1.97 mile southwest at 380 S. Hewes Street. This branch features a community room, study rooms and a homework center, reading room, WiFi, and public-use computers.82
As previously discussed, the proposed project would not introduce any new permanent employees or residents to the project limits or the City and therefore would not result in a population increase. As such, the proposed project would not cause a significant increase in demand for library facilities, and impacts to library facilities would be less than significant. No mitigation is required.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: Less Than Significant Impact 82 City of Orange. n.d. Facility Directory Table List. Website: https://www.cityoforange.org/Home/ Components/FacilityDirectory/FacilityDirectory/24/32?npage=2&sortn=FCName&sortd=desc (accessed February 19, 2024).
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4.16 RECREATION
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Would the project increase the use of existing
neighborhood and regional parks or other
recreational facilities such that substantial physical
deterioration of the facility would occur or be
accelerated?
b) Does the project include recreational facilities or
require the construction or expansion of recreational
facilities which might have an adverse physical effect
on the environment?
Impact Analysis
a) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
and
b) Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment? According to the Orange General Plan Natural Resources Element, the City contains approximately 256 acres of parks, City open space areas, and joint-use recreation facilities.83 In addition to parks, the City also contains equestrian and multi-purpose trails providing recreational opportunities to residents and guests.

A parking lot for the Santiago Creek Trail and Bike Path is located along the western edge of Cannon Street, just before it crosses over Santiago Creek. As stated above, Cannon Street serves as one endpoint of the Santiago Creek Trail and Bike Path.

The proposed project would not include any new structures that could accommodate permanent 83 City of Orange. 2015. Orange General Plan Natural Resources Element. Website: https://www.cityof orange.org/home/showpublisheddocument/210/637698172559270000 (accessed February 19, 2024). 744

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4 \\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) -104 residents and would therefore not result in a direct population increase. The construction of the new pedestrian bridge adjacent to the existing Santiago Canyon would re-route existing bike and pedestrian traffic that currently utilizes the existing bridge overcrossing, and would not result in increased usage of existing recreational facilities. During construction of the proposed project, Cannon Street would remain open to traffic, and access to the Santiago Creek Trail and Bike Path is anticipated to remain open throughout the approximate 8-month construction period. Access to the Santiago Creek Trail and Bike Path parking lot may be temporarily affected, but ample street parking would be available within adjacent residential neighborhoods. Any delays to through pedestrian and bicycle traffic would be temporary in nature and would resolve upon completion of the proposed project’s construction.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: Less Than Significant Impact 745

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4.17 TRANSPORTATION
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Conflict with a program, plan, ordinance or policy
addressing the circulation system, including transit,
roadway, bicycle and pedestrian facilities?
b) Conflict or be inconsistent with CEQA Guidelines
§15064.3, subdivision (b)?
c) Substantially increase hazards due to a geometric
design feature (e.g., sharp curves or dangerous
intersections) or incompatible uses (e.g., farm
equipment)?
d) Result in inadequate emergency access?
The following section is based in part on the Proposed Improvements to Cannon Street Traffic Assessment Memorandum (Traffic Assessment Memo) prepared for the proposed project by LSA in October 2024, which is provided as Appendix F to this IS/MND.

Impact Analysis
a) Would the project conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? Construction of the proposed project would be required to comply with the California Department of Transportation (Caltrans) Standard Specifications (2023), the City of Orange Standard Plans and Specifications (2016), and the Standard Specifications for Public Works Construction (Greenbook 2021), and would therefore be consistent with these regulations.

As stated in Section 2.0, Project Description, the City’s General Plan Circulation and Mobility Element84 classifies Cannon Street as a Major Arterial roadway, which can accommodate up to 50,700 vehicles on an average weekday at level of service (LOS) D conditions. At the local level, the General Plan Circulation and Mobility Element establishes LOS D as the lowest acceptable level of service for both roadway segments and peak-hour signalized intersection movements. At the regional level, Orange County’s Congestion Management Plan (CMP) specifies LOS E as the operating standard for roadways and intersections on the CMP highway system. However, the project limits are not included in the Orange County CMP.

Project-related transportation and access impacts were analyzed in the Traffic Assessment Memo. As part of the preparation of the Traffic Assessment Memo, an independent data collection company was contracted to survey daily traffic volumes within the project limits on April 4, 2023. Table 4.17.A below summarizes the daily traffic volumes within the project limits, while Table 4.17.B summarizes the traffic volumes during peak hours.
84 City of Orange. 2015. Orange General Plan Circulation and Mobility Element. Website: https://www.cityof orange.org/home/showpublisheddocument/192/637698172525970000 (accessed April 10, 2024). 746

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4 \\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) -106 Table 4.17.A: Cannon Street Daily Traffic Volume
LOS E
Capacity
Existing
Volume
Volume to
Capacity LOS
Between Serrano Avenue and Taft Avenue 37,500 33,096 0.88 D Between Taft Avenue and Santiago Canyon Road 37,500 30,297 0.81 D Sources: Orange General Plan Circulation and Mobility Element; Counts Unlimited (2023).

LOS = level of service
Table 4.17.B: Cannon Street Peak-Hour Traffic Volume
Northbound Southbound Total
Between Serrano Avenue and Taft Avenue
A.M. Peak Hour (7:30-8:30 a.m.) 796 2,325 3,121
P.M. Peak Hour (5:00-6:00 p.m.) 2,511 1,019 3,530
Between Taft Avenue and Santiago Canyon Road
A.M. Peak Hour (7:30-8:30 a.m.) 748 2,269 3,017
P.M. Peak Hour (5:00-6:00 p.m.) 2,265 937 3,202
Source: Counts Unlimited (2023).

Intersection operating conditions within the project limits were evaluated using the intersection capacity utilization (ICU) methodology and the Highway Capacity Manual (HCM) methodology. The ICU methodology compares the volume-to-capacity (v/c) ratios of conflicting turn movements at an intersection, sums these critical conflicting v/c ratios for each intersection approach, and determines the overall ICU. The resulting ICU, or delay, is expressed in terms of LOS, where LOS A represents free-flow activity and LOS F represents overcapacity operation. As previously stated, the City has established LOS D as the lowest acceptable level of service for both roadway segments and peak-hour signalized intersection movements.

The HCM methodology calculates the delay experienced by vehicles passing through the intersection.

For two-way stop controlled intersections, this analysis reports the delay for the most delayed approach.

The relationship between LOS and delay for signalized and unsignalized intersections is summarized in Table 4.17.C, below.

Table 4.17.C: Intersection LOS Criteria
LOS Signalized ICU
(v/c ratio)
Unsignalized Intersection Delay
(seconds)
A 0.00–0.60 ≤10.0
B 0.61–0.70 >10.0 and ≤15.0
C 0.71–0.80 >15.0 and ≤25.0
D 0.81–0.90 >25.0 and ≤35.0
E 0.91–1.00 >35.0 and ≤50.0
F > 1.00 >50.0
ICU = intersection capacity utilization
LOS = level of service
v/c = volume-to-capacity
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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-107 According to the City’s Traffic Impact Analysis Guidelines, a project traffic impact occurs when it creates a deficiency to an unsignalized intersection where the LOS deteriorates from an acceptable LOS to and unacceptable LOS, or if the effect of the development traffic is greater than or equal to 10 percent of the existing delay at an already unacceptable LOS and the intersection meets a signal warrant.

Peak-hour intersection turn volumes were collected at three intersections within the project limits:

Cannon Street/Serrano Avenue, Cannon Street/Taft Avenue, and Cannon Street/Santiago Canyon Road. According to the Traffic Assessment Memo, the intersection of Cannon Street/Serrano Avenue has a high volume of northbound right turns during the p.m. peak hour (1,448 vehicles). The existing LOS of each intersection is summarized below in Table 4.17.D.

Table 4.17.D: Existing Level of Service Summary
Intersection AM Peak Hour PM Peak Hour

ICU LOS ICU LOS
Cannon St/Serrano Ave 0.734 C 0.548 A
Cannon St/Taft Ave 0.877 D 0.943 E
Cannon St/Santiago Cyn Rd 0.729 C 0.746 C
Source: Compiled by LSA (2023).

ICU = Intersection Capacity Utilization
LOS = level of service
As shown in Table 4.17.D, all three intersections within the project limits operate at satisfactory LOS under existing conditions, with the exception of the Cannon Street/Taft Avenue intersection, which operates at LOS E in the p.m. peak hour. A turning lane queueing analysis of each intersection was also conducted, as shown in Table 4.17.E, below.

Table 4.17.E: Existing Peak Hour Turning Lane Queues
Intersection Storage Length
(ft)
Queue Length (ft)
AM Peak Hour PM Peak Hour
Cannon Street/Serrano Avenue
Northbound Right 185 5 125
Southbound Left 213 45 109
Westbound Left 325 286 151
Cannon Street/Taft Avenue
Northbound Left 170 135 69
Southbound Left 75 0 0
Cannon Street/Santiago Canyon Road
Northbound Left 80 145 82
Southbound Left 383 460 176
Southbound Right 263 584 116
Eastbound Left 316 129 451
Westbound Left 140 36 68
Source: Compiled by LSA (2023).
ft = foot/feet
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4 \\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) -108 As shown in Table 4.17.E, existing traffic volume results in several queues exceeding the storage length of turn pockets. At the intersection of Cannon Street/Santiago Canyon Road, the northbound left-turn pocket is exceeded by two vehicles in the a.m. peak hour, the southbound left-turn pocket is exceeded by three vehicles in the a.m. peak hour, and the eastbound left-turn pocket is exceeded by six vehicles in the p.m. peak hour. At each of these locations, stacking likely extends into the painted median with little impact to the through traffic lanes. At the intersection of Cannon Street/Santiago Canyon Road, the southbound right-turn lane queue generated by 743 vehicles in the a.m. peak hour is more than double the storage length provided in the a.m. peak hour, according to the HCM calculations, which accounts for the overlap signal phase for this movement. This a.m. peak hour queue likely blocks the exclusive southbound through lane.

A second northbound right-turn lane was recently added to the intersection of Cannon Street/Serrano Avenue to accommodate existing demand. While the intersection of Cannon Street/Serrano Avenue currently has dual northbound right-turn lanes, the existing turn pocket is 185 feet, providing queueing space for 7 or 8 vehicles. A queue exceeding 7 or 8 vehicles would first begin to obstruct the northbound bicycle lane, then the second northbound through lane. At the intersection of Cannon Street/Serrano Avenue the HCM calculations predict that a 125-foot queue would form in the p.m. peak hour even with dual northbound right-turn lanes if both lanes are evenly utilized. Prior to installation of the second northbound right-turn lane, the 1,448 vehicles in the p.m. peak hour would form a queue 1,272 feet in length, the queue extending south of the Cannon Street/Taft Avenue intersection. Installation of the second northbound right-turn lane reduced queueing at the intersection, but the high volume of vehicles making this movement still use much of the northbound through capacity along the Cannon Street corridor.

The proposed project would extend the existing northbound right-turn lanes at Cannon Street/Serrano Avenue (as an auxiliary lane) approximately 2,500 feet until 500 feet north of the intersection of Cannon Street/Santiago Canyon Road. This would result in one continuous lane from the westbound free-right turn at Cannon Street/Santiago Canyon Road to the northbound right-turn lanes at Cannon Street/ Serrano Avenue. As a result of the proposed project, the high volume of vehicles traveling from westbound Santiago Canyon Road, through northbound Cannon Street, to eastbound Serrano Avenue would not be required to make any lane changes.

As such, the proposed project is not anticipated to lead to a substantial or measurable increase in vehicle travel that could create a deficiency to an unsignalized intersection where the LOS deteriorates from an acceptable LOS to an unacceptable LOS, or contribute traffic greater than or equal to 10 percent of the existing delay at an already unacceptable LOS. As such, the proposed project’s traffic impacts would be less than significant based on the City’s General Plan Circulation and Mobility Element criteria.

Alternative Transportation Facilities
Bicycle paths and sidewalks exist to various degrees throughout the project limits. A 10-foot-wide Class I off-street bicycle path (part of the Santiago Creek Trail and Bikepath) is provided on the west side of Cannon Street between Santiago Canyon Road and the Santiago Creek Trail and Bikepath bicycle parking area (approximately 1,200 feet south of Taft Avenue). Class II on-street bicycle lanes of approximately 4–6 feet in width are provided on both sides of Cannon Street in this area as well. The bicycle lanes continue north to Serrano Avenue. For a portion of that distance, the bicycle lane on the west side of Cannon Street is limited to 4 feet, including the gutter, which could potentially discourage users.
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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-109 A sidewalk is provided along the east side of Cannon Street between Serrano Avenue and Santiago Creek. On the west side of Cannon Street, however, a portion of sidewalk is missing between Serrano Avenue and Taft Avenue. In addition, pedestrians must share the Santiago Creek Trail and Bikepath along the western edge of Cannon Street south of the Santiago Creek Trail and Bikepath bicycle parking area.

The proposed project would include a new bicyclist and pedestrian bridge spanning Santiago Creek just west of the existing vehicular bridge. The new bridge would clear span the creek and is expected to consist of a prefabricated steel truss, approximately 170 feet long and 12 feet wide. The new bridge would carry two-way traffic for pedestrians and southbound traffic for bicyclists and would increase safety by creating a physical separation between vehicular traffic and pedestrians or bicyclists. This would represent an improvement from existing conditions pertaining to pedestrian and bicycle facilities. Therefore, the proposed project would not conflict with adopted plans, programs, ordinances, or policies regarding public transit, bicycle, or pedestrian facilities.

As established in Response 4.11(a), in Section 4.11, Land Use and Planning, the proposed project would be consistent with applicable General Plan Circulation and Mobility Element policies. Therefore, the proposed project would result in a less than significant impact related to conflicts with an applicable plan, program, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. No mitigation would be required.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: Less Than Significant Impact b) Would the project conflict or be inconsistent with CEQA Guidelines §15064.3, subdivision (b)?
On September 27, 2013, Governor Jerry Brown signed Senate Bill (SB) 743 into law, which directed the Governor’s Office of Planning and Research (OPR) to establish new CEQA guidance for jurisdictions that removes the LOS method, which focuses on automobile vehicle delay and other similar measures of vehicular capacity or traffic congestion, from CEQA transportation analysis.

Rather, VMT, or other measures that promote “the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses,” are now used as the basis for determining significant transportation impacts in the State.

As part of a January 2019 update to the State CEQA Guidelines, Section 15064.3 codifies that projectrelated transportation impacts are typically best measured by evaluating the project’s VMT.

Specifically, subdivision (b) focuses on specific criteria related to transportation analysis. Subdivision (b)(2) addresses VMT associated with transportation projects and states that projects that reduce VMT, such as pedestrian, bicycle, and transit projects, should be presumed to have a less than significant impact. Subdivision (b)(4) stipulates that Lead Agencies have the discretion to formulate a methodology that would appropriately analyze a project’s VMT. The July 2020 City of Orange Traffic Impact Analysis Guidelines for Vehicle Miles Traveled and Level of Service Assessment (July 2020) establishes thresholds for land development projects, but does not establish thresholds for transportation projects. However, the State provides sufficient guidance to evaluate transportation project impacts related to VMT.
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4 \\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) -110 The Technical Advisory on Evaluating Transportation Impacts in CEQA85 published by the Governor’s OPR states that:

Projects that would not likely lead to a substantial or measurable increase in vehicle travel, and therefore generally should not require an induced travel analysis, include [27 examples of which are]:
• Addition of an auxiliary lane of less than one mile in length designed to improve roadway safety.
• Installation, removal, or reconfiguration of traffic lanes that are not for through traffic, such as left, right, and U-turn pockets, two-way left turn lanes, or emergency breakdown lanes that are not utilized as through lanes. • Addition of roadway capacity on local or collector streets provided the project also substantially improves conditions for pedestrians, cyclists, and, if applicable, transit.

The proposed project would extend the existing northbound right-turn lanes at Cannon Street/Serrano Avenue (as an auxiliary lane) approximately 2,500 feet until 500 feet north of the intersection of Cannon Street/Santiago Canyon Road. This would result in one continuous lane from the westbound free‐right turn at Cannon Street/Santiago Canyon Road to the northbound right‐turn lanes at Cannon Street/Serrano Avenue. The continuous lane will operate as the northbound right-turn lane at Cannon Street/Serrano Avenue as over 85 percent of the capacity of this lane use turns right at Serrano Avenue.

In addition to the extension of this turn lane, the project would add a new, 12‐foot‐wide bridge over Santiago Creek to accommodate two‐way traffic for pedestrians and southbound bicyclists. North of Santiago Creek, the roadway would be widened by approximately 9 feet to improve pedestrian and bicycle facilities where the existing bicycle lane narrows to 4 feet (including the gutter). The project completes bicycle and pedestrian facilities where a gap currently exists south of Santiago Creek.

Therefore, the proposed project can be classified as an auxiliary lane less than 1 mile in length (2,500 feet) and installation of a traffic lane that is not for through traffic (extending the Cannon Street/ Serrano Avenue northbound right-turn lane). It should also be noted that the proposed project improves conditions for pedestrians and cyclists (new pedestrian bridge, widening of the west side of Cannon Street utilized by pedestrians and bicyclists, and facility gap closure). As such, the proposed project would not be anticipated to lead to a substantial increase in vehicle travel, and therefore can be presumed to have less than significant transportation impacts related to VMT under the revised State CEQA Guidelines and the Technical Advisory on Evaluating Transportation Impacts in CEQA.

Therefore, the proposed project would not be inconsistent with State CEQA Guidelines Section 15064.3, subdivision (b), and no mitigation is required.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: Less Than Significant Impact 85 Governor’s Office of Planning and Research (OPR). 2018. Technical Advisory on Evaluating Transportation Impacts in CEQA. April. Website: https://opr.ca.gov/docs/20180416-743_Technical_ Advisory_4.16.18.pdf (accessed April 10, 2024).
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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-111 c) Would the project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? As previously stated, the proposed project involves the widening of Cannon Street by approximately 9 feet in order to accommodate a third northbound lane from approximately 500 feet north of Santiago Canyon Road to Serrano Avenue. South of Santiago Creek, additional pavement would be constructed to the east to widen the roadway and provide pedestrian and bicycle facilities absent in the existing condition. Removing bicycles and pedestrians from vehicle travel lanes and the roadway shoulder removes this potential hazard.

Aside from the improvements discussed above, the proposed project would continue existing uses and would not substantially alter the configuration of Cannon Street from its existing condition. No new hazardous geometric design features or incompatible land uses would be included as part of the proposed project. The proposed project would introduce one continuous lane within the project limits that would transition to the northbound right-turn lanes at Cannon Street/Serrano Avenue, which would eliminate the need for the high volume of vehicles traveling through northbound Cannon Street to eastbound Serrano Avenue to make any lane changes, thus potentially improving safety conditions within the project limits. Additionally, the design of the proposed project would be subject to review by the Orange Fire Department in coordination with the City of Orange Department of Public Works.

As such, impacts related to increased hazards due to a geometric design feature or incompatible uses would be less than significant, and no mitigation is required.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: Less Than Significant Impact d) Would the project result in inadequate emergency access? According to Figure PS-4, Generalized Evacuation Corridors, of the City’s General Plan Public Safety Element,86 Cannon Street is not designated as an evacuation corridor. Cannon Street does intersect with the Chapman Avenue evacuation corridor, but this intersection falls outside of the project limits and therefore is not anticipated to be affected by the proposed project. As noted by the City’s Emergency Operations Plan, evacuation routes for emergency situations are contingent upon the scale and location of the emergency, and would change depending on the direction of evacuation required by the situation.

The proposed project would not result in any substantial traffic impacts or queueing on nearby streets during short-term construction activities with utilization of lane shifts, and all construction equipment would be staged within the project limits or within nearby temporary construction easements. Longterm operations of the proposed project would result in improved movement along the Cannon Street roadway, particularly in the northbound direction, thus improving the mobility of emergency vehicles along Cannon Street when necessitated by an emergency event. As such, emergency access would not be impaired by the proposed project.

Further, the improvements and pedestrian bridge proposed under the project would be reviewed and approved by the Orange City Fire Department and the City as part of the City’s Design Review process to ensure compliance with all applicable codes and ordinances for emergency vehicle access. Therefore, 86 City of Orange. 2015. Orange General Plan Public Safety Element. Website: https://www.cityoforange.org/ home/showpublisheddocument/214/637698172567530000 (accessed February 9, 2024). 752

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Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: Less Than Significant Impact 753

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4.18 TRIBAL CULTURAL RESOURCES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Cause a substantial adverse change in the
significance of a tribal cultural resource, defined in
Public Resources Code Section 21074 as either a site,
feature, place, cultural landscape that is
geographically defined in terms of the size and scope
of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that
is:
i. Listed or eligible for listing in the California
Register of Historical Resources, or in a local
register of historical resources as defined in
Public Resources Code Section 5020.1(k)? Or
ii. A resource determined by the lead agency, in its
discretion and supported by substantial
evidence, to be significant pursuant to criteria set
forth in subdivision (c) of Public Resources
Code Section 5024.1? In applying the criteria set
forth in subdivision (c) of Public Resource Code
Section 5024.1, the lead agency shall consider
the significance of the resource to a California
Native American tribe.

Impact Analysis
a) Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
i. Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k)? Or
ii. A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1? In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

Effective July 1, 2015, Assembly Bill (AB) 52 requires meaningful consultation with California Native American Tribes on potential impacts to Tribal Cultural Resources, as defined in Public Resources Code (PRC) Section 21074 as sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are eligible for inclusion in the California 754

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4 \\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) -114 Register of Historical Resources or included in a local register of historical resource. Per PRC Section 21080.3.1, a tribe must submit a written request to the relevant lead agency if it wishes to be notified of proposed projects in its traditionally and culturally affiliated area. The lead agency must provide written formal notification to the tribes that have requested it within 14 days of determining that a project application is complete or of deciding to undertake a project. The tribe must respond to the lead agency within 30 days of receipt of the notification if it wishes to engage in consultation on the project, and the lead agency must begin the consultation process within 30 days of receiving the request for consultation. Consultation concludes when either (1) the parties agree to mitigation measures to avoid a significant effect, if one exists, on a tribal cultural resource, or (2) a party, acting in good faith and after reasonable effort, concludes that mutual agreement cannot be reached. AB 52 also addresses confidentiality during tribal consultation per PRC Section 21082.3(c).

The Native American Heritage Commission (NAHC) is a State agency that maintains the Sacred Lands File (SLF), an official list of sites that are of cultural and religious importance to California Native American tribes. The NAHC was contacted on March 3, 2023, in order to request a SLF search for the project limits, as well as a list of potential Native American contacts for consultation. The NAHC responded on March 10, 2023, that the SLF search was negative for the project limits. The NAHC also provided a list of suggested Native American contacts for consultation outreach efforts.

In compliance with AB 52, letters have been distributed to local Native American tribes that are traditionally and culturally affiliated with the geographic area of the proposed project and have previously requested to be notified of future projects proposed by the City. The letters, which were sent on July 18, 2023, via certified mail, provided each tribe with an opportunity to request consultation with the City regarding the proposed project. The purpose of this effort was to provide Native American tribes with the opportunity for meaningful participation and to identify known tribal cultural resources on or near the project limits. The record of tribal consultation efforts is included as Appendix G to this IS/MND. The following tribes received letters pursuant to AB 52:
• San Gabriel Band of Mission Indians, Anthony Morales, Chief • Gabrieleño Band of Mission Indians – Kizh Nation, Andrew Salas, Chairperson • Torres Martinez Desert Cahuilla Indians, Michael Mirelez, Cultural Coordinator • Gabrielino/Tongva Nation, Sandonne Goad, Chairperson
In compliance with AB 52, tribes had 30 days from the date of receipt of notification to request consultation on the proposed project. Information provided through the AB 52 tribal consultation process typically informs the assessment as to whether tribal cultural resources are present within the project limits and the significance of any potential impacts to such resources.

The only response received during the open tribal consultation period was from a representative of the Gabrieleño Band of Mission Indians – Kizh Nation. The Kizh Tribe engaged in the formal consultation process with the City, during which they determined that utilization of standard mitigation measures was acceptable to address the Tribe’s concerns regarding the proposed project. As such, Mitigation Measures (MMs) TCR-1 through TCR-3 are applicable to the proposed project, as discussed below.

With this agreement, the consultation was closed on September 15, 2023.

Because no other tribes contacted on July 18, 2023, indicated the presence of tribal cultural resources within the project limits, no tribal cultural resources are known to exist within the project limits. Further, as discussed previously in Section 4.5, Cultural Resources, of this IS/MND, no known cultural resources have been documented within the project limits or in the direct vicinity of the project limits 755

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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-115 based on archival research and field surveys. In addition, low potential exists for the proposed project to impact tribal cultural resources due to significant prior disturbance from past grading and development activities on the project limits and in the surrounding area. Regulatory Compliance Measure (RCM) CUL-1, identified in Section 4.5, sets forth procedures for handling inadvertent discoveries of human remains, including those determined to be Native American. Based on the lack of known tribal cultural resources within the project limits and with the incorporation of RCM CUL-1 and MMs TCR-1 through TCR-3, impacts to tribal cultural resources would be less than significant.

Mitigation Measures:

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

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

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

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

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

E. Upon discovery of any TCRs, all construction activities in the immediate vicinity of the discovery shall cease (i.e., not less than the surrounding 50 feet) and shall not resume until the discovered TCR has been fully assessed by the Kizh monitor 756

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4 \\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) -116 and/or Kizh archaeologist. The Kizh will recover and retain all discovered TCRs in the form and/or manner the Tribe deems appropriate, in the Tribe’s sole discretion, and for any purpose the Tribe deems appropriate, including for educational, cultural, and/or historic purposes.

MM TCR-2 Unanticipated Discovery of Human Remains and Associated Funerary Objects.

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

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

C. Human remains and grave/burial goods shall be treated alike per California PRC Section 5097.98(d)(1) and (2).

D. Construction activities may resume in other parts of the project limits at a minimum of 200 feet away from discovered human remains and/or burial goods, if the Kizh determines in its sole discretion that resuming construction activities at that distance is acceptable and provides the project manager express consent of that determination (along with any other mitigation measures the Kizh monitor and/or archaeologist deems necessary). (CEQA Guidelines Section 15064.5(f).) E. Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human remains and/or burial goods. Any historic archaeological material that is not Native American in origin (non-TCR) shall be curated at a public, non-profit institution with a research interest in the materials, such as the Natural History Museum of Los Angeles County or the Fowler Museum, if such an institution agrees to accept the material. If no institution accepts the archaeological material, it shall be offered to a local school or historical society in the area for educational purposes.

F. Any discovery of human remains/burial goods shall be kept confidential to prevent further disturbance.
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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-117 MM TCR-3 Procedures for Burials and Funerary Remains.

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

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

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

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

If the project cannot be diverted, it may be determined that burials will be removed.

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

F. Each occurrence of human remains and associated funerary objects will be stored using opaque cloth bags. All human remains, funerary objects, sacred objects and objects of cultural patrimony will be removed to a secure container on site if possible. These items should be retained and reburied within six months of recovery. The site of reburial/repatriation shall be in the project limits but at a location agreed upon between the Tribe and the landowner at a site to be protected in perpetuity. There shall be no publicity regarding any cultural materials recovered.

G. The Tribe will work closely with the project’s qualified archaeologist to ensure that the excavation is treated carefully, ethically and respectfully. If data recovery is approved by the Tribe, documentation shall be prepared and shall include (at a minimum) detailed descriptive notes and sketches. All data recovery data recovery-related forms of documentation shall be approved in advance by the 758

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Significance Determination: Potentially Significant Impact Mitigation Measures: As noted in RCM CUL-1 and MMs TCR-1, TCR-2, and TCR-3.

Significance Determination After Mitigation: Less than Significant Impact 759

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4.19 UTILITIES AND SERVICE SYSTEMS
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Require or result in the relocation or construction of new or expanded water, wastewater treatment or
stormwater drainage, electric power, natural gas, or
telecommunications facilities, the construction or
relocation of which could cause significant
environmental effects?
b) Have sufficient water supplies available to serve the project and reasonably foreseeable future
development during normal, dry and multiple dry
years?
c) Result in a determination by the wastewater
treatment provider which serves or may serve the
project that it has adequate capacity to serve the
project’s projected demand in addition to the
provider’s existing commitments?
d) Generate solid waste in excess of State or local
standards, or in excess of the capacity of local
infrastructure, or otherwise impair the attainment of
solid waste reduction goals?
e) Comply with federal, state, and local management
and reduction statutes and regulations related to solid waste?
Impact Analysis
a) Would the project require or result in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
Water. The Water Division of the City of Orange Public Works Department provides domestic water service to the City of Orange, including the project limits. 87 According to the City’s 2020 Urban Water
Management Plan (UWMP),
88 approximately 77 percent of the City’s water supply is sourced from groundwater supplies from the Orange County Groundwater Basin via 12 active wells. The rest of the supply consists of 18 percent imported water and 5 percent surface water. The City imports water from the Metropolitan Water District of Southern California, sourced from the Colorado River via the Colorado River Aqueduct (CRA) and the Lake Oroville watershed in Northern California via the State Water Project. The water obtained from these sources is treated at the Robert B. Diemer Filtration Plant 87 City of Orange. n.d.-b. Water Division. Website: https://www.cityoforange.org/residents/water-division (accessed February 8, 2024).
88 City of Orange. 2021. 2020 Urban Water Management Plan Final. November. Website: https://www.cityof orange.org/home/showpublisheddocument/1540/637873464981170000 (accessed February 8, 2024). 760

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The Orange County Groundwater Basin (OC Basin) covers an area approximately 350 square miles underlying the northerly half of Orange County. The OC Basin is managed by the Orange County Water District (OCWD), which monitors groundwater levels by regulating the annual amount of allowable pumping. The OC Basin’s primary source of recharge is flow from the Santa Ana River, which is diverted into recharge basins and its main Orange County tributary, Santiago Creek. Other sources of recharge water include natural infiltration, recycled water, and imported water. The City’s source of surface water is local water from the Irvine Lake, which is purchased from the Serrano Water District.

The 2020 UWMP projects that by the year 2045, the City’s water supply will consist of 85 percent groundwater, 11 percent imported water, and 4 percent surface water. According to the 2020 UWMP, the City’s projected water supply is able to meet projected water demand in 2025, 2030, 2035, 2040, and 2045. Therefore, the City’s existing water supplies are projected to meet full service demands through the year 2045.

The proposed project consists of widening an existing roadway, the construction of a new pedestrian bridge over Santiago Creek, and traffic signal modification. The proposed project would therefore not result in any new land uses that would increase water consumption beyond existing conditions. Water would be used during construction to reduce fugitive dust in compliance with South Coast Air Quality Management District (SCAQMD) Rules 402 and 403 and during operation of the irrigation of landscaped areas, including the proposed landscaped median. The amount of water used during construction and operation would be minimal, and water use for construction would cease when construction is completed.

Landscaping for the project limits, which would include native trees and shrubs, would not represent a substantial increase in water used for irrigation in comparison to existing conditions within the project limits. The proposed project would be required to comply with the principles of the State Model Water Efficient Landscape Ordinance (adopted City Resolution No. 10413) that requires improvements in the efficiency of water use in existing and new urban irrigated landscapes in California. The proposed project is subject to this ordinance and will be required to implement water-efficient landscaping design (i.e., drought-tolerant landscaping) within the project limits. Refer to Regulatory Compliance Measure (RCM) UTL-1, below. RCM UTL-1 is a standard condition based on local and State regulations or laws that serve to reduce impacts related to water usage. Adherence to RCM UTL-1 would further ensure that project-related water demand would not cause the City’s Water Division’s supply to be exceeded during operations of the proposed project.

Because the proposed project would not increase water demand beyond existing conditions and with adherence to RCM UTL-1, the proposed project would not require or result in the construction of new water facilities or the expansion of existing facilities, and no impact to existing water facilities would occur as a result of the proposed project.
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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-121 Regulatory Compliance Measure:

RCM UTL-1 Water Efficient Landscape Ordinance. Prior to the issuance of a grading permit, the City of Orange Director of Community Development, or designee, shall confirm that the Final Landscaping Plan for the proposed project is consistent with all applicable provisions outlined in the City’s Landscape Water Efficiency Ordinance, as codified in City Resolution No. 10413.

Wastewater. The City’s Public Works Department operates and maintains local wastewater collection facilities, which convey wastewater to the Orange County Sanitation District’s (OCSD) sewer system.

The City’s sewer system includes 312 miles of sewer and two small sewage lift stations. Wastewater in the City is conveyed to and treated at OCSD’s Reclamation Plant No. 1 in Fountain Valley or at Treatment Plant No. 2 in Huntington Beach. Reclamation Plant No. 1 has a design capacity of 108 millions of gallons per day (mgd) with average daily flow of 92 mgd. Treatment Plant No. 2 has an average daily flow of 129 mgd with a design capacity of 168 mgd.89 As stated previously, the proposed project includes improvements to an existing roadway in addition to a new pedestrian bridge. None of the components of the proposed project would introduce wastewater-generating uses to the project limits. As such, development of the proposed project would not contribute to the wastewater received by either OCSD treatment plant. The proposed project therefore would not require, nor would it result in, the construction or relocation of new or expanded wastewater treatment or collection facilities. Project impacts related to the construction of wastewater treatment or collection facilities would be less than significant, and no mitigation would be required.

Stormwater Drainage Facilities. Implementation of the proposed project would increase the pervious surface area within the project limits by approximately 0.1 acre, which could result in a slight decrease in stormwater runoff from the project limits. With implementation of the proposed project, any curb inlets affected by the proposed curb shift or road widening would be replaced along the new alignment to ensure that drainage properties within the project limits is not adversely affected. Therefore, the proposed project would not decrease the capacity of the existing stormwater drainage system through the permanent removal of any drainage facilities. As such, both outermost curbs of Cannon Street would continue to accommodate runoff water originating from the project limits. As previously discussed, the project limits currently consist of a roadway already developed with predominantly impervious surface area and the proposed project would result in a potential decrease of surface runoff in comparison to existing conditions. Therefore, the proposed project would not necessitate the expansion of existing facilities beyond the improvements included as part of the proposed project. Therefore, impacts to stormwater drainage facilities would be less than significant. No mitigation is required.

Electric Power. The City of Orange receives its electrical power from Southern California Edison (SCE), an independently owned utility.90 Refer to Section 4.6, Energy, for a detailed discussion of the proposed project’s impacts with respect to existing and projected supplies of electricity. As discussed further in Section 4.6, the proposed project would not introduce substantial new electricity demand to 89 City of Orange. 2010. City of Orange General Plan Program Environmental Impact Report. March. Website:
https://www.cityoforange.org/home/showpublisheddocument/240/637698173340500000 (accessed February 19, 2024).
90 Southern California Edison (SCE) About Us. Website: https://www.sce.com/about-us/who-we-are#:~:
text=As%20one%20of%20the%20nation%27s,represented%20across%20our%20service%20territory%20. (accessed April 23, 2024).
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4 \\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) -122 the project limits beyond existing conditions and therefore would not require or result in the relocation or construction of new or expanded electric power facilities, the construction of which could cause significant environmental effects. Impacts would be less than significant, and no mitigation would be required.

Natural Gas. Natural gas is provided in the City by the Southern California Gas Company (SoCal Gas). Refer to Section 4.6, for a detailed discussion related to the proposed project’s impacts with respect to existing and projected supplies of natural gas. As discussed further in Section 4.6, the proposed project would not involve the use of natural gas and therefore would not require or result in the relocation or construction of new or expanded gas facilities, the construction of which could cause significant environmental effects. No impacts would occur, and no mitigation would be required.

Telecommunications. Cable, internet, and telephone services are provided to the City’s residents by major third-party purveyors. Cellular services provided by all major cellular networks are available in the City. Construction activities associated with the proposed project would not increase the demand for telecommunications facilities. In addition, the proposed project would not involve the construction or relocation of new or expanded telecommunications facilities. Further, the proposed roadway improvements would not introduce any new residents to the telecommunications service area.

Therefore, implementation of the proposed project would not result in impacts related to the construction or relocation of existing telecommunications facilities, and no mitigation would be required.

Summary. As the proposed project would improve existing uses on site, the supply and distribution network of utilities and service systems would generally remain unchanged. The water, wastewater, stormwater drainage, natural gas, electricity, and telecommunications needs generated by the proposed project would not exceed the existing supply and distribution network, or the available service capacities of the respective service providers. Levels of service to off-site users would not be adversely affected. Project impacts related to the relocation or construction of utilities would be less than significant with compliance with regulatory compliance measures as noted. No mitigation is required.

Significance Determination: Less Than Significant Impact Mitigation Measures: No mitigation is required, but adherence to RCM UTL-1 is required.

Significance Determination After Mitigation: Less Than Significant Impact b) Would the project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years? As previously stated in Response 4.19(a), above, the project would have sufficient water supplies available to serve the proposed project and reasonably foreseeable future development during normal, dry, and multiple dry years through 2045. As such, operation of the proposed project would not cause the City’s Water Division’s available supply to be exceeded in the single dry year or multiple dry year scenarios. Therefore, the proposed project would operate within the Water Division’s current and projected water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years. Impacts related to water supplies would be less than significant and no mitigation is required.
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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-123 Significance Determination: Less Than Significant
Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: Less Than Significant c) Would the project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments? Refer to Response 4.19(a). As the proposed project is limited to roadway improvements, no wastewater would be generated during construction or operation of the proposed project. As such, the proposed project would not result in any of the wastewater treatment plants discussed above exceeding wastewater treatment requirements. Development of the proposed project would not require, nor would it result in, the construction or relocation of new or expanded wastewater treatment or collection facilities. Therefore, no impacts related to wastewater generation would occur, and no mitigation would be required.

Significance Determination: No Impact
Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: No Impact
d) Would the project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
The proposed project would consist of roadway improvements and would generate minimal waste throughout operations. However, the proposed project would generate construction waste that would require processing in local recycling facilities and disposal in local landfills.

The City has an exclusive solid waste franchise agreement with CR&R, Inc., which provides solid trash, recyclables, and organics collection services to the City.91 Additionally, the project limits are located within the Orange County Waste and Recycling (OCWR) service area. OCWR owns and operates three landfills in Orange County that accept municipal solid waste. These include the Frank R. Bowerman Landfill in the City of Irvine, which accepts commercial waste only; the Olinda Alpha Landfill in the City of Brea, which accepts both public and commercial waste; and the Prima Deshecha Landfill in the City of San Juan Capistrano, which also accepts both public and commercial waste. All three landfills are Class III and only accept non-hazardous municipal solid waste.

The Frank R. Bowerman Landfill at 11002 Bee Canyon Access Road in the City of Irvine is the closest OCWR landfill to the project limits, located approximately 8 miles southeast of Cannon Street. The Frank R. Bowerman Landfill spans 725 acres of land and has a projected capacity to serve Orange County until approximately 2053. Its maximum permitted solid waste intake is 11,500 tons per day (TPD) and, on average, processes 8,500 TPD.92
91 City of Orange. n.d.-a. Trash, Recycling, and Organics. Website: https://www.cityoforange.org/residents/ trash-recycling-and-organics (accessed February 9, 2024). 92 Orange County Waste and Recycling. n.d.-a. Frank R. Bowerman Landfill. Website: https://oclandfills.com/ landfills/frank-r-bowerman-landfill (accessed February 9, 2024). 764

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4 \\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) -124 The Olinda Alpha Landfill is located just over 8 miles northwest of the project limits at 1942 Valencia Ave in Brea. The Olinda Alpha Landfill spans 565 acres and has a projected capacity to serve Orange County until approximately 2030. Its maximum permitted solid waste intake is 8,000 TPD and its average rate is 7,000 TPD.93
The Prima Deshecha Landfill is located approximately 24 miles southeast of the project limits at 32250 Avenida La Pata in San Juan Capistrano. The Prime Deshecha Landfill spans 1,530 acres and has a projected capacity to serve Orange County until approximately 2102. Its maximum permitted solid waste intake is 4,000 TPD.94
Pursuant to various State legislation and the California Green Building Code, 65 percent of all materials generated from construction projects within the City must be diverted from landfills. To meet reporting obligations, the City of Orange requires individuals pulling permits with construction and demolition debris to provide information on where the materials will be taken and the percentage of materials diverted from the landfill, which would apply to the proposed project. Therefore, 65 percent of the construction waste generated by the proposed project would be diverted from the OCWR landfills, and the remaining waste would represent a minimal contribution to the landfills’ daily capacity. Therefore, the landfills would provide adequate waste disposal capacity to accept the construction waste and minimal operations waste generated by the proposed project, and project impacts to local solid waste standards and infrastructure would be less than significant.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: Less Than Significant Impact e) Would the project comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
The California Integrated Waste Management Act of 1989 (Assembly Bill [AB] 939) requires each jurisdiction in California to divert at least 50 percent of its waste stream away from landfills either through waste reduction, recycling, or other means. According to the Orange General Plan Infrastructure Element,
95 City efforts to increase waste diversion include maximizing recycling and source reduction to ensure continued compliance with State regulations. The City plans to eliminate landfill waste by improving waste collection services, operating a curbside recycling program, and increasing community knowledge of available waste diversion practices. These efforts will collectively improve the City’s total waste diversion rate.

As discussed in Response 4.19(d), waste generated during construction of the proposed project would be limited to construction debris and would not generate an excessive amount of solid waste that would exceed the capacity of the OCWR landfills. Construction waste would be disposed of in accordance with federal, State, and local regulations including AB 939 as discussed above. CR&R hauls construction waste produced within the City to a Materials Recycling Facility where the recyclable 93 Orange County Waste and Recycling (OCWR). n.d.-b. Olinda Alpha Landfill. Website: https://oclandfills. com/landfills/olinda-landfill (accessed February 9, 2024). 94 Orange County Waste and Recycling (OCWR). n.d.-c. Prima Deshecha Landfill. Website: https://oclandfills. com/landfills/prima-deshecha-landfill (accessed February 9, 2024). 95 City of Orange. 2015. Orange General Plan Infrastructure Element. Website: https://www.cityoforange.org/ home/showpublisheddocument/204/637698172548000000 (accessed February 9, 2024). 765

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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-125 items are removed for processing. Operation of the completed project would generate very limited waste material. Specifically, waste collected during maintenance of the roadway would be collected and disposed of consistent with City policies. Therefore, the proposed project would comply with all federal, State, and local statutes and regulations related to solid waste, and impacts would be less than significant, and no mitigation is required.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: Less Than Significant Impact 766

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4.20 WILDFIRE
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:
a) Substantially impair an adopted emergency response
plan or emergency evacuation plan?
b) Due to slope, prevailing winds, and other factors,
exacerbate wildfire risks, and thereby expose project
occupants to pollutant concentrations from a wildfire
or the uncontrolled spread of a wildfire?
c) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency
water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
d) Expose people or structures to significant risks,
including downslope or downstream flooding or
landslides, as a result of runoff, post-fire slope
instability, or drainage changes?
Impact Analysis
a) If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project substantially impair an adopted emergency response plan or emergency evacuation plan?
As previously discussed in Section 4.9, the California Department of Forestry and Fire Protection (CAL FIRE) has mapped areas of significant fire hazards in the State through its Fire and Resources Assessment Program (FRAP). These maps place areas of California into different fire hazard severity zones (FHSZ), based on a hazard scoring system using subjective criteria for fuels, fire history, terrain influences, housing densities, and occurrence of severe fire weather where urban conflagration could result in catastrophic losses. CAL FIRE currently identifies the proposed project limits, and the City of Orange in its entirety, as a Local Responsibility Area (LRA), in which local fire protection agencies are responsible for wildfires that occur within the area.

According to the CAL FIRE Fire and Resource Assessment Program Fire Hazard Severity Viewer, the project limits are not located within a very high fire hazard severity zone (VHFHSZ), or within a State Responsibility Area (SRA).
96 However, the land directly to the east of the project limits is considered a VHFHSZ. Despite this proximity to a VHFHSZ, the proposed project would utilize land shifts in order to maintain through access during short-term construction activities and therefore is not anticipated to result in any substantial traffic impacts or queueing on nearby streets during construction of the proposed project, as discussed in Section 4.17, Transportation. In addition, all construction 96 California Department of Forestry and Fire Protection (CAL FIRE). 2022. Fire and Resource Assessment Program Fire Hazard Severity Viewer. Website: https://egis.fire.ca.gov/FHSZ/ (accessed February 6, 2024). 767

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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-127 equipment would be staged within temporary construction easements and would not interfere with movement along the Cannon Street corridor.

The City has developed an Emergency Operations Plan, which sets forth emergency preparedness and response procedures, in accordance with State Office of Emergency Services guidelines. According to Figure PS-4, Generalized Evacuation Corridors, of the City’s General Plan Public Safety Element,97 Cannon Street is not designated as an evacuation corridor. The proposed project would improve mobility for northbound traffic along Cannon Street once operational, thus facilitating the movement of emergency vehicles in the event they utilize the Cannon Street roadway.

The proposed project would be required to comply with all applicable codes and ordinances for emergency vehicle access, which would ensure adequate access to, from, and on site for emergency vehicles. Adherence to these codes and ordinances would ensure that construction and operation of the proposed project would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. In the long run, the proposed project would improve traffic operations along Cannon Street within the project limits, thus improving emergency response times along this corridor. As such, the proposed project would not substantially impair an adopted emergency response plan or emergency evacuation plan in the event of wildfire, and no mitigation is required.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: Less Than Significant Impact b) If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project, due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
As discussed in Response 4.20(a), although the project limits are not located within a VHFHSZ, it is located directly adjacent to a VHFHSZ along the eastern boundary of Cannon Street. However, the project limits are relatively flat, and a majority of surrounding area consists of fully developed neighborhoods. Based on the surrounding scale of development, a majority of the project limits lack the combustible materials and vegetation necessary for the uncontrolled spread of a wildfire.

As previously stated, the proposed project includes various roadway improvements to Cannon Street including lane addition, widening, traffic signal modification, and a new pedestrian bridge crossing Santiago Creek. As such, the project itself would not exacerbate wildfire risks as compared to existing conditions because it would improve and continue an existing roadway use in the area and does not propose any inhabitable structures that would expose occupants to wildfire risks. Further, the project limits are not located in or near an SRA or lands classified as VHFHSZ. Therefore, due to the lack of slopes and other risk factors within the project limits, the proposed project would not exacerbate wildfire risks, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire. Impacts would be less than significant, and no mitigation is required. 97 City of Orange. 2015. Orange General Plan Public Safety Element. Website: https://www.cityoforange. org/ home/showpublisheddocument/214/637698172567530000 (accessed February 9, 2024). 768

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4 \\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) -128 Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: Less Than Significant Impact c) If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
The proposed project generally involves improvements to existing infrastructure rather than the installation of new infrastructure. The only new development proposed under the project would be the new pedestrian bridge crossing Santiago Creek, which would clear span the creek and is expected to consist of a prefabricated steel truss, approximately 170 feet long and 12 feet wide. The installation of this bridge would thereby involve the use of nonflammable materials and would not exacerbate fire risk or result in impacts to the environment.

Development located within or adjacent to the identified wildland fire area, as shown in Figure PS-1, Environmental and Natural Hazard Policy Map, of the City’s General Plan Public Safety Element, must prepare and implement a comprehensive fuel modification program in accordance with City regulations.

Furthermore, the project limits are not located in or near an SRA or lands classified as VHFHSZ.

Design and implementation of the proposed roadway improvements would be reviewed and approved by the City’s Public Works Department and the Orange City Fire Department as part of the project approval process to ensure the proposed project is compliant with all applicable design standards and regulations. Therefore, impacts related to exacerbated fire risk associated with infrastructure development would be less than significant, and no mitigation is required.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: Less Than Significant Impact d) If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?
The project limits are located in a relatively flat area and lack sloped areas capable of exposing people or structures to risks associated with landslides and other forms of slope instability. Please refer to Section 4.7, Geology and Soils, of this IS/MND, for more details regarding the topography of the project limits.

According to the Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM) No. 06059C0158J (effective 12/3/2009), most of the project limits are located within Zone X, which is identified as an area of minimal flood hazard, with 0.2 percent annual chance of flood hazard. However, the portion of the project limits that crosses the San Juan Creek is located within Zone AE, which is identified as an area subject to inundation by the 1 percent annual chance flood event (100-year flood event). However, it should be noted that the portion of the project limits identified as within Zone AE 769

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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-129 is located on the Cannon Street bridge that crosses over Santiago Creek, and is therefore elevated above the existing ground surface where the flood hazard exists. Therefore, the project limits are elevated from the risk of downstream flooding.

As described in Section 4.10, Hydrology and Water Quality, during construction activities, soil would be exposed and disturbed, drainage patterns would be temporarily altered, and there would be an increased potential for flooding compared to existing conditions. As specified in Regulatory Compliance Measure ( RCM) HYD-1 would ensure that construction Best Management Practices (BMPs), such as Erosion Control and Sediment Control BMPs, would target and reduce pollutants of concern in stormwater runoff during construction, and on-site storm drain facilities would be adequately sized to accommodate stormwater runoff from the project limits so that on-site flooding would not occur. With incorporation of RCM HYD-1, the proposed project would not exposure people or structures to significant risks, such as flooding, as a result of runoff, post-fire slope instability, or drainage changes during construction. Further, the project limits are not located in or near an SRA or lands classified as VHFHSZ. Design and implementation of the proposed roadway improvements would be reviewed and approved by the City’s Public Works Department and the Orange City Fire Department as part of the project approval process to ensure the proposed project is compliant with all applicable design standards and regulations.

Further, as previously stated, the proposed project proposes roadway improvements to serve drivers and pedestrians who already utilize Cannon Street and does not include any habitable structures that would increase human presence within the project limits. Therefore, the proposed project does not expose people or structures to significant risks, such as landslides, as a result of runoff, post-fire slope instability, or drainage changes. Impacts would be less than significant, and no mitigation is required.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: Less Than Significant Impact 770

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4.21 MANDATORY FINDINGS OF SIGNIFICANCE
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Does the project have the potential to substantially degrade the quality of the environment, substantially
reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below selfsustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number
or restrict the range of a rare or endangered plant or
animal or eliminate important examples of the major
periods of California history or prehistory?
b) Does the project have impacts that are individually
limited, but cumulatively considerable?
(“Cumulatively considerable” means that the
incremental effects of a project are considerable
when viewed in connection with the effects of past
projects, the effects of other current projects, and the effects of probable future projects.)
c) Does the project have environmental effects which
will cause substantial adverse effects on human
beings, either directly or indirectly?
Impact Analysis
a) Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? Based on the discussion in Section 4.4, Biological Resources, the proposed project is anticipated to result in less than significant impacts related to habitat, wildlife species, and/or plant and animal communities with incorporation of Mitigation Measures (MMs) BIO-1 through BIO-6. After mitigation, the proposed project would not threaten or eliminate a plant or animal community nor would it substantially reduce the number or restrict the range of a rare or endangered plant or animal.

As discussed in Section 4.5, Cultural Resources, Response 4.5(a), the project limits do not contain any buildings or structures that meet any of the California Register of Historical Resources (California Register) criteria or qualify as “historical resources” as defined by CEQA. Further, the project limits are not designated as a historical/archaeological landmark by the City of Orange or the County of Orange. Therefore, the proposed project would not cause a substantial adverse change in the significance of a historical resource.

As discussed in Section 4.18, Tribal Cultural Resources, the City requested a search of the Sacred Lands File by the Native American Heritage Commission (NAHC) for the project limits. According to NAHC correspondence, no resources were noted in the database. The City did not receive any communication from the three of the four tribes that requested notification regarding the proposed 771

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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 4-131 project, pursuant to Assembly Bill (AB) 52. One tribe, the Gabrieleño Band of Mission Indians – Kizh Nation, responded with a request to initiate the formal consultation process with the City, during which it was determined that utilization of standard mitigation measures was acceptable to address the Tribe’s concerns regarding the proposed project. As such, Mitigation Measures (MMs) TCR-1 through TCR-3 are applicable to the proposed project, and would reduce potential impacts to tribal cultural resources to a less than significant level.

MM CUL-1 requires cultural resources monitoring during excavation activities and establishes procedures in the event of the discovery of an unknown cultural resource. With implementation of MM CUL-1, impacts to cultural resources would be less than significant. In addition, MM GEO-2 has been incorporated to address the discovery of paleontological resources should they be unearthed during construction. With the application of MM GEO-2 potential impacts to previously undiscovered paleontological resources would be less than significant.

For the reasons stated above, the proposed project does not have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of California history or prehistory.

Impacts would be less than significant with implementation of the mitigation measures identified above.

Mitigation Measures: Refer to MMs BIO-1 through BIO-6 (in Section 4.4, Biological Resources), MM CUL-1 (in Section 4.5, Cultural Resources), and MM GEO-2 (in Section 4.7, Geology and Soils).

Significance Determination: Potentially Significant Impact Mitigation Measures: Refer to MMs BIO-1 through BIO-6, MM CUL-1, MM GEO-2, and MM TCR1 through TCR-3.

Significance Determination After Mitigation: Less Than Significant Impact b) Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)? The proposed project involves improvements to an existing roadway and would not introduce any new land uses to the project limits. The proposed project would rely on and can be accommodated by the existing infrastructure, public services, and utilities. Based on Section 2.0, Project Description, and the preceding responses, impacts related to the proposed project are less than significant or can be reduced to less than significant levels with the incorporation of mitigation measures. Because all potentially significant impacts can be mitigated to a less than significant level, such impacts would not be cumulatively significant. The proposed project’s contribution to any significant cumulative impacts would therefore be less than cumulatively considerable.

Significance Determination: Less Than Significant Impact Mitigation Measures: No Mitigation is Required
Significance Determination After Mitigation: Less Than Significant Impact 772

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Previous sections of this IS/MND reviewed the proposed project’s potential impacts, and standard conditions and mitigation measures related to Biological Resources (MMs BIO-1 through BIO-6 and RCM BIO-1 and RCM BIO-2), Cultural Resources (MM CUL-1 and RCM CUL-1), Geology and Soils (MMs GEO-1 through GEO-4), Hydrology and Water Quality (RCM HYD-1 through RCM HYD-4), Noise (RCM NOI-1), Tribal Cultural Resources (MMs TCR-1 through TCR-3), and Utilities and Service Systems (RCM UTL-1). As concluded in these previous discussions, the proposed project would result in less than significant environmental impacts with adherence to the Regulatory Compliance Measures and implementation of the recommended Mitigation Measures. Therefore, the proposed project would not result in environmental impacts that would cause substantial adverse effects on human beings.

Mitigation Measures: Refer to MMs BIO-1 through BIO-6 (in Section 4.4, Biological Resources), MM CUL-1 (in Section 4.5, Cultural Resources), MMs GEO-1 through GEO-4 (in Section 4.7, Geology and Soils), and MMs TCR-1 through TCR-3 (in Section 4.18, Tribal Cultural Resources). 773

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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 5-1 SECTION 5.0 MITIGATION MONITORING AND REPORTING

PROGRAM

5.1 MITIGATION MONITORING REQUIREMENTS
Public Resources Code (PRC) Section 21081.6 (enacted by the passage of Assembly Bill [AB] 3180) mandates that the following requirements shall apply to all reporting or mitigation monitoring programs:

The public agency shall adopt a reporting or monitoring program for the changes made to the project or conditions of project approval in order to mitigate or avoid significant effects on the environment.

The reporting or monitoring program shall be designed to ensure compliance during project implementation. For those changes which have been required or incorporated into the project at the request of a Responsible Agency or a public agency having jurisdiction by law over natural resources affected by the project, that agency shall, if so requested by the Lead Agency or a Responsible Agency, prepare and submit a proposed reporting or monitoring program.

The Lead Agency shall specify the location and custodian of the documents or other material which constitute the record of proceedings upon which its decision is based. A public agency shall provide the measures to mitigate or avoid significant effects on the environment that are fully enforceable through permit conditions, agreements, or other measures. Conditions of project approval may be set forth in referenced documents which address required mitigation measures or in the case of the adoption of a plan, policy, regulation, or other project, by incorporating the mitigation measures into the plan, policy, regulation, or project design.

Prior to the close of the public review period for a draft Environmental Impact Report (EIR) or Mitigated Negative Declaration (MND), a Responsible Agency, or a public agency having jurisdiction over natural resources affected by the project, shall either submit to the Lead Agency complete and detailed performance objectives for mitigation measures which would address the significant effects on the environment identified by the Responsible Agency or agency having jurisdiction over natural resources affected by the project, or refer the Lead Agency to appropriate, readily available guidelines or reference documents. Any mitigation measures submitted to a Lead Agency by a Responsible Agency or an agency having jurisdiction over natural resources affected by the project shall be limited to measures that mitigate impacts to resources which are subject to the statutory authority of, and definitions applicable to, that agency. Compliance or non-compliance by a Responsible Agency or agency having jurisdiction over natural resources affected by a project with that requirement shall not limit that authority of the Responsible Agency or agency having jurisdiction over natural resources affected by a project, or the authority of the Lead Agency, to approve, condition, or deny projects as provided by this division or any other provision of law.

5.2 MITIGATION MONITORING PROCEDURES
The mitigation monitoring and reporting program has been prepared in compliance with PRC Section 21081.6. The program describes the requirements and procedures to be followed by the City of Orange to ensure that all mitigation measures adopted as part of the proposed project would be carried out as described in this IS/MND. Table 5.A lists each of the mitigation measures and regulatory compliance measures specified in this IS/MND and identifies the party or parties responsible for implementation and monitoring of each measure.
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4.1: Aesthetics
The proposed project would not result in significant adverse impacts related to aesthetics. No mitigation is required.

4.2: Agriculture and Forest Resources
The proposed project would not result in significant adverse impacts related to agriculture and forest resources. No mitigation is required.

4.3: Air Quality
The proposed project would not result in significant adverse impacts related to air quality. No mitigation is required.

4.4: Biological Resources
MM BIO-1 Pre-Construction California Legless Lizard Surveys. If construction activities take place from September through November, a qualified biologist will conduct preconstruction surveys for California legless lizards no more than 48 hours before initial grading and/or ground-disturbing activities in or near areas of sandy, friable soil. This survey will include systematic subsurface searching, as legless lizards are fossorial (burrowing), and staking and fencing the limits of the survey areas with small-mesh construction fencing buried to a minimum depth of 6 to 10 inches below grade would reduce the likelihood of lizards reentering the construction zone.

Potential direct and/or indirect impacts (e.g., noise during construction) could potentially disrupt or otherwise adversely affect bird nesting activities in and/or adjacent to the project impact area. However, implementation of the recommended avoidance measure identified below would reduce potential impacts to nesting birds to less than significant levels. Other avoidance and minimization measures identified below would address potential construction-related impacts to nesting birds.

A qualified biologist Prior to the
commencement of
construction activities, if
taking place from
September through
November
MM BIO-2 Pre-Construction Nesting Bird Surveys and Active Nest Avoidance Buffers. If vegetation removal, construction, or grading activities are planned to take place within the active nesting bird season (February 15 through August 31), a qualified biologist should conduct a pre-construction nesting bird survey no more than 3 days prior to the start of such activities. The nesting bird survey should include the entirety of the project limits and areas immediately adjacent to the limits that could potentially be affected by project-related activities such as noise, vibration, increased human activity, and dust. If any active bird nests are found within areas that could be directly or indirectly impacted by project-related activities, the qualified biologist should establish an appropriate buffer zone around each active nest. The appropriate buffer should be determined by the qualified biologist based on species, location, and the nature of the proposed activities.

Project activities should be avoided within the buffer zone until each nest is deemed no longer active by a qualified biologist.

A qualified biologist Prior to the
commencement of
construction activities, if
taking place within the
active nesting bird
season (February 15
through August 31)
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Regulatory Compliance Measures / Mitigation Measures Responsible Party Timing for RCM or Mitigation Measure
MM BIO-3 Least Bell’s Vireo Protocol Surveys. Ground disturbance or vegetation removal activities within 500 linear feet of least Bell’s vireo habitat from March 1 through July 15 are not authorized. Should minor project activities (i.e., removal of equipment) be required between March 15 to August 31, focused surveys following United States Fish and Wildlife Service (USFWS) protocol for least Bell’s vireo shall be conducted. The physical extent of the survey area shall include all areas within 500 feet of project disturbance. Survey results shall be submitted in writing to the California Department of Fish and Wildlife (CDFW) for review. The Permittee shall not conduct ANY project activities within 500 linear feet of least Bell’s vireo habitat from March 1 through July 15 if nesting birds are present. Nesting status will be determined by a Designated Biologist with expertise with the species in question, utilizing USFWS survey protocols and CDFW review of the nest monitoring data.

Least Bell’s vireo falls under the “May Affect, but Not Likely to Adversely Affect” designation as defined in the Federal Endangered Species Act (FESA) Section 7(a)(2) due to permanent impacts to suitable southern cottonwood-willow riparian forest habitat. Therefore, a Federal consultation between the City of Orange and the USFWS is expected due to the modification of suitable habitat for least Bell’s vireo, as currently planned and designed.

City of Orange Public Works
Department
Prior to the
commencement of minor
project activities (i.e.,
removal of equipment)
between March 15 to
August 31
MM BIO-4 Bat Construction Surveys. A qualified bat biologist shall survey all suitable trees/vegetation within the project limits for bat roosts within 30 days prior to the start of project construction activities. If bats roosts are found within the project limits, the qualified bat biologist shall identify the bats to the species level and evaluate the roosts and/or colony to determine its size and significance. Proposed work in areas with no suitable habitat shall not require a bat survey, as determined by the bat biologist.

A qualified bat biologist Within 30 days prior to
the start of project
construction activities.

MM BIO-5 Tree Trimming and Removal. To the greatest extent feasible, tree trimming/removal activities will be performed outside the bat maternity season (April 1–August 31) to avoid direct impacts to non-volant (flightless) young that may roost in trees or the bridge within the study area. This period also coincides with the typical bird nesting season. If trimming or removal of trees during the bat maternity season cannot be avoided, a qualified bat biologist will monitor tree trimming and removal activities.

City of Orange Public Works
Department
Throughout the duration
of the proposed project’s
construction
MM BIO-6 Night Work Lighting. If night work (i.e., between dusk and dawn) is anticipated within 100 feet of trees where known bat roosting is confirmed, night lighting will be used only in areas of active work and will be focused on the direct area(s) of work and away from the roost entrances to the greatest extent practicable. This measure would minimize visual disturbance and allow bats to continue to utilize the remainder of the area for foraging and night roosting. If bats are showing signs of distress, as determined by the City of Orange Public Works
Department, a qualified bat
biologist
Throughout the duration
of the proposed project’s
construction
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RCM BIO-1 Clean Water Act 401 and 404 Permits & CDFW Streambed Alteration Agreement.

Prior to the issuance of grading and construction permits, the City of Orange Public Works Department shall obtain 401 and 404 permits, issued by USACE, and a CDFW Streambed Alteration Agreement due to the permanent impacts to disturbed southwestern cottonwood-willow riparian forest within wetland/riparian habitat associated with the County of Orange Central/Coastal Natural Community Conservation Plan (NCCP) Reserve System located within the project limits.

City of Orange Public Works
Department
Prior to the issuance of
grading and construction
permits
RCM BIO-2 Tree Removal Permit. Prior to the issuance of grading permits, the City of Orange Public Works Department shall obtain a Tree Removal Permit, issued by the City of Orange (City) Director of Community Services, in accordance with Section 12.32 of the City’s Municipal Code.

City of Orange Director of
Community Services, or
designee
Prior to the issuance of
grading permits

4.5: Cultural Resources
MM CUL-1 Cultural Resources Monitoring and Accidental Discovery. Prior to the commencement of ground-disturbing activities, and in adherence to the recommendations of the cultural resources records search results, the City of Orange Public Works Department shall retain, with approval of the City of Orange (City) Community Development Director, or designee, a qualified archaeological monitor. A monitoring plan shall be prepared by the archaeologist and implemented upon approval by the City. Prior to the commencement of ground-disturbing activities, the City of Orange Public Works Department shall also retain a Native American monitor to be approved by the City Community Development Director, or designee, after consultation with interested tribal and Native American representatives. Both monitors shall be present full-time on the project limits during the first 10 working days when excavation activities will extend below Artificial Fill deposits into native soil. If cultural materials are discovered during excavation, a qualified professional archaeologist shall assess the nature and significance of the find and determine if any additional study or treatment of the find is warranted. Additional studies could include, but would not be limited to, collection and documentation of artifacts, documentation of the cultural resources on State of California Department of Parks and Recreation Series 523 forms, or subsurface testing. If further monitoring is warranted, it shall continue until the monitoring archaeologist determines, based on field observations, that there is no likelihood of encountering intact archaeological cultural resources. If deemed appropriate by the archaeologist, subsequent monitoring may be reduced from full-time to part-time, or to spot-checking. Project personnel shall not collect or move any archaeological materials or human remains and associated materials. To the extent feasible, project activities shall City of Orange Community
Development Director, or
designee
Prior to the
commencement of
ground-disturbing
activities
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avoid these deposits. Upon completion of any monitoring activities, the archaeologist shall prepare a report documenting the methods and results of monitoring activities. The final version of this report shall be submitted to the City of Orange Community Development Department, the South Central Coastal Information Center (SCCIC), and the State Historic Preservation Office, if required.

RCM CUL-1 Human Remains. In the event that human remains are encountered on the project limits, work within 50 feet of the discovery shall be redirected and the County of Orange (County) Coroner notified immediately consistent with the requirements of California Code of Regulations (CCR) Section 15064.5(e). State Health and Safety Code Section 7050.5 states that no further disturbance shall occur until the County Coroner has made a determination of origin and disposition pursuant to Public Resources Code (PRC) Section 5097.98. If the remains are determined to be Native American, the County Coroner shall notify the Native American Heritage Commission (NAHC), which shall determine and notify a Most Likely Descendant (MLD). With the permission of the property owner, the MLD may inspect the site of the discovery. The MLD shall complete the inspection within 48 hours of notification by the NAHC. The MLD may recommend scientific removal and non-destructive analysis of human remains and items associated with Native American burials. Consistent with CCR Section 15064.5(d), if the remains are determined to be Native American and an MLD is notified, the City shall consult with the MLD as identified by the NAHC to develop an agreement for treatment and disposition of the remains. Prior to the issuance of grading permits, the Director of the City Community Development Department, or designee, shall verify that all grading plans specify the requirements of CCR Section 15064.5(e), State Health and Safety Code Section 7050.5, and PRC Section 5097.98, as stated above.

City of Orange Director of
Community Development, or
designee
Throughout the duration
of ground disturbing
activities

4.6: Energy
The proposed project would not result in significant adverse impacts related to energy. No mitigation would be required.

4.7: Geology and Soils
MM GEO-1 Compliance with the Recommendations in the Foundation Report. Prior to the issuance of demolition or grading permits, the City of Orange (City) Public Works Department shall verify that requirements and recommendations in the Foundation Report have been appropriately incorporated into the project plans. All grading operations and construction shall be conducted in conformance with all of the recommendations included in the Foundation Report, which was prepared by Earth Mechanics, Inc., titled Foundation Report Cannon Street Widening Improvement Project Orange, California (Foundation Report) (January 25, 2024) as well as any Final Geotechnical Reports prepared for the project. All recommendations found in the City of Orange Public Works
Department
Prior to the issuance of
demolition or grading
permits; during
construction
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Foundation Report shall be incorporated into project design and shall include, but not be limited to:
• Seismic design recommendations
• Foundation type recommendations
• Lateral pile solutions
• Bridge abutment wall earth pressures
• Approach embankments
• Pavement structural section design
• Construction considerations
Additional site construction plans, including grading plans, shall be reviewed by the project Geotechnical Consultant prior to construction to check for conformance with all of the recommendations of the Foundation Report. Design, grading, and construction shall be performed in accordance with the requirements of the applicable seismic standards identified in the Foundation Report, as well as the recommendations of the project Geotechnical Consultant as summarized in the Foundation Report subject to review by the Public Works Department, prior to the start of grading activities.

If paleontological resources are encountered during the course of ground disturbance, the paleontological monitor shall have the authority to temporarily redirect construction away from the area of the find. In the event that paleontological resources are encountered when a paleontological monitor is not present, work in the immediate area of the find shall be redirected, and the paleontologist or paleontological monitor shall be A qualified paleontologist Prior to ground
disturbing activities
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contacted to assess the find for scientific significance. If determined to be scientifically significant, the fossil shall be collected from the field.

Collected resources shall be prepared to the point of identification, identified to the lowest taxonomic level possible, cataloged, and curated into the permanent collections of a museum repository. At the conclusion of the monitoring program, a Report of Findings shall be prepared to document the results of the monitoring program MM GEO-3 Paleontological Monitoring. Excavation and grading activities in deposits with high paleontological sensitivity (i.e., Old Alluvial Fan Deposits, Unit 3 and the Sespe and Vaqueros Formations, Undifferentiated) shall be monitored by a qualified paleontological monitor following a PRIMP. No monitoring is required for excavations in deposits with no or low paleontological sensitivity (i.e., Artificial Fill and Young Alluvial Fan Deposits above a depth of 10 feet). If paleontological resources are encountered during the course of ground disturbance, the paleontological monitor shall have the authority to temporarily redirect construction away from the area of the find. In the event that paleontological resources are encountered when a paleontological monitor is not present, work in the immediate area of the find shall be redirected, and the paleontologist or paleontological monitor shall be contacted to assess the find for scientific significance. If determined to be scientifically significant, the fossil shall be collected from the field.

A qualified paleontologist Throughout the duration
of ground disturbing
activities
MM GEO-4 Report of Findings. Collected resources shall be prepared to the point of identification, identified to the lowest taxonomic level possible, cataloged, and curated into the permanent collections of a museum repository. At the conclusion of the monitoring program, a report of findings shall be prepared to document the results of the monitoring program.

A qualified paleontologist Within 6 months of the
completion of
paleontological
monitoring

4.8: Greenhouse Gas Emissions
The proposed project would not result in significant adverse impacts related to greenhouse gas emissions. No mitigation would be required.

4.9: Hazards and Hazardous Materials
The proposed project would not result in significant adverse impacts related to hazards and hazardous materials. No mitigation would be required. 780

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4.10: Hydrology and Water Quality
RCM HYD-1 City of Orange Local Implementation Plan. During and post-construction, the Construction Contractor shall comply with the City of Orange’s (City) Local Implementation Plan (LIP) prepared as part of a compliance program to satisfy the requirement of the area-wide Drainage Area Management Plan (DAMP) and the Santa Ana Regional Water Quality Control Board (RWQCB) municipal storm water permit issued to the City. The LIP outlines protocols for citywide projects to implement in order to contribute to regional stormwater pollution control efforts and adhere to the requirements of applicable National Pollutant Discharge Elimination System (NPDES) permits described above.

Post construction, the City shall ensure that all applicable BMPs set forth in the Orange County Drainage Area Management Plan (DAMP) and the City’s LIP are being properly implemented, such as storm drain signage, landscaping with native or drought tolerant species, and landscaped areas designed to infiltrate and/or treat runoff.

Construction Contractor During and postconstruction
RCM HYD-2 Groundwater Discharge Permit. If groundwater dewatering is required during construction of the proposed project, the City of Orange Public Works Department shall submit a Notice of Intent (NOI) for coverage under the permit to the Santa Ana RWQCB at least 60 days prior to the start of excavation activities and anticipated discharge of dewatered groundwater to surface waters in order to obtain coverage under the General Waste Discharge Requirements for Discharges to Surface Waters That Pose an Insignificant (De Minimis) Threat to Water Quality (Groundwater Discharge Permit), Order No. R8-2020-0006, NPDES No. CAG998001. The construction contractor shall comply with the requirements of Order No. R8-2020-0006, NPDES No. CAG998001.

Groundwater dewatering activities shall comply with all applicable provisions in the Groundwater Discharge Permit, including water sampling, analysis, treatment (if required), and reporting of dewatering-related discharges. Upon completion of groundwater dewatering activities, a Notice of Termination shall be submitted to the Santa Ana RWQCB.

City of Orange Public Works
Department
During construction, in
the event that
groundwater
dewatering is required
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RCM HYD-3 MS4 Permit. Prior to construction, the Construction Contractor shall prepare a Water Quality Management Plan (WQMP) using the City’s Non-Priority Projects WQMP Preparation Guidance Manual (Non-Priority Manual), detailing the range of BMPs to be implemented as part of project operations, in accordance with the NPDES Permit and Waste Discharge Requirements for Discharges from the Municipal Separate Storm Sewer Systems (MS4s) Draining the Watersheds Within the Orange County Region, Order No. R8-2009-0030, NPDES No. CAS618030 as amended by Order No. R8-2010- 0062 (MS4 Permit). The City shall ensure the implementation of all applicable Source Control and Site Design BMPs included in the Non-Priority Manual. The City shall implement, maintain and operate all such BMPs in a timely and reasonably diligent manner.

Construction Contractor Prior to construction
RCM HYD-4 City of Orange Municipal Code Chapter 7.01. During and post-construction, the Construction Contractor shall comply with Section 7.01, Water Quality and Stormwater Discharge, of the City of Orange Municipal Code.

Construction Contractor During and postconstruction

4.11: Land Use and Planning
The proposed project would not result in significant adverse impacts related to land use and planning. No mitigation would be required.

4.12: Mineral Resources
The proposed project would not result in significant adverse impacts related to mineral resources. No mitigation would be required. 782

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4.13: Noise
RCM NOI-1 Construction Noise and Vibration. The construction contractor shall limit construction activities to between the hours of 7:00 a.m. and 8:00 p.m., Monday through Friday, and between the hours of 8:00 a.m. and 8:00 p.m. on Saturday. Construction is prohibited outside these hours and on Sundays and federal holidays.

Construction Contractor Throughout the
duration of the
proposed project’s
construction

4.14: Population and Housing
The proposed project would not result in significant adverse impacts related to population and housing. No mitigation would be required.

4.15: Public Services
The proposed project would not result in significant adverse impacts related to public services. No mitigation would be required.

4.16: Recreation
The proposed project would not result in any significant adverse impacts related to recreation. No mitigation would be required.

4.17: Transportation
The proposed project would not result in any significant adverse impacts related to transportation. No mitigation would be required.

4.18: Tribal Cultural Resources
MM TCR-1 Retain a Native American Monitor Prior to Commencement of Ground Disturbing Activities.

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

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

H. The monitor will complete daily monitoring logs that will provide descriptions of the relevant ground-disturbing activities, the types of construction activities performed, locations of ground-disturbing activities, soil types, cultural-related materials, and any other facts, conditions, materials, or discoveries of significance to the Tribe. Monitor logs will identify and describe any discovered TCRs, City of Orange Public Works
Department
Prior to the
commencement of
ground disturbing
activities
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Regulatory Compliance Measures / Mitigation Measures Responsible Party Timing for RCM or Mitigation Measure
including but not limited to, Native American cultural and historical artifacts, remains, places of significance, etc., (collectively, tribal cultural resources, or “TCR”), as well as any discovered Native American (ancestral) human remains and burial goods. Copies of monitor logs will be provided to the project Applicant/lead agency upon written request to the Tribe.

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

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

MM TCR-2 Unanticipated Discovery of Human Remains and Associated Funerary Objects.

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

H. If Native American human remains and/or grave goods are discovered or recognized in the project limits, then all construction activities shall immediately cease. California Health and Safety Code Section 7050.5 dictates that any discoveries of human skeletal material shall be immediately reported to the County Coroner and all ground-disturbing activities shall immediately halt and shall remain halted until the coroner has determined the nature of the remains. If the coroner recognizes the human remains to be those of a Native American or has reason to believe they are Native American, he or she shall contact, by telephone within 24 City of Orange Public Works
Department
Throughout the
duration of ground
disturbing activities
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I. Human remains and grave/burial goods shall be treated alike per California PRC Section 5097.98(d)(1) and (2).

J. Construction activities may resume in other parts of the project limits at a minimum of 200 feet away from discovered human remains and/or burial goods, if the Kizh determines in its sole discretion that resuming construction activities at that distance is acceptable and provides the project manager express consent of that determination (along with any other mitigation measures the Kizh monitor and/or archaeologist deems necessary). (CEQA Guidelines Section 15064.5(f).) K. Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human remains and/or burial goods. Any historic archaeological material that is not Native American in origin (non-TCR) shall be curated at a public, non-profit institution with a research interest in the materials, such as the Natural History Museum of Los Angeles County or the Fowler Museum, if such an institution agrees to accept the material. If no institution accepts the archaeological material, it shall be offered to a local school or historical society in the area for educational purposes.

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

MM TCR-3 Procedures for Burials and Funerary Remains.

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

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

J. The prepared soil and cremation soils are to be treated in the same manner as bone fragments that remain intact. Associated funerary objects are objects that, as part of the death rite or ceremony of a culture, are reasonably believed to have been placed with individual human remains either at the time of death or later; other City of Orange Public Works
Department
Throughout the
duration of ground
disturbing activities
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Regulatory Compliance Measures / Mitigation Measures Responsible Party Timing for RCM or Mitigation Measure
items made exclusively for burial purposes or to contain human remains can also be considered as associated funerary objects. Cremations will either be removed in bulk or by means as necessary to ensure complete recovery of all sacred materials.

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

If the project cannot be diverted, it may be determined that burials will be removed.

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

M. Each occurrence of human remains and associated funerary objects will be stored using opaque cloth bags. All human remains, funerary objects, sacred objects and objects of cultural patrimony will be removed to a secure container on site if possible. These items should be retained and reburied within six months of recovery. The site of reburial/repatriation shall be in the project limits but at a location agreed upon between the Tribe and the landowner at a site to be protected in perpetuity. There shall be no publicity regarding any cultural materials recovered.

N. The Tribe will work closely with the project’s qualified archaeologist to ensure that the excavation is treated carefully, ethically and respectfully. If data recovery is approved by the Tribe, documentation shall be prepared and shall include (at a minimum) detailed descriptive notes and sketches. All data recovery data recoveryrelated forms of documentation shall be approved in advance by the Tribe. If any data recovery is performed, once complete, a final report shall be submitted to the Tribe and the NAHC. The Tribe does NOT authorize any scientific study or the utilization of any invasive and/or destructive diagnostics on human remains. 786

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4.19: Utilities and Service Systems
RCM UTL-1 Water Efficient Landscape Ordinance. Prior to the issuance of a grading permit, the City of Orange Director of Community Development, or designee, shall confirm that the Final Landscaping Plan for the proposed project is consistent with all applicable provisions outlined in the City’s Landscape Water Efficiency Ordinance, as codified in City Resolution No. 10413.

City of Orange Director of
Community Development, or
designee
Prior to the issuance of
a grading permit

4.20: Wildfire
The proposed project would not result in any significant adverse impacts to wildfire. No mitigation would be required.

4.21: Mandatory Findings of Significance
Refer to Mitigation Measures BIO-1 through BIO-6, MM CUL-1, MMs GEO-1 through GEO-4, and MMs TCR-1 through TCR-3. 787

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6.1 CITY OF ORANGE
• Eric Perez, City Project Manager/Assistant Engineer
• Robert Garica, Senior Planner
• Chad Ortlieb, Senior Planner
• Randy Nguyen, Principal Civil Engineer
• Youichi Nakagawa, Senior Civil Engineer

6.2 LSA ASSOCIATES, INC.
• Deborah Pracilio, Principal, Environmental
• Amanda Johnson, Senior Environmental Planner
• Jazmine Estores, Environmental Planner/Project Manager • Olivia Mattair, Environmental Planner
• Arthur Black, Principal, Traffic/Transportation
• Jeremy Rosenthal, Biologist
• Kelly Vreeland, Senior Paleontologist
• Ron Brugger, Senior Air Quality Specialist
• Bianca Martinez, Air Quality Specialist
• Jason Lui, Senior Noise Specialist
• Kevin Nguyendo, Noise Specialist
• Christopher Morgan, Archaeologist
• Rory Goodwin, Cultural Resources Specialist
• Jaimi Starr, Cultural Resources Coordinator
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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 7-1 SECTION 7.0 REFERENCES
SECTION 2.0 PROJECT DESCRIPTION
City of Orange. 2015. Orange General Plan Circulation and Mobility Element. Website:
https://www.cityoforange.org/home/showpublisheddocument/192/637698172525970000 (accessed April 10, 2024).

City of Orange. 2020. Zoning Map. September. Website: https://www.cityoforange.org/home/ show publisheddocument/40/637707607413300000 (accessed April 10, 2024).

Orange County Transportation Authority (OCTA). 2023. Traffic Flow Map 2023. August. Website:
https://maps.octa.net/portal/home/item.html?id=ef1e93c895ae4357ab5f9bc3e3daa20f (accessed April 12, 2024).

SECTION 4.1: AESTHETICS
California Department of Transportation (Caltrans). 2018. California State Scenic Highway System Map. Website: https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd 3d807c46cc8e8057116f1aacaa (accessed February 12, 2024).

City of Orange. 2010. Orange General Plan Program Environmental Impact Report (PEIR). March 2010. Website: https://www.cityoforange.org/home/showpublisheddocument/ 240/6376981 73340500000 (accessed March 2024).

City of Orange. 2010. Orange General Plan Circulation and Mobility Element. March 2010. Website:
https://www.cityoforange.org/home/showpublisheddocument/192/637698172525970000 (accessed March 21, 2024).

City of Orange. 2010. Orange General Plan Urban Design Element. March 2010. Website:
https://www.city oforange.org/home/showpublisheddocument/218/637698172574570000 (accessed March 21, 2024).

SECTION 4.2: AGRICULTURE AND FORESTRY RESOURCES
City of Orange. 2015. Orange General Plan Land Use Element. Website: https://www.cityof orange.org/home/showpublisheddocument/208/637698172555630000 (accessed February 9, 2024).

City of Orange. 2020. City of Orange Zoning Map. September. Website: https://www.cityoforange. org/home/showpublisheddocument/40/637707607413300000 (accessed February 9, 2024).

SECTION 4.3: AIR QUALITY
California Department of Conservation (DOC). California Geological Survey. n.d. Asbestos. Website:
https://www.conservation.ca.gov/cgs/minerals/mineral-hazards (accessed April 15, 2024).

LSA Associates, Inc. (LSA). 2024. Proposed Improvements to Cannon Street Traffic Assessment Memorandum. October 2024.
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7 \\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) -2 South Coast Air Quality Management District (SCAQMD). 2008. Final Localized Significance Threshold Methodology. July. Website: http://www.aqmd.gov/docs/default-source/ceqa/hand book/localized-significance-thresholds/final-lst-methodology-document.pdf (accessed April 15, 2024).

South Coast Air Quality Management District (SCAQMD). 2022. Final 2022 Air Quality Management Plan. December 2.

SECTION 4.4: BIOLOGICAL RESOURCES
California Department of Fish and Wildlife (CDFW). 2021. California Natural Diversity Database.

RareFind 5 (Version 5.3.0) website: https://www.wildlife.ca.gov/Data/CNDDB/Maps-andData (May and June 2023).

California Research Bureau. 2001. Natural Community Conservation Planning (NCCP). March.

Website: file:///C:/Users/OMattair/Downloads/NCCP%20The%20Origins%20of%20an%20 Ambitious%20Experiment%20to%20Protect%20Ecosystems.pdf (accessed March 5, 2024).

City of Orange. 2010. City of Orange General Plan Program Environmental Impact Report.

March. Website: https://www.cityoforange.org/home/showpublisheddocument/240/637698 173340500000 (accessed March 5, 2024).

United States Army Corps of Engineers_(USACE). 2008. Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Region (Version 2.0), J.S. Wakeley, R.W.

Lichvar, and C.V. Noble, eds. ERDC/EL TR 08 28. Vicksburg, MS: United States Army Engineer Research and Development Center.

SECTION 4.5: CULTURAL RESOURCES
City of Orange. 2010. City of Orange General Plan Program Environmental Impact Report.

March. Website: https://www.cityoforange.org/home/showpublisheddocument/240/63769817 3340500000 (accessed February 20, 2024).

City of Orange. 2015. Orange General Plan Cultural Resources and Historic Preservation Element.

December. Website: https://www.cityoforange.org/home/showpublisheddocument/196/63769 8172534300000 (accessed February 20, 2024).

City of Orange. n.d. Old Towne Orange. Website: https://www.cityoforange.org/our-city/visitorinformation/old-towne-orange (accessed February 20, 2024).

SECTION 4.6: ENERGY
California Energy Commission (CEC). 2019. California Energy Consumption Database. Website:
http://www.ecdms.energy.ca.gov/ (accessed March 13 and April 10, 2024).

California Energy Commission (CEC). 2024. 2023 Integrated Energy Policy Report. February.

Website: https://www.energy.ca.gov/data-reports/reports/integrated-energy-policy-report/ 2023-integrated-energy-policy-report (accessed April 10, 2024). 791

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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 7-3 Southern California Edison (SCE). 2020. About Us. Website: https://www.sce.com/about-us/who-weare (accessed April 10, 2024).

Southern California Gas (SoCalGas). n.d. Company Profile. Website: https://www.socalgas.com/ about-us/company-profile (accessed March 13, 2024).

United States Energy Information Administration (EIA). 2020. California State Profile and Energy Estimates. Table F3: Motor gasoline consumption, price, and expenditure estimates, 2017.

Website: eia.gov/state/seds/data.php?incfile=/state/seds/sep_fuel/html/fuel_mg.html&sid= CA (accessed April 10, 2024).

SECTION 4.7: GEOLOGY AND SOILS
California Department of Conservation (DOC). 2021. California Earthquake Hazards Zone Application. September. Website: https://www.conservation.ca.gov/cgs/geohazards/eq-zapp (accessed April 11, 2024).

City of Orange. 2015. Orange General Plan Public Safety Element. Website: https://www.cityof orange. org/home/showpublisheddocument/214/637698172567530000 (accessed February 20 and April 11, 2024).

County of Orange. 2012. Orange County General Plan. Website: https://ocds.ocpublicworks .com/service-areas/oc-development-services/planning-development/codes-andregulations/general-plan (accessed February 20, 2024).

Earth Mechanics, Inc. 2024. Foundation Report Cannon Street Widening Improvement Project Orange, California. January 25, 2024.

LSA Associates, Inc. (LSA). 2024. Paleontological Analysis of the Cannon Street Widening Project, City of Orange, Orange County, California. Jacob Biewer. April 12, 2024.

SECTION 4.8: GREENHOUSE GAS EMISSIONS
LSA Associates, Inc. (LSA). 2024. Proposed Improvements to Cannon Street Traffic Assessment Memorandum. October 2024.

SECTION 4.9: HAZARDS AND HAZARDOUS MATERIALS
California Department of Forestry and Fire Protection (CAL FIRE). 2022. Fire and Resource Assessment Program Fire Hazard Severity Viewer. Website: https://egis.fire.ca.gov/FHSZ/ (accessed February 6, 2024).

California Department of Toxic Substances Control (DTSC). n.d. EnviroStor Database. Website:
https://www.envirostor.dtsc.ca.gov/public/ (accessed April 9, 2024).

California Environmental Protection Agency (CalEPA). 2024. Cortese List Data Resources. Website:
https://calepa.ca.gov/sitecleanup/corteselist/ (accessed April 9, 2024).

California Environmental Protection Agency (CalEPA). n.d.-a. List of “Active” CDO and CAO from Water Board (accessed April 9, 2024).
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7 \\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) -4 California Environmental Protection Agency (CalEPA). n.d.-b. Sites Identified with Waste Constituents Above Hazardous Waste Levels Outside the Waste Management Unit. Website:
https://calepa.ca.gov/wp-content/uploads/sites/6/2016/10/SiteCleanup-CorteseListCurrentList.pdf (accessed April 9, 2024).

City of Orange. 2015. Orange General Plan Public Safety Element. Website: https://www. .org/home/ showpublisheddocument/214/637698172567530000 (accessed February 9, 2024).

Orange County Airport Land Use Commission (OCALUC). 2008. Airport Environs Land Use Plan for John Wayne Airport. April 17. Website: https://files.ocair.com/media/2021-02/JWA_AELUPApril-17-2008.pdf?VersionId=cB0byJjdad9OuY5im7Oaj5aWaT1FS.vD (accessed April 9, 2024).

Orange County Airport Land Use Commission (OCALUC). 2019. Airport Environs Land Use Plan for Fullerton Municipal Airport. February 21. Website: https://files.ocair.com/media/202102/ AELUP%20for%20FMA%2005092019.pdf (accessed April 9, 2024).

State Water Resources Control Board (SWRCB). n.d. GeoTracker Database. Website: https://geo tracker.waterboards.ca.gov/ (accessed April 9, 2024).

SECTION 4.10: HYDROLOGY AND WATER QUALITY
California Department of Conservation (DOC). 2019. Orange County Tsunami Inundation Maps.

Website: https://www.conservation.ca.gov/cgs/tsunami/maps/orange (accessed April 19, 2024).

City of Orange. 2005. Non-Priority Projects WQMP Preparation Guidance Manual. December.

Website: https://www.cityoforange.org/home/showpublisheddocument/182/637698164 909270000 (accessed April 25, 2024).

City of Orange. 2011. Storm Water Local Implementation Plan (LIP). July. Website: https://www. cityoforange.org/home/showpublisheddocument/500/637702460732200000 (accessed April 25, 2024).

SECTION 4.11: LAND USE AND PLANNING
City of Orange. 2015. Orange General Plan Circulation and Mobility Element. Website: https://www. cityoforange.org/home/showpublisheddocument/192/637698172525970000 (accessed April 10, 2024).

City of Orange. 2020. Zoning Map. September. Website: https://www.cityoforange.org/home/show publisheddocument/40/637707607413300000 (accessed April 10, 2024).

Southern California Association of Governments (SCAG). 2024. Connect SoCal: Regional Transportation Plan/Sustainable Communities Strategy. April 4. Website: https://scag.ca. gov/sites/main/files/file-attachments/23-2987-connect-socal-2024-final-complete040424.pdf?1714175547 (accessed October 2024). 793

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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 7-5 SECTION 4.12: MINERAL RESOURCES
California Department of Conservation Division of Mine Reclamation. 2016. Mines Online. Website:
https://maps.conservation.ca.gov/mol/index.html (accessed February 6, 2024).

City of Orange. 2015. Orange General Plan Natural Resources Element. Website: https://www.cityof orange.org/home/showpublisheddocument/210/637698172559270000 (accessed February 5, 2024).

Miller, R.V. 1995. Update of Mineral Land Classification of Portland Cement Concrete Aggregate in Ventura, Los Angeles, and Orange Counties, California, Part III - Orange County.

United States Geological Survey (USGS). 2011. Mineral Resources Data System (MRDS). Website:
https://mrdata.usgs.gov/mrds/ (accessed February 6, 2024).

SECTION 4.13: NOISE
California Department of Transportation (Caltrans). 2020. Transportation and Construction Vibration Guidance Manual.

City of Orange. 2015. Orange General Plan Noise Element. December. Website: https://www.cityof orange.org/home/showpublisheddocument/212/637698172563500000 (accessed April 8, 2024).

City of Villa Park. 2010. Villa Park General Plan Noise Element. Website: http://villapark.org/Portals/ 0/Documents/Departments/Planning/General%20Plan/Noise%20Element/VII.%20 Noise.pdf?ver=SeS8ZAYPuu6mBDm4nrU4Vw%3d%3d&timestamp=1712616513224 (accessed April 8, 2024).

Federal Highway Administration (FHWA). 2006. FHWA Highway Construction Noise Handbook, Table 9.1.

Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment Manual.

FTA Report No. 0123. September. Website: https://www.transit.dot.gov/sites/fta. dot.gov/files/docs/research-innovation/118131/transit-noise-and-vibration-impact-assessment -manual-fta-report-no-0123_0.pdf (accessed March 2024).

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City of Orange. 2015. Orange General Plan Natural Resources Element. Website: https://www.cityof orange.org/home/showpublisheddocument/210/637698172559270000 (accessed February 19, 2024).

City of Orange. 2023. Fiscal Year 2023-24 Budget. June 27. Website: https://www.cityoforange. org/ home/showpublisheddocument/4662/638302921366700000 (accessed February 19, 2024).

City of Orange. n.d. Facility Directory Table List. Website: https://www.cityoforange.org/Home/ Components/FacilityDirectory/FacilityDirectory/24/32?npage=2&sortn=FCName &sortd=desc (accessed February 19, 2024).

Orange City Fire Department (OCFD). 2023. 2023 Orange City Fire Annual Report. December.

Website: https://static1.squarespace.com/static/62c47583a67bd82b35d529e7/t/6657e4b42857 6c38703866f6/1717036216155/2023+Orange+City+Fire+Annual+Report+-+%28Website %29.pdf (accessed July 31, 2024).

Orange Unified School District (OUSD). n.d. School Locator. Website: https://portal.schoolsite locator. com/apps/ssl/?districtcode=57964# (accessed February 19, 2024).

State of California Department of Finance. 2023. Population and Housing Estimates for Cities, Counties, and the State - January 1, 2022, and 2023. May. Website: https://dof.ca.gov/ forecasting/demographics/estimates-e1/ (accessed February 19, 2024).

SECTION 4.16: RECREATION
City of Orange. 2015. Orange General Plan Natural Resources Element. Website: https://www.cityof orange.org/home/showpublisheddocument/210/637698172559270000 (accessed February 19, 2024).

SECTION 4.17: TRANSPORTATION
City of Orange. 2015. Orange General Plan Circulation and Mobility Element. Website:
https://www.cityoforange.org/home/showpublisheddocument/192/637698172525970000 (accessed April 10, 2024).

City of Orange. 2015. Orange General Plan Public Safety Element. Website: https://www.cityoforange. org/home/showpublisheddocument/214/637698172567530000 (accessed February 9, 2024).

City of Orange. 2020. Traffic Impact Analysis Guidelines for Vehicle Miles Traveled and Level of Service Assessment. July.

Governor’s Office of Planning and Research (OPR). 2018. Technical Advisory on Evaluating Transportation Impacts in CEQA. April. Website: https://opr.ca.gov/docs/20180416- 743_Technical_ Advisory_4.16.18.pdf (accessed April 10, 2024).

LSA Associates, Inc. (LSA). 2024. Proposed Improvements to Cannon Street Traffic Assessment Memorandum. October 2024.
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\\aznasunifiler2\projects\2023\20230893 - City of Orange Cannon St Widening\ISMND\Cannon St Widening Draft ISMND Rev 10-28-24.docx (10/28/24) 7-7 SECTION 4.19: UTILITIES AND SERVICE SYSTEMS
City of Orange. 2010. City of Orange General Plan Program Environmental Impact Report.

March. Website: https://www.cityoforange.org/home/showpublisheddocument/240/ 637698173340500000 (accessed February 19, 2024).

City of Orange. 2015. Orange General Plan Infrastructure Element. Website: https://www.cityof orange.org/home/showpublisheddocument/204/637698172548000000 (accessed February 9, 2024).

City of Orange. 2021. 2020 Urban Water Management Plan Final. November. Website: https://www. cityoforange.org/home/showpublisheddocument/1540/637873464981170000 (accessed February 8, 2024).

City of Orange. n.d.-a. Trash, Recycling, and Organics. Website: https://www.cityoforange.org/ residents/trash-recycling-and-organics (accessed February 9, 2024).

City of Orange. n.d.-b. Water Division. Website: https://www.cityoforange.org/residents/waterdivision (accessed February 8, 2024).

Orange County Waste and Recycling (OCWR). n.d.-a. Frank R. Bowerman Landfill. Website:
https://oclandfills.com/landfills/frank-r-bowerman-landfill (accessed February 9, 2024).

Orange County Waste and Recycling (OCWR). n.d-b. Olinda Alpha Landfill. Website:
https://oclandfills.com/landfills/olinda-landfill (accessed February 9, 2024).

Orange County Waste and Recycling (OCWR). n.d.-c. Prima Deshecha Landfill. Website:
https://ocland fills.com/landfills/prima-deshecha-landfill (accessed February 9, 2024).

Southern California Edison (SCE) About Us. Website: https://www.sce.com/about-us/who-weare#:~:text=As%20one%20of%20the%20nation%27s,represented%20across%20our%20serv ice%20territory%20. (accessed April 23, 2024).

SECTION 4.20: WILDFIRE
California Department of Forestry and Fire Protection (CAL FIRE). 2022. Fire and Resource Assessment Program Fire Hazard Severity Viewer. Website: https://egis.fire.ca.gov/FHSZ/ (accessed February 6, 2024).

City of Orange. 2015. Orange General Plan Public Safety Element. Website: https://www.cityof orange. org/home/showpublisheddocument/214/637698172567530000 (accessed February 9, 2024). 796

C A N N O N S T R E E T WI D E N I N G P R O J E C T

OR A N G E, C A L I F O R N I A

I N I T I A L S T U D Y /MI T I G A T E D NE G A T I V E DE C L A R A T I O N OC T O B E R 2 0 24
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797

I N I T I A L S T U D Y /MI T I G A T E D NE G A T I V E DE C L A R A T I O N OC T O B E R 2 0 24

C A N N O N S T R E E T WI D E N I N G P R O J E C T

OR A N G E , C A L I F O R N I A
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APPENDIX A

AQ/GHG MEMO/CALEEMOD OUTPUT
(LSA ASSOCIATES, INC., JULY 2024)
798

C A N N O N S T R E E T WI D E N I N G PR O J E C T

OR A N G E , C A L I F O R N I A

I N I T I A L S T U D Y /MI T I G A T E D NE G A T I V E DE C L A R A T I O N OC T O B E R 2 0 24

C A N N O N S T R E E T WI D E N I N G P R O J E C T

OR A N G E , C A L I F O R N I A
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APPENDIX B

BIOLOGICAL RESOURCES ASSESSMENT
(LSA ASSOCIATES, INC., APRIL 2024)
800

C A N N O N S T R E E T WI D E N I N G PR O J E C T

OR A N G E , C A L I F O R N I A

I N I T I A L S T U D Y /MI T I G A T E D NE G A T I V E DE C L A R A T I O N OC T O B E R 2 0 24

C A N N O N S T R E E T WI D E N I N G P R O J E C T

OR A N G E , C A L I F O R N I A
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APPENDIX C

FOUNDATION REPORT
(EARTH MECHANICS, INC., JANUARY 2024)
802

C A N N O N S T R E E T WI D E N I N G PR O J E C T

OR A N G E , C A L I F O R N I A

I N I T I A L S T U D Y /MI T I G A T E D NE G A T I V E DE C L A R A T I O N OC T O B E R 2 0 24

C A N N O N S T R E E T WI D E N I N G P R O J E C T

OR A N G E , C A L I F O R N I A
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APPENDIX D

PALEO ASSESSMENT
(LSA ASSOCIATES, INC., APRIL 2024)
804

C A N N O N S T R E E T WI D E N I N G PR O J E C T

OR A N G E , C A L I F O R N I A

I N I T I A L S T U D Y /MI T I G A T E D NE G A T I V E DE C L A R A T I O N OC T O B E R 2 0 24

C A N N O N S T R E E T WI D E N I N G P R O J E C T

OR A N G E , C A L I F O R N I A
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APPENDIX E

NOISE MEMO
(LSA ASSOCIATES, INC., APRIL 2024)
806

C A N N O N S T R E E T WI D E N I N G PR O J E C T

OR A N G E , C A L I F O R N I A

I N I T I A L S T U D Y /MI T I G A T E D NE G A T I V E DE C L A R A T I O N OC T O B E R 2 0 24

C A N N O N S T R E E T WI D E N I N G P R O J E C T

OR A N G E , C A L I F O R N I A
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APPENDIX F

TRAFFIC TECHNICAL ASSESSMENT MEMO
(LSA ASSOCIATES, INC., OCTOBER 2024)
808

C A N N O N S T R E E T WI D E N I N G PR O J E C T

OR A N G E , C A L I F O R N I A

I N I T I A L S T U D Y /MI T I G A T E D NE G A T I V E DE C L A R A T I O N OC T O B E R 2 0 24

C A N N O N S T R E E T WI D E N I N G P R O J E C T

OR A N G E , C A L I F O R N I A
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APPENDIX G

NATIVE AMERICAN CONSULTATION RECORD
810

C A N N O N S T R E E T WI D E N I N G PR O J E C T

OR A N G E , C A L I F O R N I A

I N I T I A L S T U D Y /MI T I G A T E D NE G A T I V E DE C L A R A T I O N OC T O B E R 2 0 24
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811
Current Condition
Cannon Street Widening
City of Orange 812
Agenda Item
City Council
Item #: 3.29. 6/24/2025 File #: 25-0327
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Christopher Cash, Public Works Director

1. SUBJECT
Adoption of a finding of exemption from the California Environmental Quality Act for the City of Orange Wells 25 and 27 Project. Resolution No. 11617.

2. SUMMARY
In 2019, Orange County Water District, who manages the groundwater basins of north and central Orange County, conducted a study to address the treatment of per- and polyfluoroalkyl substances, as required by the California State Water Resources Control Board Division of Drinking Water. At Wells 25 and 27, water quality sampling indicated elevated levels of these substances with concentrations exceeding the Division of Drinking Water’s Response Levels, indicating the need for treatment systems at these sites. The design and construction of treatment system facilities for these well sites are being fully funded by the Orange County Water District. Adoption of Resolution No. 11617 is necessary to support Orange County Water District’s effort to apply for available grants to fund the construction costs of the treatment systems at these two wells.

3. RECOMMENDED ACTION
Adopt Resolution No. 11617. A Resolution of the City Council of the City of Orange adopting the exemption from the California Environmental Quality Act (CEQA) for Wells 25 & 27 PFOA and PFOS Treatment Plants Construction and Operation.

4. FISCAL IMPACT
None.

5. STRATEGIC PLAN GOALS
Goal 5: Improve Infrastructure, Mobility, and Technology

6. DISCUSSION AND BACKGROUND
Under the Bipartisan Infrastructure Law, $5 billion has been set aside through the Drinking Water State Revolving Fund Program administered by the State Water Resources Control Board (SWRCB) for projects that will reduce people’s exposure to per- and polyfluoroalkyl (PFAS) and other Emerging Contaminants (EC). The SWRCB will provide one hundred percent as principal forgiveness (i.e., a federal grant) and up to $5,000,000 in funding for each qualified applicant. Eligible projects include the construction of new treatment facilities that address EC/PFAS, such as the City of Orange Wells 25 and 27 PFAS Treatment Systems Project. Orange County Water District (OCWD) is not City of Orange Page 1 of 2 Printed on 6/19/2025
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Item #: 3.29. 6/24/2025 File #: 25-0327
25 and 27 PFAS Treatment Systems Project. Orange County Water District (OCWD) is not considered as a qualified applicant for the PFAS grant because OCWD does not own nor operate any PFAS-contaminated wells in its service area. Therefore, OCWD is requesting assistance from the City of Orange to apply for the PFAS grant.

Per the PFAS Treatment Facilities and Program Agreement, OCWD has financed, in its entirety, the technical feasibility study, design, and construction of the City of Orange Wells 25 and 27 PFAS Treatment Systems Project, which is scheduled to be completed in 2027. The total project budget is approximately $12,000,000, with construction costs of $7,600,000. Per the Agreement, the City of Orange is to support and assist OCWD in the pursuit of any PFAS grants that may be used to fund project construction. The receipt of this grant would minimize future replenishment assessment (i.e., groundwater fees) cost increases from OCWD, fees which are passed through to the customer in the City of Orange’s water rates.

If the PFAS grant funding agreement were executed, the City would be the recipient of grant funds as the owner and the operator of the PFAS water treatment systems. The City would serve as a “pass through” agency between SWRCB and OCWD, and the net financial impact to the City would be zero. OCWD would submit invoice(s) to the City that total to the grant amount. The City would need to pay OCWD as “proof of payment” before seeking and receiving grant reimbursement from the SWRCB.

The City’s adoption of an Authorization Resolution is a requirement of the PFAS grant application and is needed to execute a grant funding agreement with the SWRCB.

7. ENVIRONMENTAL REVIEW
The City of Orange Wells 25 and 27 Project is exempt from the California Environmental Quality Act (CEQA) pursuant to Section 15303 of the CEQA Guidelines because it consists of the construction and operation of small treatment plants and associated connection facilities at previously disturbed sites, representing the development of limited numbers of new small facilities and structures intended to improve water quality by removing pollutants from groundwater and would not result in any significant impacts to the environment.

8. ATTACHMENTS
· Resolution No. 11617
City of Orange Page 2 of 2 Printed on 6/19/2025
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Agenda Item
City Council
Item #: 3.29. 6/24/2025 File #: 25-0327
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Christopher Cash, Public Works Director

1. SUBJECT
Adoption of a finding of exemption from the California Environmental Quality Act for the City of Orange Wells 25 and 27 Project. Resolution No. 11617.

4. FISCAL IMPACT
None.

5. STRATEGIC PLAN GOALS
Goal 5: Improve Infrastructure, Mobility, and Technology

6. DISCUSSION AND BACKGROUND
Under the Bipartisan Infrastructure Law, $5 billion has been set aside through the Drinking Water State Revolving Fund Program administered by the State Water Resources Control Board (SWRCB) for projects that will reduce people’s exposure to per- and polyfluoroalkyl (PFAS) and other Emerging Contaminants (EC). The SWRCB will provide one hundred percent as principal forgiveness (i.e., a federal grant) and up to $5,000,000 in funding for each qualified applicant. Eligible projects include the construction of new treatment facilities that address EC/PFAS, such as the City of Orange Wells 25 and 27 PFAS Treatment Systems Project. Orange County Water District (OCWD) is not City of Orange Page 1 of 2 Printed on 6/19/2025
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Item #: 3.29. 6/24/2025 File #: 25-0327
25 and 27 PFAS Treatment Systems Project. Orange County Water District (OCWD) is not considered as a qualified applicant for the PFAS grant because OCWD does not own nor operate any PFAS-contaminated wells in its service area. Therefore, OCWD is requesting assistance from the City of Orange to apply for the PFAS grant.

The City’s adoption of an Authorization Resolution is a requirement of the PFAS grant application and is needed to execute a grant funding agreement with the SWRCB.

8. ATTACHMENTS
· Resolution No. 11617
City of Orange Page 2 of 2 Printed on 6/19/2025
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RESOLUTION NO. 11617

A RESOLUTION OF THE CITY COUNCIL OF THE

CITY OF ORANGE ADOPTING THE EXEMPTION

FROM THE CALIFORNIA ENVIRONMENTAL
QUALITY ACT (CEQA) FOR WELLS 25 & 27 PFOA

AND PFOS TREATMENT PLANTS CONSTRUCTION
AND OPERATION.

WHEREAS, the City of Orange (the “City”) is a municipal corporation which exercises governmental functions and powers and is organized and existing under the laws of the State of California; and
WHEREAS, the City of Orange staff determined that a treatment plant for PFOA and PFOS compounds is required to reduce concentrations in drinking water extracted from the groundwater basin at existing and future well connections; and
WHEREAS, the City of Orange, in its capacity under the California Environmental Quality Act (CEQA), has conducted an evaluation of the potential for environmental impacts associated with the City of Orange Wells 25 & 27 Project; and
WHEREAS, such evaluation determined that the Project is consistent with the applicable Categorical Exemption (Class 3, Section 15303) under CEQA as it consists of the construction and operation of small treatment plants and associated connection facilities at previously disturbed sites representing the development of limited numbers of new, small facilities or structures and it would not result in any significant impacts to the environment.

NOW, THEREFORE, the City Council of the City of Orange resolves, finds and determines, on the basis of the facts set forth in the agenda report presented to it, as follows:

Adopts the finding that the City of Orange Wells 25 & 27 Project is exempt from CEQA pursuant to Section 15303 of the CEQA Guidelines because it consists of the construction and operation of small treatment plants and associated connection facilities at previously disturbed sites representing the development of limited numbers of new, small facilities or structures and it would not result in any significant impacts to the environment.The foregoing recitals are true and correct.

ADOPTED this ____ day of ____________________, 2025
Daniel R. Slater, Mayor, City of Orange
ATTEST:

Pamela Coleman, City Clerk, City of Orange
817
2 APPROVED AS TO FORM:

Wayne W. Winthers
Interim City Attorney, 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 , 2025 by the following vote:

AYES: COUNCILMEMBERS:

NOES: COUNCILMEMBERS:

ABSENT: COUNCILMEMBERS:

ABSTAIN: COUNCILMEMBERS:

Pamela Coleman, City Clerk, City of Orange
818
Agenda Item
City Council
Item #: 3.30. 6/24/2025 File #: 25-0347
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Christopher Cash, Public Works Director

1. SUBJECT
Status and update of the Circulation Element and Mitigation Fee Program for the Measure M2 Program. Resolution No. 11618.

2. SUMMARY
Annual Submittal of Measure M2 eligibility documentation to the Orange County Transportation Authority is required to remain eligible to receive Measure M2 sales tax revenue funds. The submittal documentation for this year requires that the City Council adopt a Seven-Year Capital Improvement Program and adopt a resolution that attests to the consistency of the City’s General Plan Circulation Element and confirms that the City’s Mitigation Fee Program assesses traffic impacts of new development.

3. RECOMMENDED ACTION

1. Adopt Resolution No. 11618. A Resolution of the City Council of the City of Orange concerning the status and update of the circulation element, and mitigation fee program for the Measure M (M2) program.

2. Authorize staff to submit M2 eligibility documentation to the Orange County Transportation Authority (OCTA).

4. FISCAL IMPACT
None.

5. STRATEGIC PLAN GOALS
Goal 5: Improve Infrastructure, Mobility, and Technology.

6. DISCUSSION AND BACKGROUND
In November 1990, voters of Orange County approved Measure M, a half-cent sales tax for transportation improvements. The sales tax included funding for the streets that was available to local agencies through a formal distribution and a competitive funding application. In November 2006, voters approved Measure M2 to continue the half-cent sales tax for an additional 30 years, beginning at the expiration of Measure M in 2011. Major improvement plans target Orange County freeways, streets and roads, transit, and environmental programs. As part of the Measure M2 funding request, the City is required to submit resolutions that verify that the City has a Seven-Year Capital Improvement Program (CIP), a Mitigation Fee Program, and Master Plan of Arterial Highway (MPAH) City of Orange Page 1 of 2 Printed on 6/19/2025
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Item #: 3.30. 6/24/2025 File #: 25-0347
Circulation Element Consistency.

Seven-Year Capital Improvement Program
The City’s Measure M2 Seven-Year CIP for Fiscal Years 2025-2026 through 2031-2032 is a transportation planning and fiscal forecasting document that is utilized to navigate programming for existing and future capital improvement projects. The Measure M2 Seven-Year CIP is consistent with the City’s proposed CIP for Fiscal Year 2025-2026.

While the annual submittal of the City’s Measure M2 CIP does not commit to the City to fund identified improvements, projects must be included in the Seven-Year CIP to be eligible to receive M2 funding. The seven-Year CIP and Resolution No. xxxxx are included as part of the Proposed Fiscal Year 2025-2026 Budget Staff Report.

Mitigation Fee Program
On a biennial basis, the City must submit a City Council approved resolution to the Orange County Transportation Authority (OCTA) certifying that the City has an existing mitigation program that assesses traffic impacts of new development and requires new development to pay their fair share of necessary transportation improvements that are attributable to the new development.

Master Plan of Arterial Highways Consistency
One of the M2 eligibility requirements is for the City Council of the local jurisdiction to pass a biennial resolution verifying that the City’s Circulation and Mobility Element is consistent with the County Master Plan of Arterial Highways. The Circulation and Mobility Element that the City utilizes is derived from the 2010 updated General Plan. The Circulation Element within the General Plan describes the number of lanes a given arterial will have in the future, as well as the roadway width of that street. To be consistent with the County’s MPAH, an arterial on the City’s Circulation Element must show at least as many lanes as the same roadway on the County’s MPAH. The City’s Circulation Element is consistent with the County MPAH.

7. ATTACHMENTS
· Resolution No. 11618
City of Orange Page 2 of 2 Printed on 6/19/2025
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Agenda Item
City Council
Item #: 3.30. 6/24/2025 File #: 25-0347
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Christopher Cash, Public Works Director

1. SUBJECT
Status and update of the Circulation Element and Mitigation Fee Program for the Measure M2 Program. Resolution No. 11618.

3. RECOMMENDED ACTION

2. Authorize staff to submit M2 eligibility documentation to the Orange County Transportation Authority (OCTA).

4. FISCAL IMPACT
None.

5. STRATEGIC PLAN GOALS
Goal 5: Improve Infrastructure, Mobility, and Technology.

6. DISCUSSION AND BACKGROUND
In November 1990, voters of Orange County approved Measure M, a half-cent sales tax for transportation improvements. The sales tax included funding for the streets that was available to local agencies through a formal distribution and a competitive funding application. In November 2006, voters approved Measure M2 to continue the half-cent sales tax for an additional 30 years, beginning at the expiration of Measure M in 2011. Major improvement plans target Orange County freeways, streets and roads, transit, and environmental programs. As part of the Measure M2 funding request, the City is required to submit resolutions that verify that the City has a Seven-Year Capital Improvement Program (CIP), a Mitigation Fee Program, and Master Plan of Arterial Highway (MPAH) City of Orange Page 1 of 2 Printed on 6/19/2025
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Item #: 3.30. 6/24/2025 File #: 25-0347
Circulation Element Consistency.

7. ATTACHMENTS
· Resolution No. 11618
City of Orange Page 2 of 2 Printed on 6/19/2025
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RESOLUTION NO. 11618

A RESOLUTION OF THE CITY COUNCIL OF THE

CITY OF ORANGE CONCERNING THE STATUS AND

UPDATE OF THE CIRCULATION ELEMENT, AND

MITIGATION FEE PROGRAM FOR THE MEASURE
M (M2) PROGRAM.

WHEREAS, the City of Orange desires to maintain and improve the streets within its jurisdiction, including those arterials contained in the Master Plan of Arterial Highways (MPAH); and
WHEREAS, the City of Orange has endorsed a definition of and process for, determining consistency of the City’s Traffic Circulation Plan with the MPAH; and WHEREAS, the City has adopted a General Plan Circulation Element which does not preclude implementation of the MPAH within its jurisdiction; and WHEREAS, the City is required to adopt a resolution biennially informing the Orange County Transportation Authority (OCTA) that the City’s Circulation Element is in conformance with the MPAH and whether any changes to any arterial highways of said Circulation Element have been adopted by the City during Fiscal Years (FY) 2023-24 and FY 2024-25; and WHEREAS, the City is required to send biennially to the OCTA all recommended changes to the City Circulation Element and the MPAH for the purposes of re-qualifying for participation in the Comprehensive Transportation Funding Programs; and
WHEREAS, the City is required to adopt a resolution biennially certifying that the City has an existing Mitigation Fee Program that assesses traffic impacts of new development and requires new development to pay a fair share of necessary transportation improvements attributable to the new development.

NOW, THEREFORE, BE IT RESOLVED THAT:

The City Council of the City of Orange, does hereby inform OCTA that:
a) The arterial highway portion of the Circulation Element of the City is in conformance with the MPAH.
b) The City attests that no unilateral reduction in through lanes has been made on any MPAH arterials during FY 2023-24 and FY 2024-25.
c) The City affirms that it will bring forward requests to amend the MPAH, when necessary, in order to ensure that the MPAH and the General Plan Circulation Element remain consistent.
823
2 d) The City reaffirms that Council concurs with the existing Mitigation Fee Program is in effect.

ADOPTED this 24th day of June, 2025.
_______________________________________
Daniel R. Slater, Mayor, City of Orange
ATTEST:
_____________________________________
Pamela Coleman, City Clerk, City of Orange
APPROVED AS TO FORM:

Wayne W. Winthers
Interim City Attorney, 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 24
th day of June 2025, by the following vote:

AYES: COUNCIL MEMBERS:

NOES: COUNCIL MEMBERS:

ABSENT: COUNCIL MEMBERS:

ABSTAIN: COUNCIL MEMBERS:
______________________________________
Pamela Coleman, City Clerk, City of Orange
824
Agenda Item
City Council
Item #: 7.1. 6/24/2025 File #: 25-0366
TO: Honorable Mayor and Members of the City Council
FROM: Tom Kisela, City Manager

1. SUBJECT
Consider renewing the City of Orange’s membership with the Association of California Cities - Orange County.

2. SUMMARY
For several years, the City of Orange has been a member of the Association of California Cities - Orange County. In considering the City’s structural budget deficit, staff is seeking direction from the City Council on whether the membership with the Association of California Cities - Orange County should be renewed.

3. RECOMMENDED ACTION
Consider renewing the City of Orange’s membership with the Association of California Cities - Orange County and provide direction to City staff.

4. FISCAL IMPACT
The expense for this membership is $21,654.35 and will be funded through the General Fund (100):
100.0201.51860.00000 Association Dues

5. STRATEGIC PLAN GOALS
Goal 3: Enhance Public Communication Strategy and Quality of Life.

6. DISCUSSION AND BACKGROUND
For several years, the City of Orange has been a member of the Association of California Cities - Orange County (ACCOC). ACCOC provides legislative advocacy services on behalf of over 25 Orange County cities. In addition to legislative advocacy, ACCOC also provides educational and training opportunities for its members.

Staff is seeking City Council direction on whether the City should renew its membership with the ACCOC.

7. ATTACHMENTS
· None
City of Orange Page 1 of 1 Printed on 6/19/2025
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Agenda Item
City Council
Item #: 7.1. 6/24/2025 File #: 25-0366
TO: Honorable Mayor and Members of the City Council
FROM: Tom Kisela, City Manager

1. SUBJECT
Consider renewing the City of Orange’s membership with the Association of California Cities - Orange County.

3. RECOMMENDED ACTION
Consider renewing the City of Orange’s membership with the Association of California Cities - Orange County and provide direction to City staff.

4. FISCAL IMPACT
The expense for this membership is $21,654.35 and will be funded through the General Fund (100):
100.0201.51860.00000 Association Dues

5. STRATEGIC PLAN GOALS
Goal 3: Enhance Public Communication Strategy and Quality of Life.

Staff is seeking City Council direction on whether the City should renew its membership with the ACCOC.

7. ATTACHMENTS
· None
City of Orange Page 1 of 1 Printed on 6/19/2025
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Agenda Item
City Council
Item #: 8.1. 6/24/2025 File #: 25-0253
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Russell Bunim, Community Development Director

1. SUBJECT
Continued Public Hearing to consider introduction and First Reading of an ordinance amending provisions in Title 17 of the Orange Municipal Code (Zoning Ordinance) relating to the number of chickens allowed on residential properties and setback requirements; and finding of CEQA exemption. Ordinance No. 08-25. (Continued from June 10, 2025)

2. SUMMARY
The City proposes changes to update Title 17 to amend certain provisions of the OMC to increase the number of chickens allowed on residential properties, adjust coop setback requirements from property lines to structures used for human habitation, and remove the combining limit of dogs and cats with small animals such as poultry. These amendments are proposed in order to enhance Code clarity, enforcement, and flexibility while maintaining neighborhood compatibility.

3. RECOMMENDED ACTION

1. Conduct and close the Public Hearing.

2. Introduce and conduct First Reading of Ordinance No. 08-25. An Ordinance of the City Council of the City of Orange amending Title 17 of the Orange Municipal Code to update the number of chickens permitted on residential properties and setback requirements.

3. Find the ordinance categorically exempt from the California Environmental Quality Act (CEQA) per State CEQA Guidelines 15061(b)(3) and 15378.

4. FISCAL IMPACT
None.

5. STRATEGIC PLAN GOALS
Goal 3: Enhance Public Communication Strategy and Quality of Life

6. DISCUSSION AND BACKGROUND
The City’s current chicken keeping regulations were established to balance urban agriculture with residential land use. Based on staff interaction during Code Enforcement investigations and what has become an established popular animal keeping practice in typical single-family neighborhoods, there is a need to refresh City standards to reflect “real world” conditions that have proven to function in an acceptable manner. This includes increasing the allowable number of chickens and adjusting property line based setbacks. The proposed amendments would align with regional trends and City of Orange Page 1 of 3 Printed on 6/19/2025
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Item #: 8.1. 6/24/2025 File #: 25-0253
improve practicality for residents.

The existing regulations governing backyard chickens in the City of Orange were established to balance the benefits of urban agriculture with potential impacts on surrounding residences. Currently, residents are permitted to keep up to five chickens, with a requirement that coops be located at least twenty feet from property lines.

Concerns arose about the limitations of these current regulations because an odd-numbered flock size may not be ideal for chickens, which naturally form social bonds in pairs. Other challenges exist in residents’ ability to meet the current property line setback requirement, particularly for homes on smaller or irregularly shaped lots where the placement of a coop twenty feet from all property boundaries is impractical.

The City has reviewed backyard chicken regulations in surrounding jurisdictions and found that six or more chickens is not unreasonable when employing more flexible setback requirements.

Due to these considerations, staff developed the proposed amendments to better align with best practices and community needs. The proposed amendments to the Orange Municipal Code would modify two key aspects of backyard chicken regulations. First, the maximum number of chickens permitted on residential properties would be increased from five to six. Chickens are social animals that thrive in even-numbered groups. The proposed changes would improve overall flock health.

Additionally, allowing six chickens provides residents with a more reliable supply of eggs, particularly as individual hens may experience seasonal variations in egg production.

Second, the requirement that coops be set back at least twenty feet from all property lines would be replaced with a requirement that they be set back at least twenty feet from any structure used for human habitation. Coops would be placed at an appropriate distance from living spaces while accommodating the diverse lot configurations found in the City. The new standard would provide greater flexibility for residents while maintaining appropriate safeguards to minimize noise, odor, and pest concerns.

The ordinance also omits an existing code section that limits the combined keeping of dogs, cats, and small animals such as poultry to a maximum of five. This omission will enable households with dogs and cats to have the same number of chickens as households without dogs and cats.

The Planning Commission unanimously recommended that the City Council approve the ordinance with a recommended amendment that “no poultry shall be maintained closer to an off-property structure used for human habitation than to the structure used for human habitation where the poultry is kept.” Scenarios that would not comply with the Planning Commission’s recommended language is included in Attachment 5. Staff analysis concludes that the addition of the Commission’s recommended language will cause greater difficulty in confirming code compliance. Staff maintains that the ordinance language originally presented to the Planning Commission would provide sufficient buffering from neighbors to compensate for any potential chicken noise or odors. Staff is providing the Council with the unamended original ordinance provided to the Planning Commission.

7. PUBLIC NOTICE
On May 15, 2025, the City published notice of the City Council public hearing in the Orange City News. Notification was also posted at City Hall and on the City website on or before that date.

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Item #: 8.1. 6/24/2025 File #: 25-0253

8. ENVIRONMENTAL REVIEW
The proposed ordinance is not subject to the provisions of the California Environmental Quality Act (CEQA) pursuant to (1) Section 15061(b)(3) of the state CEQA Guidelines (Common Sense Exemption) because it can be seen with certainty that there is no possibility that it would have a significant effect on the environment; and (2) Section 15378 because it will not have a direct or reasonably foreseeable indirect physical change on the environment and is not a "project." For this reason, no further CEQA documentation is required.

9. ATTACHMENTS
· Attachment 1 -Ordinance No. 08-25 Clean
· Attachment 2 - Ordinance No. 08-25 Redlined
· Attachment 3 - Planning Commission April 21, 2025, Staff Report · Attachment 4 - Planning Commission April 21, 2025, Meeting Minutes · Attachment 5 - Chicken Keeping Scenarios
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Agenda Item
City Council
Item #: 8.1. 6/24/2025 File #: 25-0253
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Russell Bunim, Community Development Director

3. RECOMMENDED ACTION

1. Conduct and close the Public Hearing.

3. Find the ordinance categorically exempt from the California Environmental Quality Act (CEQA) per State CEQA Guidelines 15061(b)(3) and 15378.

4. FISCAL IMPACT
None.

5. STRATEGIC PLAN GOALS
Goal 3: Enhance Public Communication Strategy and Quality of Life

6. DISCUSSION AND BACKGROUND
The City’s current chicken keeping regulations were established to balance urban agriculture with residential land use. Based on staff interaction during Code Enforcement investigations and what has become an established popular animal keeping practice in typical single-family neighborhoods, there is a need to refresh City standards to reflect “real world” conditions that have proven to function in an acceptable manner. This includes increasing the allowable number of chickens and adjusting property line based setbacks. The proposed amendments would align with regional trends and City of Orange Page 1 of 3 Printed on 6/19/2025
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Item #: 8.1. 6/24/2025 File #: 25-0253
improve practicality for residents.

The City has reviewed backyard chicken regulations in surrounding jurisdictions and found that six or more chickens is not unreasonable when employing more flexible setback requirements.

Additionally, allowing six chickens provides residents with a more reliable supply of eggs, particularly as individual hens may experience seasonal variations in egg production.

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Item #: 8.1. 6/24/2025 File #: 25-0253

AN ORDINANCE OF THE CITY COUNCIL OF THE
CITY OF ORANGE AMENDING TITLE 17 OF THE

ORANGE MUNICIPAL CODE TO UPDATE THE

NUMBER OF CHICKENS PERMITTED ON

RESIDENTIAL PROPERTIES AND SETBACK
REQUIREMENTS.

WHEREAS, the City regulates the keeping of chickens on residential properties through Title 17 (Zoning Code) of the Orange Municipal Code (OMC) to ensure compatibility with residential uses, public health, and neighborhood character; and WHEREAS, the existing regulations permit up to five (5) chickens per residential property and require coops to be set back twenty (20) feet from all property lines; and WHEREAS, there is interest in increasing the permitted number of chickens and concerns about the practicality of the current setback requirement, particularly for properties with irregular lot shapes; and
WHEREAS, the proposed zoning code amendment is consistent with the City’s General Plan goals of promoting sustainable urban agriculture while maintaining compatibility with residential neighborhoods; and
WHEREAS, the Planning Commission having considered the proposed revisions to the OMC at a public hearing held on April 21, 2025, including review of the staff report, and having received public testimony on the item, and adopted Resolution No. 03-25 recommending that the City Council approve the proposed amendments to OMC Section 17.13.040; and WHEREAS, the City Council, having considered the proposed revisions to the OMC at a public hearing held on June 24, 2025, including review of the staff report, and having received public testimony on the item, recommends approval thereof; and WHEREAS, the proposed ordinance is not subject to the provisions of the California Environmental Quality Act (CEQA) pursuant to (1) Section 15061(b)(3) of the state CEQA Guidelines (Common Sense Exemption) because it can be seen with certainty that there is no possibility that it would have a significant effect on the environment; and (2) Section 15378 because it will not have a direct or reasonably foreseeable indirect physical change on the environment and is not a "project." For this reason, no further CEQA documentation is required.

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

SECTION I:

1. The subject Ordinance is not subject to the provisions of the California Environmental Quality Act (CEQA) pursuant to Section 15061(b)(3) of the state CEQA Guidelines (Common 833
2 Sense Exemption) because it can be seen with certainty that there is no possibility that it would have a significant effect on the environment; and

2. The subject Ordinance is not subject to the provisions of the California Environmental Quality Act (CEQA) pursuant to Section 15378 of the state CEQA Guidelines because it will not have a direct or reasonably foreseeable indirect physical change on the environment and is not a "project." For this reason, no further CEQA documentation is required.

SECTION II:

Section 17.13.040 (F) of the Orange Municipal Code, “Zoning – Master Use Table – Special Use Regulations – Animal Keeping,” is hereby amended to read as follows:

F. Animal Keeping.

1. The keeping of animals shall conform to the provisions of Title 6 of this code.

2. The keeping of birds (as defined in Section 17.04.021) as pets or hobby shall conform to the following standards:
a. The occasional sale of birds is permitted when such sale is incidental to the keeping of birds as pets or hobby.
b. All birds permitted under this section shall be confined indoors or in a coop or aviary. c. Coops or aviaries shall at all times be maintained in a clean and sanitary condition and shall at all times be free of offensive odors.
d. The location of coops or aviaries shall maintain a minimum setback of five feet from all property lines.
e. The City's Code Enforcement Supervisor or designee shall be responsible for determining if the keeping of birds permitted under this section constitutes a nuisance, health or safety hazard, or is being conducted in violation of subsections a, b, c or d above.

3. The keeping of animals on lots having less than 20,000 square feet of lot area per dwelling unit, shall conform to the following:
a. The total number of mature dogs and cats shall be limited to three dogs and three cats. b. Poultry (roosters prohibited), rabbits, reptiles, rodents, and other small animals (less than five pounds), shall be limited to a total number of six, and all such animals shall be maintained in coops, pens, or other quarters or restraints located a minimum of 20 feet from any structure used for human habitation other than that of the subject property owner.
834
3 4. The keeping of animals in single-family districts on lots having 20,000 square feet or more per dwelling unit and zoned R1-20 or greater shall conform to the following:
a. Adult equine, bovine, sheep, goats, and swine shall be limited to a total of two such animals in any combination per the initial 20,000 square feet of land area. One additional equine, bovine, sheep, goat, or swine may be kept for each additional 10,000 square feet of owned or leased contiguous land. However, no more than six such adult animals in any combination shall be kept. The offspring of such animals shall be considered adults when eight months old, except the offspring of equine shall be considered adults when 12 months old.
b. Animals listed in subsection (F)(3) above shall not exceed a total of 10 in any combination on a 20,000 square foot property. An additional five such animals in any combination may be kept for each additional 5,000 square feet of owned or leased contiguous land in the aggregate with a maximum of 50 such animals in any combination. The keeping of more than three dogs shall be subject to the requirements of Section 17.13.050(R).
c. All equine, bovine, sheep, goats, swine, poultry, rabbits, birds, and rodents shall be maintained in coops, pens, corrals, stables, tethers, or in some other means of confinement. Such animals shall not be kept in the required front yard and shall be kept stabled, or tethered a minimum of 50 feet from any structure used for human habitation. other than that of the subject property owner, and a minimum of 20 feet from any property line.

5. All animals and animal quarters shall be maintained in a clean and sanitary condition, and shall be subject to inspection by City code enforcement or legally authorized County of Orange employees for the enforcement of Division 1 of Title 4 of the Codified Ordinances of the County of Orange, established for animal control, welfare, license, and health requirements.

6. The following types of animal keeping or raising shall not be permitted:
a. Commercial dairies;
b. Commercial kennels;
c. Rabbit, fox, goat, and other animal-raising farms;
d. Farms devoted to the hatching, raising, fattening, and/or butchering of poultry or the commercial production of eggs;
e. Livestock-feeding ranches; and
f. Ranches operated publicly or privately for the disposal of garbage, sewage, rubbish, or offal.
835
4 SECTION III:

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 IV:

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 ___________________, 2025.

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

Pamela Coleman, City Clerk, City of Orange
APPROVED AS TO FORM:

Wayne W. Winthers, Interim City Attorney
836
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 _____________, 2025, and thereafter at the regular meeting of said City Council duly held on the ___ day of ____________, 2025 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
837
ORDINANCE NO. 08-25

AN ORDINANCE OF THE CITY COUNCIL OF THE
CITY OF ORANGE AMENDING TITLE 17 OF THE

ORANGE MUNICIPAL CODE TO UPDATE THE

NUMBER OF CHICKENS PERMITTED ON

RESIDENTIAL PROPERTIES AND SETBACK
REQUIREMENTS.

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

SECTION I:
838
2 1. The subject Ordinance is not subject to the provisions of the California Environmental Quality Act (CEQA) pursuant to Section 15061(b)(3) of the state CEQA Guidelines (Common Sense Exemption) because it can be seen with certainty that there is no possibility that it would have a significant effect on the environment; and

SECTION II:

Section 17.13.040 (F) of the Orange Municipal Code, “Zoning – Master Use Table – Special Use Regulations – Animal Keeping,” is hereby amended to read as follows:

F. Animal Keeping.

1. The keeping of animals shall conform to the provisions of Title 6 of this code.

4. The keeping of animals in single-family districts on lots having 20,000 square feet or more per dwelling unit and zoned R1-20 or greater shall conform to the following:
a. Adult equine, bovine, sheep, goats, and swine shall be limited to a total of two such animals in any combination per the initial 20,000 square feet of land area. One additional equine, bovine, sheep, goat, or swine may be kept for each additional 10,000 square feet of owned or leased contiguous land. However, no more than six such adult animals in any combination shall be kept. The offspring of such animals shall be considered adults when eight months old, except the offspring of equine shall be considered adults when 12 months old.
b. Animals listed in subsection (F)(3) above shall not exceed a total of 10 in any combination on a 20,000 square foot property. An additional five such animals in any combination may be kept for each additional 5,000 square feet of owned or leased contiguous land in the aggregate with a maximum of 50 such animals in any combination. The keeping of more than three dogs shall be subject to the requirements of Section 17.13.050(R).
c. All equine, bovine, sheep, goats, swine, poultry, rabbits, birds, and rodents shall be maintained in coops, pens, corrals, stables, tethers, or in some other means of confinement. Such animals shall not be kept in the required front yard and shall be kept stabled, or tethered a minimum of 50 feet from any structure used for human habitation other than that of the subject property owner, and a minimum of 20 feet from any property line.

6. The following types of animal keeping or raising shall not be permitted:
a. Commercial dairies;
b. Commercial kennels;
c. Rabbit, fox, goat, and other animal-raising farms;
840
4 d. Farms devoted to the hatching, raising, fattening, and/or butchering of poultry or the commercial production of eggs;
e. Livestock-feeding ranches; and
f. Ranches operated publicly or privately for the disposal of garbage, sewage, rubbish, or offal.

SECTION III:

SECTION IV:

ADOPTED this ____ day of ___________________, 2025.

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

Pamela Coleman, City Clerk, City of Orange
APPROVED AS TO FORM:

Wayne W. Winthers, Interim City Attorney
841
5 STATE OF CALIFORNIA )

COUNTY OF ORANGE )

AYES: COUNCILMEMBERS:

NOES: COUNCILMEMBERS:

ABSENT: COUNCILMEMBERS:

ABSTAIN: COUNCILMEMBERS:

Pamela Coleman, City Clerk, City of Orange
842
Agenda Item
Planning Commission
Item #: 4.2. 4/21/2025 File #: 25-0161
TO: Chair and Members of the Planning Commission
THRU: Anna Pehoushek, Assistant Community Development Director FROM: Chad Ortlieb, Principal Planner

1. SUBJECT
Public Hearing to consider an update to Title 17 of the Orange Municipal Code (OMC) to amend provisions relating to number of chickens allowed on residential properties and setback requirements; and finding of CEQA exemption.

3. RECOMMENDED ACTION

1. Conduct the Public Hearing.

2. Adopt Planning Commission Resolution No. PC 03-25 recommending that the City Council adopt an Ordinance amending Title 17 of the Orange Municipal Code to update the number of chickens permitted on residential properties and setback requirements.

3. Find the ordinance categorically exempt from the California Environmental Quality Act (CEQA) per State CEQA Guidelines Sections 15061(b)(3) and 15378.

4. AUTHORIZING GUIDELINES
Orange Municipal Code (OMC) Section 17.08.020 authorizes the Planning Commission to review and make advisory recommendations to the City Council on Zoning Ordinance Amendments.

5. PROJECT BACKGROUND
The City’s current chicken keeping regulations were established to balance urban agriculture with residential land use. Based on staff interaction during Code Enforcement investigations and what has become an established popular animal keeping practice in typical single-family neighborhoods, there is a need to refresh City standards to reflect “real world” conditions that have proven to function in an acceptable manner. This includes increasing the allowable number of chickens and adjusting property line based setbacks. The proposed amendments would align with regional trends and improve practicality for residents.

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Item #: 4.2. 4/21/2025 File #: 25-0161

6. PROJECT DESCRIPTION
The existing regulations governing backyard chickens in the City of Orange were established to balance the benefits of urban agriculture with potential impacts on surrounding residences. Currently, residents are permitted to keep up to five chickens, with a requirement that coops be located at least twenty feet from property lines.

The City has reviewed backyard chicken regulations in surrounding jurisdictions and found that many allow six or more chickens while employing more flexible setback requirements.

Additionally, allowing six chickens provides residents with a more reliable supply of eggs, particularly as individual hens may experience seasonal variations in egg production.

Staff recommends these changes to the Planning Commission.

7. ANALYSIS AND STATEMENT OF THE ISSUES
The primary objectives of this proposed amendment are to support sustainable urban agriculture, provide clearer and more enforceable regulations, and ensure compatibility between backyard chicken keeping and residential land uses. The proposed Ordinance maintains a reasonable limit on the number of animals allowed and setbacks that address enforcement challenges and provide a more practical standard for residents with irregular lot layouts.

From a land use perspective, the proposed changes maintain the balance between supporting local food production and protecting neighborhood character. By shifting the setback measurement from property lines to structures used for human habitation, health and comfort of residents are prioritized while allowing greater flexibility in how residents utilize their outdoor space.

No issues have been identified.

8. PUBLIC NOTICE
On March 27, 2025, the City published notice of the Planning Commission public hearing in the City of Orange Page 2 of 3 Printed on 4/17/2025
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Item #: 4.2. 4/21/2025 File #: 25-0161
On March 27, 2025, the City published notice of the Planning Commission public hearing in the Anaheim Bulletin. Notification was also posted at City Hall and on the City website on or before that date.

9. ENVIRONMENTAL REVIEW
The proposed ordinance is not subject to the provisions of the California Environmental Quality Act (CEQA) pursuant to (1) Section 15061(b)(3) of the state CEQA Guidelines (Common Sense Exemption) because it can be seen with certainty that there is no possibility that it would have a significant effect on the environment; and (2) Section 15378 because it will not have a direct or reasonably foreseeable indirect physical change on the environment and is not a "project." For this reason, no further CEQA documentation is required.

10. ADVISORY BOARD ACTION
No advisory board action was necessary for this ordinance.

11. ATTACHMENTS · Attachment 1 - Proposed Resolution with Proposed Ordinance (Clean and Redlined Version) City of Orange Page 3 of 3 Printed on 4/17/2025
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APPROVED BY THE PLANNING COMM]SSION ON MAY 5, 2425
MINUTES. FINAL
City of Orange
Planning Commission
April21,2025
The Planning Commission of the City of Orange, California convened on April 21, 2025, al 5:30 p.m. in a Regular Meeting in the Council Chamber, 300 E. Chapman Avenue, Orange, California.

OPENING/CALL TO ORDER
Chair Vejar called the meeting to order at 5:35 p.m

1.1 PLEDGE OF ALLEGIANCE
Commissioner McCormack led the flag salute.

ROLL CALL

Present: Leslie, Martinez, Maldonado, McCormack, and Veiar

Absent: Vazquez, and Tucker

PUBLIC COMMENTS
None.

1.2 3. CONSENTCALENDAR
All matters listed under the Consent Calendar are considered to be routine by the Planning Commission and will be enacted by one motion. There will be no separate discussion of said items unless members of the Planning Commission, staff or the public request specific items removed from the Consent Calendar for separate action.

3.'1. Approval of meeting minutes of the City of Orange Planning Commission Regular Meeting held on April 7, 2025.

ACTION: Approved minutes as presented.
3,2. Time extension for Street Lights Mixed-Use Apartment Development located at 840 The City Drive South.

ACTION: Approved item as presented.

Approval of the Consent Calendar
2 A motion was made by Commissioner Martinez, seconded by Vice approve the Consent Calendar. The motion carried by the following vote:

Aves: Leslie, lvlartinez, lvlaldonado, lvlccormack, and Veiar Noes: None

Absent: Vazquez, and Tucker
Chair Leslie, to

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Orange City CouncilJune 24, 2025

Orange City Council
June 24, 2025