Orange City Council
September 9, 2025

and restore water quality. The City of Orange, including the Project site , is within the jurisdiction of the Santa Ana RWQCB.

A. Construction Impacts
The Project may result in water quality impacts during short -term construction activities . The grading/excavation required for project implementation would result in exposed soils that may be subject to wind and water erosion. Although erosion occurs naturally in the environment, improperly managed construction activities can lead to substantially accelerated rates of erosion that are considered detrim ental to the environment. As such, short -term water quality impacts have the potential to occur during construction of the Project in the absence of any protective or avoidance measures.

The SWRCB adopted the NPDES General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities (Construction General Permit). The Construction General Permit is required for all projects that include construction activities, such as clearing, soil stockpiling, grading, and/or excavation that disturb at least one (1) acre of total land area. Additionally, the Project would be required to comply with the Santa Ana RWQCB’s Santa Ana River Basin Water Quality Control Program. Compliance with the Construction General Permit and the Santa Ana River Basin Water Quality Control Program involves the preparation and implementation of a SWPPP for construction-related activities, including grading. The purpose of the SWPPP is to identify the sources of sediment and other pollutants that could affect the quality of stormwater discharges and to describe and ensure the implementation of best management practices (BMPs) to reduce or eliminate sediment and other pollutants in stormwater as well as non -stormwater discharges resulting from construction activity.

The Project would be required to comply with the City’s Stormwater Local Implementation Plan (LIP) (Orange, 2011). The LIP requires all private and public construction projects to implement and be protected by an effective combination of erosion and sediment controls and waste and materials management BMPs, such as source control BMPs (e.g. site planning and landscaping, use of pervious pavement), structural BMPs (e.g. protection from rain, secondary containment, etc.), and treatment control BMPs (e.g. constructed wetlands and vegetative swales), to prevent discharges into the storm drain system or watercourses. Table A -8.3 of the LIP provides a comprehensive list of designated construction BMPs (Orange, 2011). The minimum requirements for all construction sites include erosion and sediment control, and waste and materials management control (Table A -8.2 of the LIP), which would be implemented during the Project’s construction phase (Orange, 2011). Additionally, the Project would be required to comply with Chapter 7.01, Water Quality and Stormwater Discharges, of the OMC. This chapter includes conditions and requirements related to the control of urban pollutants to stormwater runoff.

Mandatory compliance with the SWPPP, the City’s LIP, and Chapter 7.01 of the OMC would ensure that the Project does not violate any water quality standards or wa ste discharge requirements during construction activities. Impacts would be less than significant. 534 Struck Avenue Project
Environmental Impact Report 4.8 Hydrology and Water Quality Lead Agency: City of Orange SCH No. 2021090399

B. Post Construction-Impacts
The Project Applicant would redevelop the Project site with a building up to 57,900 sf, a maintenance building, and associated par king and landscaping. The anticipated pollutants to be generated at the Project site include: suspended solids and sediments, nutrients and pesticides (from the proposed landscaping), heavy metals (from truck-trailers both active and stored), oil and greas e, toxic organic compounds (TOCs), pathogens (bacteria/virus), and trash and debris (from all vehicular traffic).

Receiving waters for the Project site include: Santa Ana River Reach 2 and Santa Ana River Reach 1.

The Santa Ana Reach 2 provides the following beneficial uses:

• Agricultural Supply
• Groundwater Recharge
• Water Contact Recreation
• Non-Contact Water Recreation
• Warm Freshwater Habitat
• Wildlife Habitat
• Rare, Threatened, or Endangered Species

The Stormwater Program’s specific water pollutant control elements are documented in the Drainage Area Management Plan (DAMP) . The DAMP satisfies the NPDES permit conditions to reduce pollutant discharges to the maximum extent practicable for the protection of water quality at receiving water bodies and the support of designated beneficial uses. The DAMP contains guidance on both structural and non-structural BMPs for meeting these goals . With implementation of the DAMP requirements, as required by OMC Chapter 7.01 the Project would be required to prepare a WQMP in accordance with the requirements of the NPDES permit.

The Project Applicant has prepared a WQMP, which includes non -structural BMPs, such as educational materials for property owners, tenants, and occupants; activity restriction; comm on area landscape management; BMP maintenance; spill contingency plan; uniform fire code implementation; common area litter control; employee training; housekeeping of loading docks, common area catch basin inspection; and street sweeping private streets and parking lots. Structural BMPs included in the Project’s WQMP include providing storm drain signage; trash storage areas; efficient irrigation systems and landscape design; and loading docks (Webb, 2021a). The WQMP will also include Low Impact Development BMPs and/or Treatment Control BMPs to address the predicted pollutants generated from the project site during general tenant categories at the site.

As described above, a construction-related SWPPP (development SWPPP) is required as part of the Construction General Permit when any project disturbs greater than one (1) acre of soils. A post- construction SWPPP is required for the site as an Industrial General Permit holder (land use SWPPP).

The WQMP is separate from the SWPPP and is the local document showing how operations will be protective of water quality during use of the land.

534 Struck Avenue Project
Environmental Impact Report 4.8 Hydrology and Water Quality Lead Agency: City of Orange SCH No. 2021090399

The NPDES program also requires certain land uses, including the industrial land use proposed by the Project, to prepare a SWPPP for oper ational activities and to implement a long -term water quality sampling and monitoring program, unless an exemption is granted. Because the permit is dependent upon the operational activities of the building and the tenants are not known at this time, details of the SWPPP (including BMPs) or potential exemption to the SWPPP operational activities requirement cannot be determined at this time. However, based on the requirements of the NPDES Industrial General Permit, the Project’s mandatory compliance with a ll applicable regulations would further reduce potential water quality impacts during long -term operatio n. It should be noted that under existing conditions, flows generated from the site drain to Struck Avenue unmitigated and untreated.

Implementation of the Project would have a beneficial impact on water quality because it would capture all on-site flows and treat flows from smaller more frequent storm events, prior to being discharged into the City’s storm drainage system.

Based on the foregoing analysis, the Project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality or result in potential discharge of stormwater to affect beneficial uses of receiving waters . Impacts would be less than significant.

Threshold 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?
According to the Project’s Geotechnical Investigation, groundwater was not encountered at the Project site during subsurface investigations to the maximum depth explored (30 feet bgs) (GeoTek, 2020a).

Implementation of the Project would not include the construction of a potable groundwater well and no potable groundwater wells are located on-site. Most of the City’s water comes from 2 sources:
groundwater from the Lower Santa Ana River Groundwater Basin and imported water purchased from the Metropolitan Water District of Southern California (MWD).

A. Groundwater Supply
According to the City’s 2015 Urban Water Management Plan (UWMP), the City’s water resources have adequate supply to serve the Project site in addition to past, present, and future commitments under normal year, single dry year, and multiple dry years through the year 2040. Additionally, the Project does not propose a General Plan Amendment to modify the site’s land use designation, and the proposed uses are already anticipated in the City’s General Plan and UWMP. Based on the foregoing analysis, the Project would not have the potential to substantially decrease groundwater supplies.

Impacts would be less than significant.

B. Groundwater Recharge
Under existing conditions, approximately 89 percent of the Project site contains impervious surfaces that provides little opportunity for infiltration. The Project would create similar impervious surface 534 Struck Avenue Project
Environmental Impact Report 4.8 Hydrology and Water Quality Lead Agency: City of Orange SCH No. 2021090399

conditions, increasing the Project site ’s impervious surface coverage to 91 percent (Webb, 2021a).

Therefore, redevelopment of the site would not substantially interfere with groundwater recharge.

Additionally, as shown in Figure N -2 of the City General Plan Natural Resources E lement, groundwater recharge facilities for the Lower Santa Ana River Groundwater Basin include the Santa Ana River and Santiago Creek. The Project site is located approximately 0.87 miles east of the Santa Ana River and approximately 1.9 miles north of the Santiago Creek. Implementation of the Project would not have the potential to interfere with groundwater recharge. Impacts would be less than significant.

Threshold 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: result in substantial erosion or siltation on - or off-site; substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite; 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 impeded or redirect flood flows?
Under existing conditions, the Project site does not contain a stream or river; therefore, the Project does not have the potential to alter the course of a stream or river. No impacts would occur in this regard.

A. On-Site Storm Drain Facilities
Under existing conditions, the Project site slopes down at approximately 1 percent grade to the west .

The existing drainage pattern for the s ite is characterized by draining south to north and east to west.

Most of the Site flows drain to a ribbon gutter located on the western side of the site that conveys flows off-site to Struck Avenue without mitigation or treatment. The eastern portion of the Site , including the existing railroad track, drains south to north along an existing curb and gutter. All flows from the eastern portion of the site also drain north towards Struck Avenue. Flows exiting the Site are captured in a set of catch basins located at the Struck Avenue/Batavia Street intersection. From this catch basin flows are conveyed into an existing 33-inch storm drain, which transitions to a 36-inch storm drain just west of the site to Collins Channel and ultimately the Santa Ana River.

Under Project conditions, the Project would maintain the existing drainage pattern by draining flows from south to north, to the northwest corner. The Project would incorporate (curb and gutter or ribbon) gutters, storm drain pipes, and outlet structure with a BioClean modular wetland system (MWS). The MWS will utilize horizontal flow and inco rporates a pretreatment chamber that includes separation and pre-treatment filter cartridges. In this chamber, sediment and hydrocarbons are removed from runoff before entering the biofiltration chamber, large events will bypass through the system before exiting the site. The Project’s proposed ribbon gutters would be located within the parking areas located east and west of the proposed building. Inlets along the ribbon gutters will collect and deposit 534 Struck Avenue Project
Environmental Impact Report 4.8 Hydrology and Water Quality Lead Agency: City of Orange SCH No. 2021090399

flows into the Project’s proposed storm drain syste m and into the proposed outlet structure located within the northwestern portion of the site. The Project storm drain lines would be located throughout the site and are designed to convey 100-year peak flow rates. The starting water surface elevation for the storm drain shall be the 100-year ponding limit within the on-site basin.

The proposed outlet structure receives approximately 33.4 cubic feet per second (cfs) of on-site flows from the proposed Line A, Line B, and Line C.

• Line A is proposed along the eastern and northern portion of the proposed Site. Line A conveys approximately 21.3 cfs of total runoff towards the proposed outlet structure. The proposed line will collect flows draining through the ribbon gutter along the eastern trailer parking stalls and northern auto parking areas before discharging into Line B. Proposed laterals along Line A are proposed at various drainage inlets. The hydraulic model for Line A will be included with the final engineering design. At this time, the preliminary storm drain sizing has been taken from the rational method normal depth calculations.
• Line B is proposed near the northwestern portion of the proposed Site. The proposed line will collect flows generated by the areas west of the proposed building that are conveyed along the curb and gutter. A lateral is also provided near the end of the line to allow for flows within the auto parking stalls in the northwest corner of the Site to be collected. Line A and Line C also confluence with Line B before discharging into the proposed outlet structure. Line B conveys the total Site runoff of approximately 33.4 cfs of runoff generated on-site. The hydraulic model for Line B will be included with the final engineering design. At this time, the preliminary storm drain sizing has been taken from the rational method normal depth calculations. • Line C is proposed along the western portion of the Site . Flows captured near the southern boundary of the Site are conveyed north within Line C. The proposed Line C conveys approximately 4.9 cfs of runoff towards Line B. The hydraulic model for Line C will be included with the final engineering design. At this time, the preliminary storm drain sizing has been taken from the rational method normal depth calculations.

B. Off-Site Storm Drain Facilities
The existing storm drain adjacent to the Project site in Struck Avenue is a 33-inch RCP. This pipe transitions into a 36-inch RCP west of the Site where a lateral connection exists to convey flows from the City Corporation Yard north of the site. The 36-inch RCP continues to the intersection of Batavia Avenue. At this location, a set of catch basins pick up the street flow from Struck Avenue and the adjacent building sites, including the existing drainage of the Project site. As with existing conditions, flows from the Site would continue to flow to the existing catch basin at the Struck Avenue/Batavia Street intersection. The existing storm drain lines were sized to accommodate 10-year storm event flows and to accept flows from the surrounding properties in their developed conditions.

534 Struck Avenue Project
Environmental Impact Report 4.8 Hydrology and Water Quality Lead Agency: City of Orange SCH No. 2021090399

The storm drain design would convey flows through an under-sidewalk drain onto Struck Avenue to mimic the existing conditions, and there would be no connection to the existing 33-inch RCP storm drain line.

i) Result in substantial erosion or siltation on- or off-site?

As discussed above, the Project would increase the amount of impervious surface coverage on the Project site from 89 percent to 91 percent. However, the Project would maintain the s ite’s existing drainage pattern. Therefore, the Project would not substantially alter the site’s drainage pattern in such a way that would result in substantial erosion or siltation on- or off-site. Additionally, the Project would construct an integrated storm drain system on-site with BMPs to minimize the amount of waterborne pollutants carried from the Project site. The Project’s proposed BMPs are designed to treat runoff with medium to high efficiency and effectiveness; furthermore, they are highly effective at removing sediment from stormwater runoff flows. Therefore, stormwater runoff leaving the Project site would not carry substantial amounts of sediment. Because there are no exposed soils at the Project site’s discharge points, there is no potential for the Project’s stormwater runoff to result in erosion as it leaves the Project site. Impacts would be less than significant.

ii) Increase the rate or amount of surface runoff in a manner which would result in flooding in- or off-site?

Under existing conditions, peak stormwater runoff flows are discharged into the existing storm drain line beneath Struck Avenue, which is designed to accept the 10-year peak flows from the Project site and surrounding developments.

As shown in Table 4.8-1, Project Peak Flows, implementation of the project would reduce peak flows discharging from the Project site. As such, the Project proposed drainage improvements would not result in on-site or off-site flooding. Impacts would be less than significant.

Table 4.8-1 Project Peak Flows
Existing Conditions Project Conditions
Storm Event Peak Flow (cfs) Tc (min) Peak Flow (cfs) Tc (min) 2-Year 12.2 12.35 11.9 9.90
10-Year 22.9 11.54 21.7 9.54
100-Year 35.8 11.00 33.4 9.34
AF = acre-feet
Tc = cubic feet per second
Source: (Webb, 2021b, Table 4)

534 Struck Avenue Project
Environmental Impact Report 4.8 Hydrology and Water Quality Lead Agency: City of Orange SCH No. 2021090399

iii) Create or contribute runoff water which would exceed the capacity of existing or planned storm water drainage systems or provide substantial additional sources of polluted runoff?

As discussed above under Hydrology and Water Quality Threshold c.i and c.ii, all captured flows will be directed towards a proposed outlet structure near the northwestern corner of the s ite. Flows are expected to pond up within the outlet structure before spilling out of the structure and into a concrete- lined u-channel. The u-channel conveys the on-site flows north towards a proposed parkway culvert (type B) that will discharge all flows underneath the sidewalk and onto Struck Avenue. Within the outlet structure, an internal weir wall is proposed to divert approximately 2.0 cfs of flows east towards the proposed treatment vaults for water quality treatment. Flows that have been treated by the proposed MWS vaults are then directed towards a proposed pump located northeast of the treatment vaults. The pump will discharge the water quality flows into a second concrete-lined u-channel. From there, treated flows are directed towards a second proposed parkway culvert (type B) that will discharge treated flows underneath the sidewalk and onto Struck Avenue. As discussed above under Hydrology and Water Quality Threshold c.ii, stormwater discharge peak flow would be less than existing conditions.

BMPs would ensure that pollutants of concern are prevented, minimized, and/or otherwise appropriately treated prior to being discharged from the Project site . Impacts would be less than significant.

iv) Impede or redirect flood flows?

According to the Federal Emergency Management Agency (FEMA) flood map No. 06059C0161J, the Project site is within Zone X (Unshaded), an area of minimal flood hazard (FEMA, 2009). The Project does not have the potential to impede or redirect flood flows. No impacts would occur.

Threshold d: Would the Project in flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
As previously discussed, the Project site is not within a 100-year flood hazard zone. The Project does not have the potential to release pollutants due to 100-year flood inundation. No impacts would occur.

According to the Federal Emergency Management Agency (FEMA) flood map No. 06059C0161J, the Project site is within Zone X (Unshaded), an area of minimal flood hazard (FEMA, 2009). The Project does not have the potential to release pollutants due to Project inundation. No impacts would occur.

A tsunami is a sea wave, commonly referred to as a tidal wave, produced by a significant undersea disturbance such as tectonic displacement of a seafloor associated with large, shallow earthquakes. A seiche is an oscillation of a body of water in an enclosed or semi -enclosed basin, such as a reservoir, harbor, lake, or storage tank.

The Project site is located approximately 13 miles northeast of the Pacific Ocean. Due to site distance, the Project would not be subject to tsunami-related inundation. Additionally, there are no enclosed or semi-enclosed bodies of water in proximity to the Project site. No impacts would occur. 534 Struck Avenue Project
Environmental Impact Report 4.8 Hydrology and Water Quality Lead Agency: City of Orange SCH No. 2021090399

Threshold e: Would the Project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan? As discussed under Hydrology and Water Quality Threshold a, the Project site is within the Santa Ana River Basin; there fore, Project-related construction and operational activities would be required to comply with the Santa Ana RWQCB’s Santa Ana River Basin Water Quality Control Plan by preparing and adhering to a SWPPP and WQMP . Additionally, as discussed previously, impl ementation of the Project would not conflict with or obstruct the Santa Ana River Basin Water Quality Control Plan and no impacts would occur.

The Project site is within the Coastal Plain of Orange County Basin (Basin 8-1). The California Department of Water Resources (DWR), classifies this basin as a medium -priority basin. According to the 2014 Sustainable Groundwater Management Act (SGMA), local public agenc ies and Groundwater Sustainability Agencies (GSAs) in “high”- and “medium”-priority basins are required to develop and implement Groundwater Sustainability Plans (GSPs) or Alternatives to GSPs (DWR, 2020). GSPs are detailed roa d maps for how groundwater basins will reach long term sustainability.

The GSA for Basin 8-1 is comprised of the OCWD, City of La Habra, and Irvine Ranch Water District (IRWD). These agencies collaborated and submitted an Alternative to a GSP titled Basin 8-1 Alternative on January 1, 2017, to the DWR. This Alternative, documents the basin conditions; basin management is based on measurable objectives and minimum thresholds defined to prevent significant and unreasonable impacts on the sustainability indicators defined in the Alternative.

Groundwater is anticipated to be located at a depth greater than 40 below ground surface (bgs). The Project’s potable water would be supplied by the City, which relies on groundwater and imported water. As identified in the City’s UWMP, the City’s potable water resources contain enough water to meet demands under a normal, single dry year, and multiple dry year hydrologic conditions from 2020 through 2040. Additionally, the Project site is not within a groundwater recharge area. Therefore, the Project would not have the potential to conflict with or obstruct implementation of the Basin 8-1 Alternative and no impacts would occur.

4.8.5 CUMULATIVE IMPACT ANALYSIS
The cumulative impact analysis considers construction and operation of the Project in conjunction with other development projects in the vicinity of the Project site and projects located in the Santa Ana River Basin and Orange County Groundwater Basin.

A. Water Quality
Project construction and the construction of other projects in the cumulative study area would have the potential to contribute waterborne pollution, including erosion and siltation, to the Santa Ana River Watershed. Pursuant to the requirements of the State Water Resources Control Board and the Santa Ana RWQCB, all construction projects that disturb one (1) or more acres of land area are required to obtain coverage for construction activities under the State’s General Construction NPDES Permit. In order to obtain coverage, an effective Site -specific SWPP P is required to be developed and 534 Struck Avenue Project
Environmental Impact Report 4.8 Hydrology and Water Quality Lead Agency: City of Orange SCH No. 2021090399

implemented. The SWPPP must identify potential on -site pollutants and identify an effective combination of erosion control and sediment control measures to reduce or eliminate discharge of pollutants to surface waters. In addition, the Project Applicant and all cumulative developments in the Santa Ana River Basin would be required to comply with the Santa Ana RWQCB’s Santa Ana River Basin Water Quality Control Program , which establishes water quality standards for ground and surface waters of the region. Compliance with these mandatory regulatory requirements, would ensure that development projects within the Santa Ana River watershed, including the proposed Project, would not contribute substantially to water quality impairments during construction.

Operational activities on the Project site would be required to comply with the Project’s WQMP to minimize the amount of waterborne pollution, including erosion and sediment, discharged from the Site. Other development projects within the watershed would similarly be required by law to prepare and implement Site-specific WQMPs to ensure that runoff does not substantially contribute to water quality violations. Accordingly, operation of the Project would not contribute to cum ulatively- considerable water quality effects.

B. Groundwater Supplies and Management
The Project incorporates design features that would allow surface runoff to infiltrate into the groundwater basin. Other development projects would similarly be required by applicable lead agencies to incorporate design features that facilitate percolation (e.g., through minimum landscaped/permeable area requirements, water quality/detention basins, infiltration basins). Also, as previously noted, implementation of the Project would not result in substantial adverse effects to local groundwater supplies or groundwater recharge. Thus, no component of the Project would obstruct with or prevent implementation of the management plan for the Orange County Groundwater Basin and other development projects within the Orange County Groundwater Basin would be prohibited from any activity that would endanger the health and sustainability of the groundwater basin. Based on the lack of impacts to groundwater, the provision of design measures that would facilitate percolation, and compliance with applicable Orange County Groundwater Basin management plans, cumulative development would not result in a considerable, adverse effect to local groundwater supplies.

C. Flooding
Construction of the Project and other development projects within the Santa Ana River watershed would be required to comply with federal, State, and local regulations and applicable regional and local master drainage plans in order to mitigate flood hazards both on- and off-site. Compliance with federal, State, and local regulations and applicable drainage plans would require development sites to be protected from flooding during peak storm events (i.e., 100-year storm) and also would not allow development projects to expose downstream properties to increased flooding risks during peak storm events. In addition, future development proposals within the Santa Ana River Basin would be required to prepare hydrologic and hydraulic calculations, subject to review and approval by the re sponsible City/County Engineer, to demonstrate that substantial on- and/or off- site flood hazards would not occur. As discussed under the response to Threshold “c,” the Project is designed to ensure that runoff from the Project site during peak storm events is reduced relative to existing conditions. Because the 534 Struck Avenue Project
Environmental Impact Report 4.8 Hydrology and Water Quality Lead Agency: City of Orange SCH No. 2021090399

Project and all other developments throughout the Santa Ana River Basin, would need to comply with federal, State, and local regulations to ensure that stormwater discharges do not substantially exceed existing volumes or exceed the volume of available conveyance infrastructure, a substantial cumulative impact related to flood hazards would not occur.

Additionally, the Project site is not located within a special flood hazard area or in an area subject to inundation. Accordingly, development on the Project site would have no potential to impede or redirect flood flows and a cumulatively-considerable impact would not occur.

4.8.6 SIGNIFICANCE OF IMPACTS BEFORE MITIGATION
Threshold a: Less-than-Significant Impact. The Project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality.

Adherence to a SWPPP and WQMP is required as part of the Project’s implementation to address construction- and operational-related water quality.

Threshold b: Less-than-Significant Impact. The Project would not physically impact any of the major groundwater recharge facilities in the Orange County Groundwater Basin. The Project would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the Project would impede sustainable groundwater management of the Basin.

Threshold c: Less-than-Significant Impact. The Project would be required to comply with applicable water quality regulatory requirements to minimize erosion and siltation. Additionally, the Project would not result in flooding on- or off-site or impede/redirect flood flows. Lastly, the Project would not create or contribute runoff that would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff.

Threshold d: Less-than-Significant Impact. The Project site would not be subject to inundation from tsunamis, seiches, or other hazards.

Threshold e: Less-than-Significant Impact. The Project would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.

4.8.7 MITIGATION
Impacts would be less than significant; therefore, mitigation is not required. 534 Struck Avenue Project
Environmental Impact Report 4.9 Noise
Lead Agency: City of Orange SCH No. 2021090399

4.9 NOISE
This Subsection addresses the environmental issue of noise, including existing noise levels in the Project area and the Project’s potential to introduce new or elevated sources of noise . The analysis contained herein incorporates information contained in a technical report prepared by Urban Crossroads, Inc., titled “534 Struck Avenue Noise and Vibration Analysis” (Noise Study) and dated October 23, 2022. The report is included as Technical Appendix J to this EIR. Refer to Section 7.0, References, for a complete list of reference sources used in the analysis presented in this Subsection.

4.9.1 NOISE FUNDAMENTALS
A. Noise Definitions
Noise is simply defined as “unwanted sound.” Sound becomes unwanted when it interferes with normal activities, when it causes physical harm, or when it has adverse effects on health. Because the range of sound that the human ear can detect is large, the scale used to measure sound intensity is based on multiples of 10, the logarithmic scale. The unit of measure to describe sound intensity is the decibel (dB). A sound increase of 10 dB represents a ten-fold increase in sound energy and is perceived by the human ear as being roughly twice as loud. A -weighted decibels (dBA) a pproximate the subjective response of the human ear to broad frequency noise sources by discriminating against very low and very high frequencies of the audible spectrum (i.e., frequencies that are not audible to the human ear).

The most common sounds vary between 40 dBA (very quiet) to 100 dBA (very loud). Normal conversation at a distance of three feet is roughly 60 dBA, while a jet engine is 110 dBA at approximately 1000 feet.

B. Noise Descriptors
Environmental noise descriptors are generally based on averages, rather than instantaneous, noise levels. The most used noise descriptor is the equivalent level (Leq). Leq represents a steady state sound level containing the same total energy as a time varying signal over a given time period. Leq values are not measured directly but are calculated from sound pressure levels typically measured in dB A.

Consequently, Leq can vary depending on the time of day.

Peak hour or average noise levels, while useful, do not completely describe a given noise environment.

Noise levels lower than peak hour may cause a disturbance if they occur during times when quiet is most desirable, namely evening and nighttime (sleeping) hours. To account for this, the Community Noise Equivalent Level (CNEL), representing a composite 24-hour noise level is utilized. The CNEL is the weighted average of the intensity of a sound, with corrections for time of day, and averaged over 24 hours. The time-of-day corrections require the addition of five (5) decibels to dBA L eq sound levels
in the evening from 7:00 p.m. to 10:00 p.m., and the addition of 10 decibels to dBA Leq sound levels at night between 10:00 p.m. and 7:00 a.m. These additions are made to account for the noise sensitive time periods during the evening and night hours when sound appears louder. CNEL does not represent the actual sound level heard at any time, but rather represents the total sound exposure. The City relies on the 24-hour CNEL level to assess land use compatibility with transportation related noise sources. 534 Struck Avenue Project
Environmental Impact Report 4.9 Noise
Lead Agency: City of Orange SCH No. 2021090399

C. Sound Propagation
When sound propagates over a distance, it changes in level and frequency content . The manner in which noise reduces with distance depends on geometric spreading, ground absorption, atmospheric effects, shielding, and reflection.

1. Geometric Spreading
Sound from a localized source (i.e., a stationary point source) propagates uniformly outward in a spherical pattern. The sound level attenuates (or decreases) at a rate of 6 dB for each doubling of distance from a point source . Highways consist of several localized noise sources on a defined path and hence can be treated as a line source, which approximates the effect of several point sources. Noise from a line source propagates outward in a cylindrical pattern, often referred to as cylindrical spreading.

Sound levels attenuate at a rate of 3 dB for each doubling of distance from a line source.

2. Ground Absorption
To account for the ground-effect attenuation (absorption) of noise, two types of site conditions are commonly used in noise models: soft site and hard site conditions. For acoustically hard sites (i.e., sites with a reflective surface between the source and the receptor, such as a parking lot or body of water), no excess ground attenuation is assumed. For acoustically absorptive or soft sites (i.e., sites with an absorptive ground surface between the source and the receptor such as soft dirt, grass, or scattered bushes and trees), an excess ground attenuation value of 1.5 dB per doubling of distance is normally assumed.

3. Atmospheric Effects
Receptors located downwind from a noise source can be exposed to increased noise levels relative to calm conditions, whereas locations upwind can have lowered noise levels. Other factors that may affect noise levels include air temperature, humidity, and turbulence. (Urban Crossroads, 2022a, p. 9)

4. Shielding
A large object or barrier in the path between a noise source and a receptor can substantially attenuate noise levels at the receptor . The amount of attenuation provided by shielding depends on the size of the object and the frequency content of the noise source. Solid objects or barriers are most effective at attenuating noise levels . Effective noise barriers can reduce noise levels by 10 to 15 dBA . Noise barriers, however, do have limitations . For a noise barrier to work, it must be high enough and long enough to block the path of the noise source.

D. Response to Noise
A variety of reactions can be expected from people exposed to any given environment. Despite this variability in behavior on an individual level, the population as a whole can be expected to exhibit the following responses to changes in noise levels: a change of 3 dBA is considered “barely perceptible;” and a change of 5 dBA is considered “readily perceptible.” 534 Struck Avenue Project
Environmental Impact Report 4.9 Noise
Lead Agency: City of Orange SCH No. 2021090399

E. Vibration
Vibration is the periodic oscillation of a medium or object. Sources of ground-borne vibration include natural phenomena (e.g., earthquakes, volcanic eruptions, sea waves, landslides) or human-made causes (e.g., explosions, machinery, traffic, trains, construction equipment). Vibration sources may be continuous, such as factory machinery, or transient, such as explosions . As is the case with airborne sound, ground-borne vibrations may be described by amplitude and frequency . Vibration is often described in units of velocity (inches per second) and decibels (dB) and is denoted as VdB.

The background vibration-velocity level in residential areas is generally 50 VdB. Ground-borne vibration is normally perceptible to humans at approximately 65 VdB. For most people, a vibration- velocity level of 75 VdB is the approximate dividing line between barely perceptible and distinctly perceptible levels.

4.9.2 EXISTING NOISE CONDITIONS
A. Existing Study Area Ambient Noise Conditions
Urban Crossroads recorded 24-hour noise readings at five (5) locations in the Project study area on April 18, 2022. The noise measurement locations are identified in Figure 4.9-1, Noise Measurement Locations. The results of the existing noise level measurements are summarized below . Noise measurement worksheets for the hourly noise levels and the minimum and maximum observed noise levels at each measurement location are provided in the noise analysis (refer to Technical Appendix J).

In general, the existing background ambient noise levels in the Project area are dominated by surface street vehicle noise which includes automobile and heavy truck activities on the surrounding roadways (Struck Avenue, Collins Avenue, Parker Street, and Brenna Lane) and the railroad tracks located east of the Project site

• Location L1 represents the noise levels located northwest of the Project site near the Department of Public Works at 637 West Struck Avenue. The noise level measurements collected show an overall 24-hour exterior noise level of 53.2 dBA CNEL. The energy (logarithmic) average daytime noise level was calculated at 54.3 dBA Leq with an average nighttime noise level of 50.5 dBA Leq.

• Location L2 represents the noise levels located northeast of the Project site near proposed residential development north of West Struck Avenue. The noise level measurements collected show an overall 24- hour exterior noise level of 50.1 dBA CNEL. The energy (logarithmic) average daytime noise level was calculated at 51.2 dBA Leq with an average nighttime noise level of 47.2 dBA Leq.

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• Location L3 represents the noise levels located northeast of the Project site near the HUB OC (Mary’s Kitchen) at 517 West Struck Avenue. The noise level measurements collected show an overall 24-hour exterior noise level of 51.7 dBA CNEL. The energy (logarithmic) average daytime noise level was calculated at 52.6 dBA Leq with an average nighttime noise level of

49.3 dBA Leq.

• Location L4 represents the noise levels located northeast of the Project site near the Citrus Grove Apartments at 1120 North Lemon Street. The 24-hour CNEL indicates that the overall exterior noise level is 49.8 dBA CNEL. The energy (logarithmic) average daytime noise level was calculated at 51.0 dBA Leq with an average nighttime noise level of 46.8 dBA Leq.

• Location L5 represents the noise levels located south of the Project site near the Top Dog Inn at 606 West Collins Avenue. The 24-hour CNEL indicates that the overall exterior noise level is 66.7 dBA CNEL. The energy (logarithmic) average daytime noise level was calculated at

68.0 dBA Leq with an average nighttime noise level of 63.0 dBA Leq.

B. Existing Ground-borne Vibration
Based on the nature of the existing uses on the Project site, there are no sources of ground-borne vibration on the Project site under existing conditions because no heavy, impact machinery is used on the site.

4.9.3 REGULATORY FRAMEWORK
The following is a brief description of the federal, state, and local environmental laws and related regulations related to noise

A. Federal Regulations

1. Noise Control Act of 1972
The Noise Control Act of 1972 establishes a national policy to promote an environment for all Americans free from noise that jeopardizes their health and welfare. The Act also serves to (1) establish a means for effective coordination of Federal research and activities in noise control; (2) authorize the establishment of Federal noise emission standards for products distributed in commerce; and (3) provide information to the public respecting the noise emission and noise reduction characteristics of such products. (EPA, 2020e)

While primary responsibility for control of noise rests with State and local governments, Federal action is essential to deal with major noise sources in commerce, control of which require national uniformity of treatment. The Environmental Protection Agency (EPA) is directed by Congress to coordinate the programs of all Federal agencies relating to noise research and noise control. (EPA, 2020e)

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2. Federal Transit Administration
The Federal Transit Administration (FTA) has published a Noise and Vibration Impact Assessment Manual (NVIA), which provides guidance for preparing and reviewing the noise and vibration sections of environmental documents. In the interest of promoting quality and uniformity in assessments, the manual is used by project sponsors and consultants in performing noise and vibration analyses for inclusion in environmental documents . The manual sets forth the methods and procedures for determining the level of noise and vibration impact resulting from most federall y-funded transit projects and for determining what can be done to mitigate such impact. (FTA, 2018, p. 1)

The NVIA also establishes criteria for acceptable ground-borne vibration, which are expressed in terms of root mean square (rms) velocity levels in decibels and the criteria for acceptable ground-borne noise are expressed in terms of A -weighted sound levels. As shown in Table 4.9-1, Indoor Ground-Borne Vibration (GBV) and Ground-Borne Noise Impact Criteria for General Vibration Assessment, the FTA identifies three categor ies of land uses and provides Ground- Borne Vibration (GBV) and Ground- Based Noise (GBN) criteria for each category of land use. (FTA, 2018, p. 126)

Table 4.9-1 Indoor Ground-Borne Vibration (GBV) and Ground-Borne Noise Impact Criteria for General Vibration Assessment

Source: (FTA, 2018, p. 126)

B. State Regulations

1. State of California Noise Requirements
The State of California regulates freeway noise, sets standards for sound transmission, provides occupational noise control criteria, identifies noise standards, and provides guidance for local land use compatibility. State law requires that each county and city adopt a General Plan that includes a Noise Element which is to be prepared according to guidelines adopted by the Governor’s Office of Planning and Research. The purpose of the Noise Element is to limit the exposure of the community to excessive noise levels.

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2. Building Standards Code
The State of California’s noise insulation standards are codified in the California Code of Regulations, Title 24, Building Standards Administrative Code, Part 2, and the California Building Standards Code.

These noise standards are applied to new construction in California for the purpose of controlling interior noise levels resulting from exterior noise sources . The regulations specify that acoustical studies must be prepared when noise -sensitive structures, such as residential buildings, schools, or hospitals, are developed near major transportation noise sources, and where such noise sources create an exterior noise level of 60 dBA CNEL or higher . Acoustical studies that accompany building plans for noise-sensitive land uses must demonstrate that the structure has been designed to limi t interior noise in habitable rooms to acceptable noise levels . For new residential buildings, schools, and hospitals, the acceptable interior noise limit for new construction is 45 dBA CNEL. (BSC, n.d.)

C. Local Plans, Policies, and Regulations

1. City of Orange General Plan Noise Element
The City of Orange General Plan Noise Element addresses the control and abatement of environmental noise, and the protection of the City of Orange citizens from excessive exposure to noise. The Noise Element specifies the maximum allowable exterior noise levels for new developments impacted by transportation noise sources such as arterial roads, freeways, airports, and railroads. In addition, the Noise Element identifies several polices to minimize the impacts of excessive noise levels throughout the community and establishes noise level requirements for all land uses. To protect City of Orange residents from excessive noise, the Noise Element contains the following policies related to the Project (Urban Crossroads, 2022a, p. 13):

• Policy 1.1: Consider potential excessive noise levels when making land use planning decisions. • Policy 1.2: Encourage new development projects to provide sufficient spatial buffers to separate excessive noise generating land uses and noise-sensitive land uses. • Policy 1.4: Ensure that acceptable noise levels are maintained near noise-sensitive uses. • Policy 1.5: Reduce impacts of high-noise activity centers located near residential areas. • Policy 6.1: Encourage the design and construction of industrial uses to minimize excessive noise through project design features that include noise control. • Policy 6.2: Encourage industrial uses to locate vehicular traffic and operations away from abutting residential zones as much as possible.
• Policy 7.2: Require developers and contractors to employ noise minimizing techniques during construction and maintenance operations.
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• Policy 7.3: Limit the hours of construction and maintenance operations located adjacent to noise-sensitive land uses.

To ensure noise -sensitive land uses are protected from high levels of noise the City of Orange has developed its own land use compa tibility standards, based on recommended parameters from the Governor’s Office of Planning and Research (OPR). The City’s Land Use Compatibility standards use the CNEL noise descriptor, are intended to be applicable for land use designations exposed to noise levels generated by transportation related sources. Land use compatibility noise exposure limits are generally established as 65 dBA CNEL for most land use designations throughout the City. Higher exterior noise levels are permitted for multiple-family housing and housing in mixed-use contexts than for single -family houses. This is because multiple -family complexes are generally located in transitional areas between single -family and commercial districts or in proximity to major arterials served by transit, and a more integrated mix of residential and commercial activity (accompanied by higher noise levels) is often desired in mixed-use areas close to transit routes. The City of Orange does not identify any transportation related noise exposure standards for industrial land uses.

2. City of Orange Municipal Code
The Noise Ordinance included in Chapter 8.24 of the City of Orange Municipal Code provides performance standards and noise control guidelines for activities within the City limits, as described below.

 Operational Noise Standards
For noise -sensitive residential property, the City of Orange Municipal Code, Section 8.24.040, identifies exterior noise levels standards of 55 dBA Leq for the daytime hours (7:00 a.m. to 10:00 p.m.) and 50 dBA Leq during the nighttime (10:00 p.m. to 7:00 a.m.) hours. Per Section 8.24.040(B) for multi-family residential or mixed -use developments located within the City ’s Urban Mixed Use, Neighborhood Mixed Use, Old Towne Mixed Use or Medium Density Residential Genera l Plan land use districts, exterior noise standards shall apply to common recreation areas only and shall not apply to private exterior space (such as a private yard, patio, or balcony). The City of Orange does not identify any exterior noise level standards for non-residential land uses.

 Construction Noise Standards
The City of Orange has set restrictions to control noise impacts associated with the construction of the proposed Project. Section 8.24.50(E) of the City’s Municipal Code states:

Noise sources associated with construction, repair, remodeling, or grading of any real property, provided said activities take place between the hours of 7:00 a.m. and 8:00 p.m. on any day except for Sunday or a Federal holiday, or between the hours of 9:00 a.m. and 8:00 p.m. on Sunday or a Federal holiday.

Neither the City’s General Plan nor Municipal Code establish numeric maximum acceptable construction source noise levels at potentially affected receivers, which would allow for a quantified 534 Struck Avenue Project
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determination of what CEQA constitutes a substantial temporary or periodic noise increase. Therefore, a numerical construction threshold based on FTA Transit Noise and Vibration Impact Assessment Manual is used for analysis of daytime construction impacts, as discussed below.

According to the FTA, local noise ordinances are typically not very useful in evaluating construction noise. They usually relate to nuisance and hours of allowed activity, and sometimes specify limits in terms of maximum levels, but are generally not practical for assessing the impact of a construction project. Project construction noise criteria should account for the existing noise environment, the absolute noise levels during construction activities, the duration of the construction, and the adjacent land use. Due to the lack of standardized construction noise thresholds, the FTA provides guidelines that can be considered reasonable criteria for construction noise assessment. The FTA considers a daytime exterior construction noise level of 80 dBA Leq as a reasonable threshold for noise sensitive residential land use. While the City of Orange does not identify any specific construction noise level threshold, the City of Orange General Plan EIR relies on the same FTA guidelines for noise a nd vibration relating to transportation and construction-induced vibration. The 80 dBA Leq daytime exterior construction noise level is derived from this same FTA document used throughout the General Plan EIR to establish reasonable construction threshold of significance.

 Vibration
Construction activity can result in varying degrees of ground- borne vibration, depending on the equipment and methods used, distance to the affected structures and soil type. Construction vibration is generally associated with p ile driving and rock blasting. Other construction equipment such as air compressors, light trucks, hydraulic loaders, etc., generates little or no ground vibration. Occasionally large bulldozers and loaded trucks can cause perceptible vibration levels at close proximity.

To analyze vibration impacts originating from the operation and construction of the 534 Struck Avenue, vibration-generating activities are appropriately evaluated against standards established under a City’s Municipal Code, if such standards exist. However, the City of Orange does not identify specific vibration level limits. For analysis purposes, Urban Crossroads used t he Caltrans Transportation and Construction Vibration Guidance Manual vibration damage to assess potential temporary construction- related impacts at adjacent building locations.

4.9.4 BASIS FOR DETERMINING SIGNIFICANCE
According to Section XIII of the CEQA Guidelines, the proposed Project would result in a significant impact to noise if the Project or any Project-related component would 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;

• Generation of excessive ground borne vibration or ground borne noise levels;

534 Struck Avenue Project
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• 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 two 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.

4.9.5 IMPACT ANALYSIS
Threshold a: Would the Project result in generation of 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?
Noise generated at the Project site under existing conditions is limited to surface street vehicle noise which includes auto and heavy truck activities on the surrounding roadways (Struck Avenue, Collins Avenue, Parker Street, and Brenna Lane) and the railroad tracks located east of the Project site.

Redevelopment of the Project site with a new building and associated improvements has the potential to result in the generation of elevated noise levels during both near-term construction activities and under long-term operational conditions . Near-term (i.e., temporary) and long-term (i.e., permanent) noise level increases that would be associated with the Project are described below. Urban Crossroads took 24-hour noise measurements at 5 noise measurement locations depicted in Figure 4.9-1, Noise Measurement Locations, to assess the existing noise level environment. To assess the potential short- term construction and long-term operational noise impacts, Urban Crossroads identified 6 representative noise-sensitive receiver locations at which the Project’s anticipated noise generation was compared against as shown in Figure 4.9-2, Receiver Locations.

A. Construction
The Project’s only potential to cause a substantial temporary or periodic increase in ambient noise levels would occur during the construction phase. Construction activities on the Project site, especially those involving the use of heavy equipment, would create intermittent, temporary increases in ambient noise levels in the vicinity of the Project site . Noise generated by heavy construction equipment including trucks, graders, bulldozers, concrete mixers, and portable generators can reach hi gh levels.

However, construction-related noise increase would: 1) be transitory (i.e., varying from day-to-day and throughout the day), 2) completely cease upon completion of Project construction, and 3) not represent a recurring, periodic source of noise . Although periodic and temporary, construction noise has the potential to be substantial compared to existing ambient noise levels. As such, t he Project’s construction-related activities are required to comply with the City’s Noise Ordinance (Municipal Code Section 8.24.040). The City’s Noise Ordinance includes a provision that exempts construction activities during the hours of 7:00 am and 8:00 pm on any day except for Sunday or a Federal holiday, or between the hours of 9:00 am and 8:00 pm on a Sunday or a Federal holiday.

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To evaluate the Project ’s potential to generate potentially significant construction noise levels at the off-site receiver locations, the analysis is based on a threshold of 80 decibels (dBA) equivalent sound level (Leq) for daytime construction-related noise. This threshold was established in FTA’s Transit Noise and Vibration Impact Assessment Manual , as described above . As shown in Table 4.9 - 2,Construction Noise Level Compliance the Project’s construction-related noise at the off-site receiver locations will satisfy the 80 dBA L eq significance threshold. Therefore, impacts would be less than significant.

Table 4.9-2 Construction Noise Level Compliance
Receiver Location1 Construction Noise Level (dBA Leq)
Highest Noise Level2 Threshold3 Threshold Exceeded?4
R1 73.8 80 No
R2 66.2 80 No
R3 78.7 80 No
R4 70.3 80 No
R5 59.0 81 No
R6 57.1 82 No
1Noise receiver locations are shown on Figure 4.9-2.
2Highest construction noise level calculations based on distance from the construction noise source activity to nearby receive r locations.
3FTA, Transit Noise and Vibration Impact Assessment Manual. 4Do the estimated Project construction noise levels exceed the construction noise level threshold? Source: (Urban Crossroads, 2022a, Table 10-3)

B. Operational – Stationary
This section analyzes the potential stationary-source operational noise impacts at the nearest receiver locations, identified in Figure 4.9-2, resulting from the operation of the proposed 534 Struck Avenue Project. Figure 4.9-3, Operational Noise Source Locations, identifies the noise source locations used to assess the operational noise levels.

Future tenants of the proposed Project are currently unknown. Therefore, this operational noise analysis is intended to describe noise level impacts associated with the expected typical of warehouse use activities at the Project site . To present the potential worst -case noise conditions, this analysis assumes the Project would be operational 24 hours per day, seven days per week. The on-site Project- related noise sources are expected to include: loading dock activity, truck terminal activity, roof-top air conditioning units trash enclosure activity, parking lot vehicle movements and truck movements.

According to the City’s Municipal Code Section 8.24.040, the maximum allowable exterior sound levels for uses in proximity to residential uses are 55 dBA L eq from 7:00 am to 10:00 pm (daytime)
and 50 dBA Leq from 10:00 pm to 7:00 am (nighttime). Public facility uses do not have a threshold for maximum allowable exterior sound levels established in the Municipal Code.

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To estimate the Project’s operational noise impacts, reference noise level measurements were collected from similar types of activities to represent the noise levels anticipated with the development of the Project (see Table 4.9-3). It should be noted that the Project’s projected noise levels assume the worst- case scenario environment with the loading dock activity, truck terminal activity, truck movements, and roof-top air conditioning units, trash enclosure activity, parking lot vehicle movements and truck movements all operating at the same time. These noise level impacts will likely vary throughout the day.

Table 4.9-3 Reference Noise Level Measurements
Noise Source1
Noise
Source
Height
(Feet)
Min./
Hour2 Reference
Noise Level
(dBA Leq)
@ 50 Feet
Sound
Power
Level
(dBA)3 Day Night
Loading Dock and Truck Terminal Activity 8' 60 60 62.8 103.4 Roof-Top Air Conditioning Units 5' 39 28 57.2 88.9
Trash Enclosure Activity 5' 10 10 57.3 89.0
Parking Lot Vehicle Movements 5' 60 60 56.1 87.8
Truck Movements 8' 60 60 59.8 93.2
1 As measured by Urban Crossroads, Inc.
2 Anticipated duration (minutes within the hour) of noise activity during typical hourly conditions expected at the Project site. "Daytime" = 7:00 a.m. - 10:00 p.m.; "Nighttime" = 10:00 p.m. - 7:00 a.m. 3 Sound power level represents the total amount of acoustical energy (noise level) produced by a sound source independent of distance or surroundings. Sound power levels calculated using the CadnaA noise model at the reference distance to the noise source. Numbers may vary due to size differences between point and area noise sources.

Source: (Urban Crossroads, 2022a, Table 9-1)

1. Loading Dock and Truck Terminal Activity
The reference loading dock and truck terminal activities are intended to describe the typical operational noise source levels associated with the Project. This includes truck idling, deliveries, backup alarms, trailer movements, unloading/loading, docking including a combination of tractor trailer se mi-trucks, two-axle delivery trucks, and background forklift operations . At a uniform reference distance of 50 feet, the reference noise level was 62.8 dBA Leq. The loading dock activity noise level measurement was taken over a fifteen-minute period and represents multiple noise sources taken from the center of activity. The reference noise level measurement includes a semi -truck with trailer pass -by event, background switcher cab trailer towing, drop-off, idling, backup alarm events, employees unloading a docked truck container included the squeaking of the truck’s shocks when weight was removed from the truck, employees playing music over a radio, as well as a forklift horn. In addition, during the noise level measurement a truck entered the loading dock area and proceeded to reverse and dock in a nearby loading bay, adding truck engine, idling, air brakes noise, in addition to on-going idling of an already docked truck. Noise associated with loading dock and truck trailer activity is expected to operate for the entire hour (60 minutes).

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2. Roof-Top Air Conditioning Units
The noise level measurements describe a single mechanical roof -top air conditioning unit . The reference noise level represents a Lennox SCA120 series 10-ton model packaged air conditioning unit.

At the uniform reference distance of 50 feet, the reference noise levels are 57.2 dBA Leq. Based on the typical operating conditions observed over a four-day measurement period, the roof-top air conditioning units are estimated to operate for and ave rage 39 minutes per hour during the daytime hours, and 28 minutes per hour during the nighttime hours . These operating conditions reflect peak summer cooling requirements with measured temperatures approaching 96 degrees Fahrenheit (°F) with average daytim e temperatures of 82° F. For this noise analysis, the air conditioning units are expected to be located on the roof of the Project buildings.

3. Trash Enclosure Activity
To describe the noise levels associated with a trash enclosure activity, reference noise level measurement was collected at an existing trash enclosure containing two dumpster bins . The trash enclosure noise levels describe metal gates opening and closing, metal scraping against concrete floor sounds, dumpster movement on metal wheels, and trash dropping into the metal dumpster. The reference noise levels describe trash enclosure noise activities when trash is dropped into an empty metal dumpster, as would occur at the Project site. The measured reference noise level at the uniform 50-foot reference distance is 57.3 dBA Leq for the trash enclosure activity. The reference noise level describes the expected noise source activities associated with the trash enclosures for the Project’s proposed building. Typical trash enclosure activities are estimated to occur for 10 minutes per hour.

4. Parking Lot Vehicle Movements
To describe the on-site parking lot activity, a long -term 29-hour reference noise level measurement was collected in the center of activity within the staff parking lot of an Amazon warehouse distribution center. At 50 feet from the center of activity, the parking lot produced a reference noise level of 56.1 dBA Leq. Parking activities are expected to take place during the full hour (60 minutes) throughout the daytime and evening hours. The parking lot noise levels are mainly due cars pulling in and out of parking spaces in combination with car doors opening and closing.

5. Truck Movements
The truck movements reference noise level measurement was collected over a period of 1 hour and 28 minutes and represents multiple heavy trucks entering and exiting the outdoor loading dock area producing a reference noise level of 59.8 dBA Leq at 50 feet . The noise sources included at this measurement location account for trucks entering and existing the Project driveways and maneuvering in and out of the outdoor loading dock activity area.

6. Project Operational Noise Levels
Using the reference noise levels to represent the proposed Project operations that include loading dock activity, truck terminal activity, roof -top air conditioning units trash enclosure activity, parking lot vehicle movements and truck movements, operational source noise levels were calculated that are 534 Struck Avenue Project
Environmental Impact Report 4.9 Noise
Lead Agency: City of Orange SCH No. 2021090399

expected to be generated at the Project site and the Project-related noise level increases that would be experienced at each of the sensitive receiver locations . See Tables 9 -2 and 9 -3 if the Noise Report (Technical Appendix J of this EIR) for the operational noise levels during the daytime hours of 7:00 a.m. to 10:00 p.m and nighttime hours of 10:00 p.m. to 7:00 a.m , respectively. The daytime hourly noise levels at the off-site receiver locations are expected to range from 40.6 to 52.2 dBA Leq. The nighttime hourly noise levels at the off-site receiver locations are expected to range from 40.6 to 52.2 dBA Leq. The differences between the daytime and nighttime noise levels are largely related to the estimated duration of noise activity as outlined in Table 4.9-3.

The Project-only operational noise levels are evaluated against exterior noise level thresholds based on the City of Orange exterior noise level standards at nearby noise -sensitive receiver locations. Table

4.9-4, Operational Noise Level Compliance , shows the ope rational noise levels associated with the Project will satisfy the City of Orange daytime and nighttime exterior noise level standards. Therefore, the operational noise impacts are considered less than significant at the nearby noise-sensitive receiver locations.

Table 4.9-4 Operational Noise Level Compliance
Receiver
Location1 Land Use
Noise Levels dBA Leq
Project Operational
Noise Levels2
Noise Level
Standards3
Noise Level Standards
Exceeded?4
Daytime Nighttime Daytime Nighttime Daytime Nighttime
R1 Public-
Institutional 52.2 52.2 n/a n/a No No
R2 Proposed
Residential 46.7 46.7 55 50 No No
R3 The HUB OC 51.7 51.7 n/a n/a No No
R4 Residential 47.3 47.3 55 50 No No
R5 Residential 42.9 42.9 55 50 No No
R6 Industrial 40.6 40.6 n/a n/a No No
1See Figure 4.9-2 for the receiver locations.
2Anticipated project operational noise levels.
3Exterior noise level standards.
4Do the estimated Project operational noise source activities exceed the noise level standards? “Daytime” = 7:00 am – 10:00 pm; “Nightime” = 10:00pm – 7:00 am Source: (Urban Crossroads, 2022a, Table 9-4)

C. Traffic-Related Off-Site Noise
The Project is anticipated to generate a net total of 396 vehicle trip-ends per day with 176 truck trip- ends per day (Technical Appendix K1). To assess the off-site transportation CNEL noise level impacts associated with the development of t he Project, noise contours were developed based on the Traffic Analysis (Technical Appendix K1). The noise contours represent the distance to noise levels of a constant value and are measured from the center of the roadway for the 70, 65, and 60 dBA noise levels. The noise contours do not consider the effect of any existing noise barriers or topography that may attenuate ambient noise levels . In addition, because the noise contours reflect modeling of 534 Struck Avenue Project
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vehicular noise on area roadways, they appropriate ly do not reflect noise contributions from the surrounding stationary noise sources within the Project study area . Tables 7-1 to 7-5 in the Noise Report (Technical Appendix J ) present a summary of the exterior traffic noise levels for each traffic condition. Appendix 7.1 in the Noise Report (Technical Appendix J ) includes the traffic noise level contours worksheets for each traffic condition.

Table 4.9-5, Existing with Project Traffic Noise Level Increases, shows the Existing with and without Project conditions CNEL noise levels . The Existing without Project exterior noise levels range from

62.6 to 73.0 dBA CNEL, without accounting for any noise attenuation features such as noise barriers or topography. The Existing with Project conditions range from 62.8 to 73.1 dBA CNEL. The Project off-site traffic noise level increases range from 0.0 to 4.5 dBA CNEL on the study area roadway segments. Based on the significance criteria for off-site traffic noise of greater than or equal to 3 dBA L
eq if ambient noise is greater than 65 dBA Leq and greater or equal to 5 dBA L eq if ambient noise is less than 65 dBA L eq, land uses adjacent to the study area roadway segments would experience less than significant noise level increases on receiving land uses due to the Project-related traffic.

Table 4.9-5 Existing with Project Traffic Noise Level Increases ID Road Segment
CNEL at Receiving
Land Use (dBA)1
Incremental Noise
Level Increase
Threshold2
No
Project
With
Project
Project
Increment Limit Exceeded?
1 Main St. n/o Struck Av. 71.0 71.0 0.0 3.0 No
2 Main St. s/o Struck Av. 71.6 71.6 0.0 3.0 No
3 Batavia St. n/o Katella Av. 69.9 69.9 0.0 3.0 No
4 Batavia St. s/o Katella Av. 68.9 69.9 1.0 3.0 No
5 Batavia St. s/o Struck Av. 69.4 69.5 0.1 3.0 No
6 Katella Av. w/o Main St. 71.2 71.5 0.3 3.0 No
7 Katella Av. e/o Main St. 71.9 72.2 0.3 3.0 No
8 Katella Av. e/o Batavia Av. 72.4 72.5 0.1 3.0 No
9 Katella Av. w/o SR-57 SB
Ramps 73.0 73.0 0.0 3.0 No
10 Katella Av. e/o SR-57 NB Ramps 72.8 73.1 0.3 3.0 No
11 Struck Av. w/o Main St. 68.0 68.0 0.0 3.0 No
12 Struck Av. e/o Main St. 62.7 62.8 0.1 5.0 No
13 Struck Av. e/o Batavia Av. 62.6 67.1 4.5 5.0 No
1 The CNEL is calculated at the boundary of the right-of-way of each roadway and the property line of the receiving land use. 2 Does the Project create an incremental noise level increase exceeding the significance criteria? Source: (Urban Crossroads, 2022a, Table 7-5)

Table 4.9-6, Opening Year Conditions with Project Traffic Noise Level Increases, presents the Opening Year Cumulative (OYC) with and without Project conditions CNEL noise levels . The OYC without Project exterior noi se levels range from 63.5 to 73.2 dBA CNEL, without accounting for any noise 534 Struck Avenue Project
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attenuation features such as noise barriers or topography; and with Project conditions will range from

63.6 to 73.3 dBA CNEL . The Project off-site traffic noise level increases range from 0.0 to 3.9 dBA CNEL. Based on the significance criteria for off-site traffic noise of greater than or equal to 3 dBA Leq if ambient noise is greater than 65 dBA L eq and greater or equal to 5 dBA L eq if ambient noise is less than 65 dBA L eq, land uses adjacent to the study area roadway segments would experience less than significant noise level increases on receiving land uses due to the Project -related traffic under OYC traffic conditions.

Table 4.9-6 Opening Year Conditions with Project Traffic Noise Level Increases ID Road Segment
CNEL at Receiving
Land Use (dBA)1
Incremental Noise
Level Increase
Threshold2
No
Project
With
Project
Project
Increment Limit Exceeded?
1 Main St. n/o Struck Av. 71.1 71.1 0.0 3.0 No
2 Main St. s/o Struck Av. 71.8 71.8 0.0 3.0 No
3 Batavia St. n/o Katella Av. 70.2 70.3 0.1 3.0 No
4 Batavia St. s/o Katella Av. 69.2 70.2 1.0 3.0 No
5 Batavia St. s/o Struck Av. 69.7 69.8 0.1 3.0 No
6 Katella Av. w/o Main St. 71.4 71.7 0.3 3.0 No
7 Katella Av. e/o Main St. 72.1 72.4 0.3 3.0 No
8 Katella Av. e/o Batavia Av. 72.6 72.7 0.1 3.0 No
9 Katella Av. w/o SR-57 SB
Ramps 73.2 73.2 0.0 3.0 No
10 Katella Av. e/o SR-57 NB Ramps 73.1 73.3 0.2 3.0 No
11 Struck Av. w/o Main St. 68.4 68.5 0.1 3.0 No
12 Struck Av. e/o Main St. 63.5 63.6 0.1 5.0 No
13 Struck Av. e/o Batavia Av. 63.6 67.5 3.9 5.0 No
1 The CNEL is calculated at the boundary of the right-of-way of each roadway and the property line of the receiving land use. 2 Does the Project create an incremental noise level increase exceeding the significance criteria? Source: (Urban Crossroads, 2022a, Table 7-6)

Threshold b: Would the Project result in generat ion of excessive groundborne vibration or groundborne noise levels?
According to the FTA, vibration is the period oscillation of a medium or object . Sources of ground- borne vibrations include natural phenomena (e.g., earthquake, landslides, sea waves) or human-made causes (e.g., explosions, machinery, traffic, trains, construction equipment). To analyze vibration impacts originating from the operation and construction of the Project, vibration-generating activities are evaluated based on FTA methodology. The FTA Transit Noise and Vibration Impact Assessment Manual methodology provides guidelines for the maximum-acceptable vibration criteria. A significant impact would occur if the Project results in an exceedance of 75 vibration decibels (vdB).

534 Struck Avenue Project
Environmental Impact Report 4.9 Noise
Lead Agency: City of Orange SCH No. 2021090399

A. Construction-Related Vibration Impacts
Construction activities on the Project site would utilize heavy equipment that has the potential to generate lo w levels of intermittent, localized ground -borne vibration. The Project’s construction activities most likely to cause vibration impacts are:

• Heavy Construction Equipment: Although all heavy mobile construction equipment has the potential of causing at least some perceptible vibration while operating close to buildings, the vibration is usually short-term and is not of sufficient magnitude to cause building damage. • Trucks: Trucks hauling building materials to construction sites can be sources of vibration intrusion if the haul route passes through residential neighborhoods on streets with bumps or potholes. Repairing the bumps and potholes generally eliminates the problem.

As shown in Table 4.9-7, Project Construction Vibration Levels, at distances ranging from 31 feet to 563 feet from construction activity, construction vibration levels are calculated to range from 0.001 to

0.064 PPV (in/sec). Based on the maximum acceptable continuous vibration threshold of 0.3 PPV (in/sec), typical Project construction vibration levels will fall below the building damage thresholds at all noise sensitive receiver locations. Additionally, the vibration level reported at the sensitive receiver locations are unlikely to be sustained during the entire construction period but will occur only during the times that heavy construction equipment is operating adjacent to the Project site perimeter.

Therefore, Project -related vibration impacts are considered less than significant during typical construction activities at the Project site.

Table 4.9-7 Project Construction Vibration Levels
Receiver
Location1
Distance to
Construction
Activity (Feet)2
Typical Construction Vibration Levels PPV (in/sec)3
Thresholds
PPV
(in/sec)4
Threshold
Exceeded?5 Small
bulldozer Jackhammer Loaded
Trucks
Large
bulldozer
Highest
Vibration
Levels
R1 96 0.000 0.005 0.010 0.012 0.012 0.3 No
R2 245 0.000 0.001 0.002 0.003 0.003 0.3 No
R3 31 0.002 0.025 0.055 0.064 0.064 0.3 No
R4 126 0.000 0.003 0.007 0.008 0.008 0.3 No
R5 563 0.000 0.000 0.001 0.001 0.001 0.3 No
R6 59 0.001 0.010 0.021 0.025 0.025 0.3 No
1 Receiver locations as shown on Figure 4.9-2.
2 Distance from receiver to Project construction boundary. 3 Based on the Vibration Source Levels of Construction Equipment (Table 10-4 of Urban Crossroads report). 4 Caltrans Transportation and Construction Vibration Guidance Manual, April 2020, Table 19, p. 38. 5 Does the peak vibration exceed the acceptable vibration thresholds? "PPV" = Peak Particle Velocity
Source: (Urban Crossroads, 2022a), Table 10-5

534 Struck Avenue Project
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B. Operational Vibration Impacts
Under long- term conditions, the Project would not include nor require equipment, facilities, or activities that would result in substantial or perceptible ground-borne vibration. Trucks would travel to and from the Project site during long-term operation; however, vibration levels for heavy trucks operating at low -to-normal speeds on smooth, paved surfaces –as expected on the Project site and surrounding roadways–typically do not exceed 0.004 in/sec PPV, which is lower than the Caltrans vibration thresholds of 0.3 in/sec PPV for building damage and 0.04 in/sec PPV annoyance .

Accordingly, long-term operation of the Project would not generate or expose persons to excessive ground-borne vibration or ground-borne noise levels, and a less than significant impact would occur.

Threshold 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 two miles of a public airport or public use airport, would the P roject expose people residing or working in the project area to excessive noise levels?
As previously discussed, the Project site is not in proximity to any private airstrip or airport and is not within an airport land use plan. The closest airport to the Project site is the Fullerton Municipal Airport located approximately 8.0 miles northwest. Implementation of the Project does not have the potential to expose people residing or working in the Project area to excessive noise levels associated wi th air travel. No impacts would occur.

4.9.6 CUMULATIVE IMPACT ANALYSIS
A. Construction Noise
Construction activities associated with the proposed Project, especially activities involving heavy equipment, would create intermittent periods of noise when construction equipment is in operation and cause a short -term increase in ambient noise levels. The list of cumulative projects that have the potential to collectively increase noise is provided in Table 4.0-1 in Section 4.0, Environmental Analysis, of this EIR. As detailed on that list, there are no ongoing or imminent construction projects in the immediate vicinity of the proposed Project site with construction periods that are expected to overlap with the Project . Accordingly, there is no potential for Project -related construction activities to contribute to cumulatively-considerable impacts to occupied sensitive receptor locations.

B. Stationary Noise
The analysis presented for Threshold “a” addresses the Project’s contribution of noise to existing cumulative noi se sources (i.e., ambient noise) in the Project area. As previously shown in this Subsection, the Project’s noise contribution would not be perceptible to noise-sensitive receptors in the Project area during daytime or nighttime hours . The Project’s permanent stationary noise impacts would not be cumulatively-considerable.

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C. Traffic Noise
The analysis presented under Threshold “a” evaluates the Project’s traffic noise contribution along study area roadways with consideration of near-term cumulative development. As summarized in that analysis, the Project’s traffic noise contributions along study area roadways would not exceed applicable significance thresholds and, therefore, would not be cumulatively-considerable under near- term conditions.

Table 4.9-8, Cumulative Traffic Noise Level Increases , presents a summary of the cumulative noise level increases for each of the study area roadway segments. The cumulative traffic noise level increase increment describes the difference between the Opening Year with Project conditions and the Existing (baseline) conditions. Cumulative impacts are caused by Project traffic in combination with traffic from other closely related past, present, and reasonably foreseeable future projects rather than Project- only traffic.

The cumulative off-site traffic noise level increases presented on Table 4.9 -8 are expected to range from 0.1 to 4.9 dBA CNEL and will not exceed the cumulati ve off-site traffic noise level increase thresholds on any of the study area roadway segments due to the cumulative and Project-related traffic.

Therefore, the cumulative noise impacts are not cumulatively considerable, and the off-site traffic noise impacts are less than significant.

Table 4.9-8 Cumulative Traffic Noise Level Increases
ID Road Segment
CNEL at Receiving
Land Use (dBA)1
Noise Level
Increase Threshold2
Existing
No
Project
OYC
With
Project
Cumulative
Increase Limit Cumulative
Impact?
1 Main St. n/o Struck Av. 71.0 71.1 0.1 3.0 No
2 Main St. s/o Struck Av. 71.6 71.8 0.2 3.0 No
3 Batavia St. n/o Katella Av. 69.9 70.3 0.4 3.0 No
4 Batavia St. s/o Katella Av. 68.9 70.2 1.3 3.0 No
5 Batavia St. s/o Struck Av. 69.4 69.8 0.4 3.0 No
6 Katella Av. w/o Main St. 71.2 71.7 0.5 3.0 No
7 Katella Av. e/o Main St. 71.9 72.4 0.5 3.0 No
8 Katella Av. e/o Batavia Av. 72.4 72.7 0.3 3.0 No
9 Katella Av. w/o SR-57 SB Ramps 73.0 73.2 0.2 3.0 No
10 Katella Av. e/o SR-57 NB Ramps 72.8 73.3 0.5 3.0 No
11 Struck Av. w/o Main St. 68.0 68.5 0.5 3.0 No
12 Struck Av. e/o Main St. 62.7 63.6 0.9 5.0 No
13 Struck Av. e/o Batavia Av. 62.6 67.5 4.9 5.0 No
1 The CNEL is calculated at the boundary of the right-of-way of each roadway and the property line of the receiving land use. 2 Does the Project create an incremental noise level increase exceeding the significance criteria? 534 Struck Avenue Project
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Source: (Urban Crossroads, 2022a, Table 7-7)

D. Ground-borne Vibration and Noise
During construction, the Project’s peak vibration impacts would occur during the grading phase when large pieces of equipment, like bulldozers, are operating on-site . During the non-grading phases of Project construction, when smaller pieces of equipment are used on-site, the Project’s vibration would be minimal. Vibration effects diminish rapidly from the source; therefore, the only reasonable sources of cumulative vibration in the vicinity of the Project site could occur on properties abutting these sites.

As described above, there are no known active or pending construction projects abutting the Project site that would overlap with the Project’s proposed construction schedule . Accordingly, there is no potential for the Project to contribute to the exposure of persons to substantial temporary ground-borne vibration or noise.

Under long-term conditions, the Project would not include or require equipment or activities that would result in perceptible ground-borne vibration beyond the Project site . Trucks would travel to and from the Project site along local roadways; however, vibration levels for heavy trucks operating at the posted speed limits on paved surfaces are not perceptible beyond the roadway . The Project would not cumulatively-contribute to the exposure of persons to excessive ground-borne vibration or noise levels during long-term operation.

E. Airport Noise
There are no conditions associated with implementation of the Project that would contribute airport noise or exposure of additional people to unacceptable levels of airport noise. Accordingly, the Project would have no potential to cumulatively contribute to impacts associated with noise from a public airport, public use airport, or private airstrip. Additionally, the Project site and the immediately surrounding area are not subject to substantial airport - or air traffic-related noise. Accordingly, there is no potential for cumulative development to expose persons residing or working in the Project area to excessive airport-related noise levels.

4.9.7 SIGNIFICANCE OF IMPACTS BEFORE MITIGATION
Threshold a: Less -than-Significant Impact. The Project would generate short -term construction and long-term operational noise but would not generate noise levels that exceed significance thresholds.

The Project would not result in generation of substantial temporary or permanent increase in ambient noise levels in the vicinity of the project. Impacts are less than significant.

Threshold b: Less-than-Significant Impact. The Project’s construction and operational activities would not result in excessive groundborne vibration or groundborne noise levels . Impacts are less than significant.

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Threshold c: No Impact. The Project site is not located within two miles of a public airport or within an airport land use plan, nor is the Project site located within the vicinity of a private airstrip. No impact would occur.

4.9.8 MITIGATION
Project impacts would be less than significant and mitigation is not required.

534 Struck Avenue Project
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4.10 TRANSPORTATION
This Subsection is based, primarily, on traffic analysis prepared by Urban Crossroads titled “534 Struck Avenue Traffic Analysis” dated October 10, 2022 (Urban Crossroads, 2022b); vehicle miles traveled reports prepared by Urban Crossroads, titled “534 Struck Avenue Vehicle Miles Traveled (VMT) Screening Evaluation” dated January 5, 2023 (Urban Crossroads, 2023e). These reports are included in this EIR as Technical Appendices K1 and K2 respectively.

This Subsection assesses transportation impacts resulting from implementation of the Project. In accordance with Senate Bill (SB) 743, further discussed under Subsection 4.10.2 below, the California Natural Resources Agency (CNRA) adopted changes to the CEQA Guidelines in December 2018, which identify that starting on July 1, 2020, vehicle miles traveled (VMT) is the appropriate metric to evaluate a project’s transportation impacts. As of December 2018, when the revised CEQA Guidelines were adopted, automobile delay, as measured by “level of service” (LOS) and other similar metrics, no longer constitutes a significant environmental effect under CEQA. Lead agencies in California are required to use VMT to evaluate project-related transportation impacts.

4.10.1 ENVIRONMENTAL SETTING
A. Existing Roadway System
The Project site is generally located north of Collins Avenue, east of Batavia Street, south of Struck Avenue, and west of the Orange County Transportation Authority/Southern California Regional Rail Authority (OCTA/SCRRA) Railroad. Access to the Project site is via three two-way driveways along Struck Avenue . The primary regional vehicular travel route serving the Project area is SR -57 via Katella Avenue located approximately 1.26 miles west.

B. Existing Bicycle and Pedestrian Facilities
As shown in Figure 4.10-1, City of Orange General Plan Bike Network , the closest bike lane is a proposed Class I (off-road) bike facility proposed along the Collins Channel, approximately 0.3 miles northwest from the Project site. There is no existing Class II (on-street, striped) or Class III (signed, but not striped) bike lanes within the Project site and its surroundings . Under existing conditions, sidewalks are provided along Struck Avenue, except along the Project’s site frontage. As shown in Figure 4.10-2, Existing Pedestrian Facilities, there are pedestrian facilities in place in the vicinity of the Project site.

C. Existing Transit Service
The Project site is currently served by Orange County Transit Authority (OCTA) with bus service along Katella Avenue Main Street. OCTA Route 50 and Route 153 run along Katella Avenue and portions of Main Street (north of Katella Avenue). OCTA Route 53 runs along Main Street. As shown in Figure 4.10-3, Existing Transit Routes, the closest existing bus stop is located at Batavia Street at Katella Avenue for OCTA Route 50, approximately 0.3 miles northwest from the Project site.

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D. Existing Truck Routes
Both Katella Avenue and Batavia Street adjacent to the Project are identified as truck routes. These truck routes serve both the proposed Project and future cumulative development projects throughout the Project area.

4.10.2 REGULATORY FRAMEWORK
A. State Regulations

1. Senate Bill 743 and VMT-Based Analysis
SB 743 (Steinberg, 2013), which was codified in Public Resources Code section 21099, required changes to the guidelines implementing CEQA Guidelines regarding the analysis of transportation impacts. Pursuant to Section 21099(b)(1), the criteria for determining the significance of transportation impacts must “promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses.” (see generally, adopted CEQA Guidelines, § 15064.3, subd. (b) [C riteria for Analyzing Transportation Impacts].) With the California Natural Resources Agency’s certification and adoption of the changes to the CEQA Guidelines, automobile delay, as measured by “level of service” and other similar metrics, no longer consti tutes a significant environmental effect under CEQA, except in specific circumstances identified in the CEQA Guidelines. (Pub. Resources Code, § 21099, subd. (b)(2))

B. Regional Regulations

1. SCAG Regional Transportation Plan/Sustainable Communities Strategy The Southern California Association of Governments (SCAG) is a regional agency established pursuant to California Government Code § 6500, also referred to as the Joint Powers Authority law.

SCAG is designated as a Council of Governments (COG), a Regional Transportation Planning Agency (RTPA), and a Metropolitan Planning Organization (MPO). The Project site is within SCAG’s regional authority. On September 3, 2020, SCAG adopted the 2020-2045 Regional Transportation Plan (RTP)/Sustainable Communities Strateg y (SCS) (“RTP/SCS”; also referred to herein as “Connect SoCal”) with goals to: 1) Encourage regional economic prosperity and global competitiveness; 2) Improve mobility, accessibility, reliability, and travel safety for people and goods; 3) Enhance the preservation, security, and resilience of the regional transportation system; 4) Increase person and goods movement and travel choices within the transportation system; 5) Reduce greenhouse gas emissions and improve air quality; 6) Support healthy and equitable communities; 7) Adapt to a changing climate and support an integrated regional development pattern and transportation network; 8) Leverage new transportation technologies and data -driven solutions that result in more efficient travel; 9) Encourage devel opment of diverse housing types in areas that are supported by multiple transportation options; and 10) Promote conservation of natural and agricultural lands and restoration of habitats (SCAG, 2020). Performance measures and funding strategies also are included to ensure that the adopted goals are achieved through implementation of the RTP.

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Connect SoCal includes long-range regional transportation plans, regional transportation improvement programs, regional housing needs al locations, and other plans for the region. Connect SoCal also provides objectives for meeting emissions reduction targets set forth by the California Air Resources Board (CARB); these objectives were provided in a direct response to SB 375 which was enact ed to reduce greenhouse gas emissions from automobiles and light trucks through integrated transportation, land use, housing, and environmental planning (SCAG, 2020). Connect SoCal is updated periodically to allow for the consideration and inclusion of new transportation strategies and methods.

The Goods Movement Technical Report of Connect SoCal is applicable to the Project because the Project includes industrial uses, which are closely associated with, and rel y directly on, the goods movement system (e.g., manufacturing, construction, retail trade, wholesale trade and transportation, and warehousing). In April 2018, SCAG published a document entitled Industrial Warehousing in the SCAG Region. According to the document, the SCAG region is a vibrant hub for international and domestic trade because of its large transportation base and extensive multimodal transportation system.

The SCAG region’s freight transportation system includes warehouses and distribution centers; the Ports of Los Angeles, Long Beach, and Hueneme; airports; rail intermodal terminals; rail lines, and local streets, State highways, and interstates. Together the system enables the movement of goods from source to market, facilitating uninterrupt ed global commerce. The region is home to approximately 34,000 warehouses with 1.17 billion square feet (s.f.) of warehouse building space, and undeveloped land that could accommodate an additional 338 million s.f. of new warehouse building space. These warehouses attract robust logistics activities and are a major reason the region is a critical mode in the global supply chain. (SCAG, 2018)

C. Local Regulations

1. City of Orange General Plan Circulation and Mobility Element The City of Orange General Plan Circulation and Mobility Element prioritizes the issues and opportunities that exist within the City of Orange’s transit network. The goals, policies, and implementation programs of the Circulation & Mobility Element seek t o achieve a better balance between vehicular, pedestrian, and bicycle travel, and to provide a wide range of viable transportation options to Orange residents. The following six issues are addressed: (1) enhancing the local circulation system; (2) maintaining the regional circulation system; (3) maintaining a viable public transportation network; (4) creating a comprehensive system of sidewalks, trails, and bikeways; (5) providing adequate parking facilities; and (6) improving circulation system aesthetics and safety . (Orange, 2015d)

4.10.3 METHODOLOGY
CEQA Guidelines Section 15064.3(b) establishes criteria for evaluating a project’s transportation impacts based on project type and using automobile VMT as the metric. As identified in S ection 15064.3(b)(4) of the CEQA Guidelines, a lead agency has the discretion to choose the most appropriate methodology to evaluate a project's VMT. The Governor’s Office of Planning and Research (OPR) released a Technical Advisory on Evaluating Transport ation Impacts in CEQA. Based on OPR’s 534 Struck Avenue Project
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Technical Advisory, the City of Orange has prepared their City of Orange Traffic Impact Analysis Guidelines for Vehicle Miles Traveled and Level of Service Assessment . The City Guidelines have been utilized to prepare the Project’s VMT analysis.

For the purposes of fully disclosing potential VMT impacts, this analysis includes a VMT evaluation measuring Project VMT. City Guidelines identify Orange County Transportation Analysis Model (OCTAM) version 5.0 as the appropriate tool for conducting VMT analysis for land use projects in the City of Orange. OCTAM is a useful tool to estimate VMT as it considers interactions between different land uses based on socio-economic data such as population, households, and employment.

4.10.4 BASIS FOR DETERMINING SIGNIFICANCE
According to Section XVI of Appendix G to the CEQA Guidelines, the proposed Project would result in a significant impact to transportation and traffic if the Project or any Project -related component would (OPR, 2019):

• Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities;
• Conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b);

• Substantially increase h azards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment);

• Result in inadequate emergency access.

4.10.5 IMPACT ANALYSIS
Threshold a: Would the Project conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? A. Project Trip Generation
The Institute of Transportation Engineers Trip Generation Manual includes trip generation rates for an Intermodal Truck Terminal (ITE Land Use Code 030), however, upon further review the land use was not deemed appropriate for use. Specifically, the rates included in the ITE Trip Generation Manual are based on data collected at only 2 or 4 sites (ranging in size from 10,000 to 35,000 square feet), which are all located outside of California and are dated from the 1990s and 2010s. ITE also has a cautionary note on the AM peak hour trip generation rates as the number of surveyed sites is bel ow the ITE’s recommended minimum of 3 sites.

In light of the proposed building size discrepancy and the desire to use data that is more current data that is specific to Southern California, driveway counts were collected at 5 existing facilities in order to generate a unique rate specific to the proposed Project . The sites that were specifically chosen are very similar in nature to the proposed Project. The data collected at the 5 sites indicates most of the 534 Struck Avenue Project
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truck activity occurs outside of the typical morning and evening peak commute hours (7-9 AM and 4- 6 PM). The number of dock doors has been utilized as the independent variable in calculating the trip generation rates as opposed to square footage since the proposed building is not intended to be used for the storage of materials. The trip generation for a truck terminal facility could be better correlated to the number of dock doors due to the truck activity associated with the transfer of goods. The empirical data provides a more conservative (higher) t rip rate than trip generations rates under ITE Land Use Code 030.

As a result, i mplementation of the Project is anticipated to generate 3 96 two-way daily trips with 26 AM peak hour trips and 23 PM peak hour trips. (Urban Crossroads, 2022b)

B. Roadway Facilities
According to Figure CM-2 of the City General Plan Circulation and Mobility Element, Struck Avenue is classified as a Collector Street (2 lanes undivided), Batavia Street is classified as a Primary Arterial (4 lanes divided), and Katella Avenue is classified as a Smart Street (6-8 lanes divided). Additionally, the Katella Avenue/Batavia Street intersection is identified as a critical intersection, which is an intersection that deviates from the City’s typical design standards by increasing the number of lanes at an intersection beyond what typically would be required. By increasing capacity at the critical intersection, the circulation link increases overall system capacity (Orange, 2015d).

As shown in Figure 4.10-4, Truck Routes, truck-trailers will utilize SR-57 via Katella Avenue to travel to the site. Truck-trailers exiting the site would travel west on Struck Avenue, turn right onto northbound Batavia Street, and turn left onto westbound Katella Avenue to access the SR-57. Truck- trailers enter ing the site would exit the SR -57 at Katella eastbound, turn right at Batavia Street southbound, and turn left onto Struck Avenue eastbound. Traveling eastbound from SR-57 on Katella Avenue, truck-trailers would be prohibited from turning right onto Struck Avenue to access the site .

West of Batavia Street, all eastbound and westbound truck-trailer movement will occur on Katella Avenue. The Project would utilize routes consistent with the City’s truck routes. Additionally, the City will impose conditions of approval to require 1) posting of the truck routes in the building; 2) tenant provided driver education on the truck route; and 3) truck route street signage. Therefore, implementation of the Project would not conflict with an applicable pla n, ordinance, or policy addressing the circulation system. Impacts would be less than significant.

C. Transit
The OCTA provides bus service for the City. The nearest bus stop to the Project site is the Route 50 Katella-Batavia bus stop operated by OCTA loca ted approximately 0.3 miles (approximate 4-minute walk) northwest. The City recognizes that ridership of bus systems will increase and has designed a land use plan that enables and accommodates increased transit use. The City has identified major commercial and employment areas which include the Town and County Road corridor, South Main Street, Katella Avenue, Uptown Orange, and Old Towne. The Project site is not located within the identified major commercial and employment areas of the City. Therefore, the Project does not have 534 Struck Avenue Project
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the potential to interfere with the City’s goal to provide convenient and attractive transit amenities and streetscape features to encourage transit use. No impacts would occur.

D. Bicycle and Pedestrian Facilities
The City of Orange recognizes walking and biking contribute to a healthy community and play significant roles as alternatives to the automobile. The City has identified mixed-use areas and reinvigorated commercial areas within the City as spaces that will provide people areas to walk and shop. The City’s goal is to create and implement a pedestrian-oriented streetscape master plan addressing the key commercial corridors including Tustin Street, Chapman Avenue, Main Street, Lincoln Avenue, and Katella Avenue. The Project site not in any of the key commercial corridors. The Project site is within an urbanized and industrial portion of the City that is not conducive to walking.

Under existing conditions, sidewalks are provided along Struck Avenue, except along the Project’s site frontage. Implementation of the Project would not interfere with the City’s pedestrian-oriented streetscape master plan. No impacts would occur.

As previously discussed, the Project site is within an industrialized area of the City. According to Figure CM-3 of the City’s General Plan Circulation and Mobility Element, there are is no existing Class II (on-street, striped) or Class III (signed, but not striped) bike lanes within the Project site and its surroundings. Implementation of the Project would not i nterfere with the City’s Bikeway Master Plan. No impacts would occur.

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Threshold b: Would the Project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
Changes to State CEQA Guidelines were adopted in December 2018, which requires all lead agencies to adopt vehicle miles traveled (VMT) as a replacement for automobile delay-based level of service (LOS) as the new measurement for identifying transportation impacts for land use projects. This statewide mandate took effect on July 1, 2020.

The City of Orange adopted their own VMT analysis guidelines and thresholds on July 14, 2020. The City has chosen to utilize the North Orange County Collaborative VMT Traffic Study Screening Tool (Screening Tool) that identifies VMT screening criteria for a project based on the type of land use and its location within the City. The Screening tool is based on the screening criteria described in the adopted City Guidelines and follows the those recommended by the Office of P lanning and Research (OPR) in their Technical Advisory on Evaluating Transportation Impacts in CEQA.

The City Guidelines provide a multi -step procedure to evaluate VMT screening criteria that can be used to identify when a proposed land use project is ant icipated to result in a less than significant impact without conducting a more detailed project level VMT analysis. The screening criteria are listed as three steps:

• Transit Priority Area (TPA) Screening
• Low VMT Area Screening
• Project Type Screening

A land use project needs only to meet one of the above screening thresholds to result in a less than significant impact.

A. TPA Screening
The City’s TIA Guidelines note that projects within a TPA, 0.5 miles of an existing “major transit stop,” or an existing stop along a “high-quality transit corridor” will have a less than significant impact on VMT. According to the Screening Map, the Project site is within a TPA. Although the Project site is within a TPA, if the Project meets any of the following secondary sc reening checks, the Project would not meet the TPA Screening threshold:

• Has a FAR of less than 0.75;
• Includes more parking for use by residents, customers, or employees of the project than required by the jurisdiction (if the jurisdiction requires the project to supply parking); • Is inconsistent with the applicable SCS (as determined by the lead agency, with input from the Metropolitan Planning Organization); or
• Replaces affordable residential units with a smaller number of moderate - or high-income residential units.

534 Struck Avenue Project
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The Project site is located within ½ mile of an existing major transit stop, or along a high-quality transit corridor. However, the Project’s proposed FAR would be less than 0.75; therefore, the Project would not meet the TPA Screening threshold.

B. Low VMT Area Screening
According to the City’s TIA Guidelines, “residential and office projects located within a low VMT generating area may be presumed to have a less than significant impact absent substantial evidence to the contrary. In addition, other employment related and mixed -use land use projects may qualify for the use of screening if the project can reasonably be expected to generate VMT per resident, per worker, or per service population that is similar to the existing land uses in the low VMT area.” VMT performance for the traffic analysis zones (TAZ) containing the Project was collected using the Orange County Transportation Analysis Model (OCTAM). The TAZ containing the Project (i.e., OCTAM TAZ #457) has an existing VMT per service population of 24.85 VMT per service population and the City’s impact threshold is 31.3 VMT per service population. The Project is located in a TAZ that generates VMT below the City’s VMT impact threshold. The Low VMT Area screening threshold is met.

C. Project Type Screening
The City Guidelines provides a list of project types that are presumed to have a less than significant impact absent substantial evidence to the contrary. A brief list of these project types includes:

• Local serving essential services (i.e., public schools, parks, day care centers, etc.) • Local serving retail (less than 50,000 square feet)
• Local serving hotels
• Assisted living facilities
• Community institutions (i.e., public libraries, fire stations, local government) • Projects that generate less than 110 daily vehicle trips

The Project does not intend to develop any of the above outlined local serving uses and is estimated to generate daily vehicle trips that would exceed the 110 daily trip threshold. Therefore, the Project would not meet the Project Type Screening threshold.

D. Conclusion
Based on the review of applicable VMT screening thresholds, the Project meets the Low VMT Area screening criteria and would therefore result in a less than significant VMT impact.

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Threshold 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)?
Vehicular access to the site would be provided via two driveways along the site’s northern boundary on Struck Avenue. The Project’s proposed driveway 1, located at the site’s northwest corner, and driveway 2, located at the site’s northeast corner, would accommodate the wide turning radius of the heavy trucks. Due to the typical wide turning radius of large trucks, a truck turning template has been overlaid on the site plan at each applicable Project driveway anticipated to be utilized by heavy trucks in order to determine appropriate curb radii and to verify that trucks will have sufficient space to execute turning maneuvers. Figure 4.10-5, Project Driveway Truck Access , shows that the Project driveways would accommodate the wide turning radius of the heavy trucks (WB‐67, 53‐foot trailer) as currently designed. Additionally, the truck exit would occur at the westernmost driveway (driveway 1) away from the existing driveway across Struck Avenue to the north, which would provide future access to the proposed Orange City Yard Affordable Housing Project, located approximately 220 feet north of the Project site. The Project would not increase hazards and impacts are less than significant.

Threshold d: Would the Project result in inadequate emergency access? According to the City General Plan Public Safety Element, the City has an emergency plan which establishes emergency preparedness and emergency response procedures. All City arterials are recognized as primary emergency response routes and non-arterials ar e recognized as secondary emergency response routes. The Project would have two driveways along Struck Avenue. All Project driveways would be subject to the City’s site access and circulation requirements identified in OMC Chapter 12, Streets, Sidewalks, and Public Places. Additionally, the Project’s internal drive aisles will provide adequate access for emergency vehicles. Moreover, all construction staging would occur within the boundaries of the Project site and would not interfere with the circulation of nearby roadways or implementation of the City’s emergency plan. The Project would provide adequate emergency access for fire vehicles via Struck Avenue. Impacts would be less than significant.

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4.10.6 CUMULATIVE IMPACT ANALYSIS
This cumulative impact analysis considers development of the proposed Project in conjunction with other development projects and planned development. The analysis under Threshold “a” indicates that the Project would not conflict with relevant programs, pla ns, and policies addressing the circulation system. Each related project would be expected to comply with all applicable relevant programs, plans, and policies. Therefore, no cumulative impact would occur.

OPR’s Technical Advisory states that “a project t hat falls below an efficiency -based threshold (e.g., VMT per service population) that is aligned with long-term goals and relevant plans has no cumulative impact distinct from the project impact. Accordingly, a finding of a less than significant project impact would imply a less than significant cumulative impact and vice versa. This is similar to the analysis typically conducted for greenhouse gas emissions, air quality impacts, and impacts that utilize plan compliance as a threshold of significance.” Since the Project was found to have a less than significant impact at the project level, it would result in a less than significant cumulative impact.

Based on the review of the Project s ite driveways, no safety concerns relating to geometric design of the Project site access points or emergency access would occur. Furthermore, the Project is compatible with the uses in the immediately surrounding area. Therefore, impacts are not considered to be cumulatively-considerable and no significant cumulative impact would occur.

4.10.7 SIGNIFICANCE OF IMPACTS BEFORE MITIGATION
Threshold a: Less than Significant Impact. The Project would not conflict with a program, plan, policy addressing the circulation system such that the Project would result in a significant impact on the environment.

Threshold b: Less than Significant Impact. The Project meets the Low VMT Area screening criteria and would result in a less than significant VMT impact.

Threshold c: Less than Significant Impact. The Project would not create or substantially increase safety hazards due to a design feature or incompatible use.

Threshold d: Less than Significant Impact . Adequate emergency access would be provided to the Project site during construction and long-term operation. The Project would not result in inadequate emergency access to the site or surrounding properties.

4.10.8 MITIGATION
Impacts would be less than significant; therefore, mitigation is not required. 534 Struck Avenue Project
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4.11 TRIBAL CULTURAL RESOURCES
The analysis in this Subsection relies on information from a cultural resource assessment report titled “Cultural and Paleontological Resource Letter Report for the 534 Struck Avenue Project ,” and dated April 30, 2021. The report was prepared by Duke CRM and is included as Technical Appendix D to this EIR. (Duke, 2021). The analysis in this Subsection also contains information obtained by the City during consultation with local Native American tribal representatives. All references used in this Subsection are listed in EIR Section 7.0, References.

Confidential information has been redacted from Technical Appendix D for purposes of public review.

In addition, much of the written and oral communication between Native American tribes, the City, and Duke CRM is considered confidential in respect to places that may have traditional tribal cultural significance (Government Code Section 65352.4), and although relied upon in part to inform the preparation of this EIR Subsection, those communications are treated a s confidential and are not available for public review. Under existing law, environmental documents must not include information about the location of archeological sites or sacred lands or any other information that is exempt from public disclosure pursua nt to the Public Records Act (California Code Regulations Section 15120(d)).

4.11.1 EXISTING CONDITIONS
Refer to Subsection 4.3, Cultural Resources , for a description of the prehistoric period setting for southern California.

A. Project Site Conditions
The Project site is developed with an approximately 40,000 square foot (sf) manufacturing facility that was occupied until the end of 2020 by Nursery Supplies, Inc., a manufacturer of plastic nursery planting pots. The Project site is primarily hardscaped and ground surface visibility was limited to the perimeter with less than five percent visibility. Areas of exposed soils and sediments were subject to 10-15 meter pedestrian transects. All observed soils and sediments were fill, and no archeological or paleontological resources were observed during the survey.

A cultural resources records search was performed by Duke CRM for the Project at the South Central Coastal Information Center (SCCIC) at California State University, Fullerton in order to identify any National Register of Historic Places (NRHP) or California Register of Historical Resources (CRHR) within one-half mile of the Project site. The results indicate that no previous cultural resource studies have included the Project site boundaries.

4.11.2 REGULATORY FRAMEWORK
The following is a brief description of applicable State environmental laws and related regulations governing the protection of tribal cultural resources.

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A. State Plans, Policies, and Regulations

1. Assembly Bill 52 (AB 52)
California AB 52 (2014) Chapter 532 amended Section 5097.94 of, and added Sections 21073, 21074, 21080.3.1, 21080.3.2, 21802.3, 21083.09, 21084.2 and 21084.3 to the California Public Resources Code, relating to Native Americans. AB 52 was approved on September 25, 2014. The legislature added new requirements regarding tribal cultural re sources in AB 52. By including tribal cultural resources early in the CEQA process, the legislature intended to ensure that local and Tribal governments, public agencies, and project proponents would have information available, early in the project planning process, to identify and address potential adverse impacts to tribal cultural resources (OPR, 2017a). By taking this proactive approach, the legislature also intended to reduce the potential for delay and conflicts in the environmental review process.

The Public Resources Code now establishes that “[a] project with an effect that may cause a substantial adverse change in the significance of a tribal cultural resource is a project that may have a significant effect on the environment.” (Pub. Resources Code, Section 21084.2.) To help determine whether a project may have such an effect, the Public Resources Code requires a lead agency to consult with any California Native American tribe that requests consultation and is traditionally and culturally affiliated with the geographic area of a proposed project. That consultation must take place prior to the determination of whether a negative declaration, mitigated negative declaration, or environmental impact report is required for a project (Pub. Resources Code, Section 21080.3.1.).

If a lead agency determines that a project may cause a substantial adverse change to tribal cultural resources, the lead agency must consider measures to mitigate that impact. Public Resources Code Section 20184.3 (b)(2) provides examples of mitigation measures that lead agencies may consider to avoid or minimize impacts to tribal cultural resources.

Section 21074 of the Public Resources Code defines “tribal cultural resources.” In brief, in order to be considered a “tribal cultural resource,” a resource must be either:

(1) listed, or determined to be eligible for listing, on the national, state, or local register of historic resources, or
(2) a resource that the lead agency chooses, in its discretion, to treat as a tribal cult ural resource.

In the latter instance, the lead agency must determine that the resource meets the criteria for listing in the state register of historic resources. In applying those criteria, a lead agency must consider the value of the resource to the tribe. (OPR, 2017b)

2. State Health and Safety Code
California Health and Safety Code Section 7050.5(b) requires that excavation and disturbance activities must cease “In the event of discovery or recognition of any human remains in any location 534 Struck Avenue Project
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other than a dedicated cemetery…” until the coroner can determine regarding the circumstances, manner, and cause of any death (CA Legislative Info, n.d.). The coroner is then required to make recommendations concerning the treatment and disposition of the human remains. Further, this section of the code makes it a misdemeanor to intentionally disturb, mutilate or remove interred human remains. Section 7051 specifies that the removal of human remains from “internment or a place of storage while awaiting internment” with the intent to sell them or to dissect them with “malice or wantonness” is a public offense punishable by imprisonment in a state prison. Lastly, Health and Safety Code Sections 8010-8011 establish the California Native American Graves Protection and Repatriation Act consistent with the federal law addressing the same. The Act stresses that “all California Indian human remains and cultural items are to be treated with dignity and respect.” It encourages voluntary disclosure and return of remains and cultural items by publicly funded agencies and museums in California. It also outlines the need for aiding California Indian tribes, including non- federally recognized tribes, in filing repatriation claims.

California Health and Safety Code, Section 5097.98 states that whenever the commission receives notification of a discovery of Native American human remains pursuant to HSC subdivision (c) of Section 7050.5, it shall immediately notify those persons that a re the most likely descendants. The descendants may inspect the Site and make recommendations to the landowner as to the treatment of the human remains. The landowner shall ensure that the immediate vicinity around the remains is not damaged or disturbed by further development activity until coordination has occurred with the descendants regarding their recommendations for treatment, taking into account the possibility of multiple human remains. The descendants shall complete their inspection and make recommendations within 48 hours of being granted access to the Site. (CA Legislative Info, n.d.)

4.11.3 BASIS FOR DETERMINING SIGNIFICANCE
According to Section XVII of Appendix G to the CEQA Guidelines, the proposed Project would result in a significant impact to tribal resources if the Project or any Project-related component would (OPR, 2019):

• 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:

a) 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

b) A resource determined by the lead agency, in its discretion and support ed 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 Resources Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.
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4.11.4 IMPACT ANALYSIS
Threshold 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: 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 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 Resources Code Section 5024.1, the lead agency shall consider th e significance of the resource to a California Native American tribe?

As analyzed in Section 4.3, Cultural Resources, Threshold a, there are no resources on the Project site that are eligible for listing in the National Register of Historic Places, California Register of Historical Resources, or in a local register of historical resources as defined by Public Resources Code Section 5020.1(k). Implementation of the Project would not result in a substantial adverse change in the significance of a listed historical resource. No impacts would occur.

As of July 1, 2015, California Assembly Bill 52 (AB 52) was enacted and expanded CEQA by establishing a formal consultation process for California tribes within the CEQA process. In compliance with AB 52, the City of Orange distributed letters on July 9, 2020 to those Native American tribes that have requested notification for AB 52 notifying each tribe of the opportunity to consult with the City on the Project. O nly the Gabrieleno Band of Mission Indians – Kizh Nation has requested consultation with the City of Orange. The City conducted Tribal Consultation with the Gabrieleno Band of Mission Indians – Kizh Nation on September 10, 2020. The results of the Sacred Lands File search were received from the NAHC on Fe bruary 24, 2019. This search did not identify any sacred lands within the Project, nor in the vicinity.

Because the Project would require excavation for construction into previously undisturbed soils, there is a potential to uncover undiscovered prehistoric artifacts or tribal cultural resources during excavation. Therefore, while unlikely, the presence of subsurface tribal cultural resources on the Project site remains possible, and these could be affected by ground-disturbing activities associated with grading and construction at the Project site. As a result, impacts to tribal cultural resources are potential significant.

4.11.5 CUMULATIVE IMPACT ANALYSIS
This cumulative impact analysis considers development of the proposed Project in conjunction with other development projects and planned development in the vicinity of the Project site that have a potential for uncovering tribal cultural resources as defined by Public Resources Code 21074. Impacts 534 Struck Avenue Project
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relating to tribal cultural resources impacts are site -specific and addressed on a site -by-site basis.

Therefore, while there is a potential for an impact on a specific site, the impact would not ordinarily extend beyond the site or immediately surrounding area. There could be circumstances in which a tribal cultural resource extends over more than one property, but in that event, there could be a cumulative effect only if all affected properties were in the process of being developed and physical alterations to the ground were proposed in all of those projects. There are no adjacent related projects that could potentially result in affects to unknown tribal cultural resources that may lie in the subsurface of the Project site; therefore, there would be no cumulative impacts affecting tribal cultural resource.

4.11.6 SIGNIFICANCE OF IMPACTS BEFORE MITIGATION
Threshold a: Potentially Significant Direct Impact. The Project site does not contain any recorded, significant tribal cultural resource sites; therefore, the Project would not cause a substantial adverse change in the significance of a tribal cultural resource that is listed or eligible for listing in the California Register of Historical Resources or a local register of historical resources. Nonetheless, Project construction activities have the potential to unearth and adversely impact tribal cultural resources that may be buried at the Project site.

4.11.7 MITIGATION
MM 4.11-1 Prior to the commencement of any ground disturbing activi ty at the project site, the Project Applicant shall retain a Native American Monitor approved by the Gabrieleno Band of Mission Indians-Kizh Nation – the tribe that consulted on this project pursuant to Assembly Bill A52 (the “Tribe” or the “Consulting Tribe”). A copy of the executed contract shall be submitted to the City of Orange Planning and Building Department prior to the issuance of any permit necessary to commence a ground-disturbing activity.

The Tribal monitor will only be present on-site during t he construction phases that involve ground-disturbing activities into areas of undisturbed soils. Ground disturbing activities are defined by the Tribe as activities that may include, but are not limited to, pavement removal, potholing or auguring, grubbing, tree removals, boring, grading, excavation, drilling, and trenching, within the Project site . The Tribal Monitor will complete daily monitoring logs that will provide descriptions of the day’s activities, including construction activities, locations, soil, and any cultural materials identified.

The on-site monitoring shall end when all ground- disturbing activities on the Project site are completed, or when the Tribal Representatives and Tribal Monitor have indicated that all upcoming ground-disturbing activities at the Project site have little to no potential for impacting Tribal Cultural Resources.

Upon discovery of any Tribal Cultural Resources, construction activities shall cease in the immediate vicinity of the find (not less than the surrounding 100 feet) until the find can be assessed. All Tribal Cultural Resources unearthed by project activities shall be evaluated by the qualified archaeologist and Tribal monitor approved by the Consulting Tribe. If the resources are Native American in origin, the Consulting Tribe will retain it/them in the form and/or manner the Tribe deems appropriate, for educational, cultural 534 Struck Avenue Project
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and/or historic purposes. If human remains and/or grave goods are discovered or recognized at the Project site, all ground disturbance shall immediately cease, and the county coroner shall be notified per Public Resources Code Section 5097.98, and Health & Safety Code Section 7050.5. Human remains and grave/burial goods shall be treated alike per California Public Resources Code section 5097.98(d)(1) and (2). Work may continue on other parts of the Project site while evaluation and, if necessary, mitigation takes place (CEQA Guidelines Section 15064.5[f]). If a non-Native American resource is determined by the qualified archaeologist to cons titute a “historical resource” or “unique archaeological resource,” time allotment and funding sufficient to allow for implementation of avoidance measures, or appropriate mitigation, must be available. The treatment plan established for the resources shall be in accordance with CEQA Guidelines Section 15064.5(f) for historical resources and PRC Sections 21083.2(b) for unique archaeological resources.

4.11.8 SIGNIFICANCE OF IMPACTS AFTER MITIGATION
Threshold a: Less -than-Significant with Mitigation Incorporated. Implementation of Mitigation Measure MM 4.11-1 would ensure the proper identification and subsequent treatment of any significant tribal cultural resources that may be encountered during ground -disturbing activities associated with Project development. With implementation of the required mitigation, the Project’s potential impact to significant tribal cultural resources would be reduced to less-than-significant.

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5.0 OTHER CEQA CONSIDERATIONS

5.1 SIGNIFICANT ENVIRONMENTAL EFFECTS THAT CANNOT BE AVOIDED IF THE PROJECT IS

IMPLEMENTED
The CEQA Guidelines require that an EIR disclose the significant environmental effects of a proposed project that cannot be reduced to a level of insignificance if the project is implemented and, where impacts cannot be alleviated without imposing an alter native design, the reasons why the project is being proposed, notwithstanding its effect, should be described (CEQA Guidelines Section 15126(b) & Section 15126.2(c)). As described in detail in Section 4.0 of this EIR, after the consideration of Project des ign features, compliance with applicable federal, State, and local regulations, and the application of the feasible mitigation measures identified in this EIR, the Project is not expected to result in any significant and unavoidable environmental impact.

5.2 SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL CHANGES WHICH WOULD BE CAUSED BY THE

PROJECT SHOULD IT BE IMPLEMENTED
The CEQA Guidelines require EIRs to address any significant irreversible environmental changes that would be involved in the proposed action shoul d it be implemented (CEQA Guidelines Section 15126.2(c)). An environmental change would fall into this category if: a) the project would involve a large commitment of non-renewable resources; b) the primary and secondary impacts of the project would generally commit future generations to similar uses; c) the project involves uses in which irreversible damage could result from any potential environmental accidents; or d) the proposed consumption of resources are not justified (e.g., the project results in the wasteful use of energy).

A. Would the project involve a large commitment of non-renewable resources? Determining whether the Project may result in significant irreversible environmental changes requires a determination of whether key non-renewable resources would be degraded or destroyed in such a way that there would be little possibility of restoring them . Natural resources, in the form of construction materials and energy resources, would be used in the construction of the proposed Project.

The consumption of these natural resources would represent an irreversible change to the environment.

However, development of the Project site would have no measurable adverse effect on the availability of such resources, including resources that may be non-renewable (e.g., construction aggregates, fossil fuels) and, in fact, the Project would crush existing on-site concrete and re-use the crushed concrete as a base material during Project construction to minimize the demand for construction aggregates and fossil fuels (that would be used to power the haul trucks bringing aggregates to the Project site ).

Additionally, the Project is required by law to comply with the California Green Building Standards Code (CALGreen), which will minimize the Project’s demand for energy, including energy produced from non-renewable sources. A more detailed discussion of Project energy consumption is provided in EIR Subsection 4.4, Energy.

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B. Would the primary and secondary impacts of the project generally commit future generations to similar uses?
Implementation of the Project would commit the Project site to a truck terminal facility. The land use proposed is compatible previous historic uses of the property (e.g., manufacturing) and with the existing land use and zoning. Accordingly, the Project and its environmental effects would not compel or commit surrounding properties to land uses other than those that are existing today or those that are planned by the City’s General Plan . For this reason, the Project would not result in a significant, irreversible change to nearby, off-site properties.

C. Would the project involve uses in which irreversible damage could result from any potential environmental accidents?
EIR Subsection 4.7, Hazards and Hazardous Materials , provides an analysis of the potential for hazardous materials to be transported to/from the Project site and/or used on the Project site during construction and operation. As concluded in Subsection 4.8, mandatory compliance with federal, State, and local regulations related to hazardous materials handling, storage, and use , in addition to compliance with the Soil Management Plan by all Project construction contractors (near term) and occupants (long-term) would ensure that any hazardous materials used on- site would be safely and appropriately handled to preclude any irreversible damage to the environment that could result if hazardous materials were released from the Site.

D. Would the project result in consumption of resources that are not justified (e.g., the project results in the wasteful use of energy)?
As discussed in detail under EIR Subsection 4.4, Energy, the Project would not result in a wasteful, inefficient, or unnecessary consumption of energy. Accordingly, the Project would not result in a significant, irreversible change to the environment related to energy use.

E. Summary
Based on the above, Project construction and operation would require the commitment of limited, slowly renewable and non-renewable resources. However, this commitment of resources would not be substantial and would be consistent with regional and local growth forecasts and development goals for the area. The loss of such resources would not be highly accelerated when compared to existing conditions, and such resources would not be used in an inefficient or wasteful manner. Project construction and operation would adhere to the sustainability requirements of Title 24, Green Building Code, and CALGreen. Therefore, the Project would not result in the commitment of large quantities of natural resources that would result in significant irreversible environmental changes.

5.3 GROWTH-INDUCING IMPACTS OF THE PROJECT
CEQA requires a discussion of the ways in which the proposed Project could be growth inducing. The CEQA Guidelines identify a p roject as growth inducing if it would foster economic or population 534 Struck Avenue Project
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growth or the construction of additional housing, either directly or indirectly, in the surrounding environment (CEQA Guidelines Section 15126.2(d)). New employees and new residential populations represent direct forms of growth. These direct forms of growth have a secondary effect of expanding the size of local markets and inducing additional economic activity in the area.

A project could indirectly induce growth at the local level by increasing the demand for additional goods and services associated with an increase in population or employment and thus reducing or removing the barriers to growth. This typically occurs in suburban or rural environs where population growth results in increased demand for service and commodity markets responding to the new population of residents or employees.

According to regional population projects included in SCAG’s Connect SoCal, the City of Orange’s population is projected to grow by 13,100 residents between 2016 and 2045 (approximately 0.3 percent annual growth (SCAG, 2020). Over this same time period, employment in the City is expected to add 8,300 new jobs (approximately 0.2 percent annual job growth) (ibid). Economic growth would likely take place as a result of the Project’s operations as a truck terminal facility and all other legally permitted uses. The Project’s employees (short-term construction and long- term operational) would purchase goods and services in the region, but any secondary increase in employment associated with meeting these goods and services demands is expected to be accommodated by existing goods and service providers and, based on the amount of existing and planned future commercial and retail services available in areas near the Project site, would be highly unlikely to result in any unanticipated, adverse physical impacts to the environment. In addition, the Project would create jobs, a majority of which would likely be filled by reside nts of the housing units either already built or planned for development within the City and nearby incorporated and unincorporated areas. Accordingly, because it is anticipated that most of the Project’s future employees would already be living in the City or the immediate surrounding area, the Project’s introduction of new employment opportunities on the Project site would not induce substantial growth in the area.

The General Plan land use designation for the site is Light Industrial (LI). As the Project vicinity is predominantly built-out, the development of the Project is unlikely to affect the existing uses within the surrounding properties. The Project is limited to the Project site’s boundaries and does not include any components that would indirec tly affect existing or planned uses on neighboring properties.

Accordingly, the Project would not induce growth in the Project area.

Under CEQA, growth inducement is not considered necessarily detrimental, beneficial, or of little significance to the environment. Typically, growth-inducing potential of a project would be considered significant if it fosters growth or a concentration of population in excess of what is assumed in pertinent master plans, land use plans, or in projections made by regional pla nning agencies such as SCAG.

Significant growth impacts also could occur if a project provides infrastructure or service capacity to accommodate growth beyond the levels currently permitted by local or regional plans and policies. In general, growth induced by a project is considered a significant impact if it directly or indirectly affects the ability of agencies to provide needed public services, or if it can be demonstrated that the potential 534 Struck Avenue Project
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growth significantly affects the environment in some other w ay. The Project is consistent with the industrial land use designations applied to the Project site by the City’s General Plan. The Project site and surrounding area i s fully developed with industrial and commercial land uses. Further, implementation of the Project would not require the expansion of water and sewer infrastructure, as the Project would connect to existing water and sewer lines within Struck Avenue.

The operation and maintenance of the Project would generate up to approximately 60 to 130 jobs, but any potential growth-inducing impact of the employment of persons at the Project site was accounted for in the City’s General Plan, as the Project would develop the Project site in compliance with the City’s General Plan land use designation. Accordingly, the Project would not directly promote growth either at the Project site or at the adjacent and surrounding properties that w ere not accounted for in the City’s General Plan.

In conclusion, not reasonably foreseeable that the Project would induce growth in the form of additional economic activity or employment that would result in measurable impacts on the off-site physical environment.

5.4 EFFECTS FOUND NOT TO BE SIGNIFICANT DURING THE EIR PREPARATION PROCESS CEQA Guidelines Section 15128 requires that an EIR “…contain a statement briefly indicating the reasons that various possible significant effects of a project were determined not to be significant and were therefore not discussed in detail in the EIR.” During the preparation of this EIR, the Project was determined to clearly have no potential to result in significant impacts under nine (9) environmental issue areas: aesthetics, agriculture and forest resources, land use and planning, mineral resources, population and housing, public services, recreation, utilities and service systems, and wildfire .

Therefore, these issue areas were not required to be analyzed in detail in EIR Section 4.0, Environmental Analysis. A brief analysis of the Project’s impacts to aesthetics, agriculture and forest resources, land use and planning, mineral resources, population and housing, public services, recreation, utilities and service systems, and wildfire is presented below and on the following pages.

The thresholds of signi ficance used to evaluate the Project’s potential impacts under each issue area are summarized directly from the CEQA Environmental Checklist.

5.4.1 AESTHETICS
Threshold a: Would the Project have a substantial adverse effect on a scenic vista? A significant impact would occur if a project were to introduce incompatible scenic elements within a field of view containing a scenic vista or substantially block views of a scenic vista. Viewsheds refer to the visual qualities of the geographical area that is defined by the horizon, topography, and other natural features that give an area its visual boundary and context, or by artificial developments that have become prominent visual components of an area.

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According to the Natural Resources Element of the City’s General Plan, portions of the City of Orange are characterized by scenic vistas that include hillsides, ridgelines, or open space areas that provide a unifying visual backdrop to the urban environment. The Project site is within the western portion of the City, where the topography is relatively flat, and very little open space exists. The Project site does not contain any scenic resources and there are no scenic vistas within proximity to the Site. The Project area is within a highly urbanized industrial area . Implementation of the Project would not have an impact to a scenic vista.

Threshold b: Would the Project substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway?? Under existing conditions, the Project site does not contain any scenic resources such as, rock outcroppings, or historic buildings . The Project site contains street trees at the site’s frontage along Struck Avenue. Implementation of the Project would result in the removal and replacement of street trees. The Project Applicant would be required to obtain a tree removal permit, per OMC Section

12.28.020 (Permit-Required for Removal or Planting).

Based on the California Department of Transportation (Caltrans) List of Eligible and Officially Designated State Scenic Highways, there are no designated or eligible State scenic highways located in proximity to the Project site (Caltrans, 2019). The nearest State designated scenic highway is a 4.2- mile portion of State Route 91 (SR-91) starting at State Route 55 (SR- 55) to the city line of Anaheim located approximately 3.1 miles northeast (Google Earth, 2020). Implementation of the Project would not have the potential to substantially damage scenic resources within a State scenic highway corridor.

No impacts would occur.

As shown in Figure NR- 4, Viewscape Corridors, of the General Plan, the City identifies the visual corridors w ithin the City limits. Figure NR-4 identifies the 4.2 -mile portion of SR- 91, Newport Boulevard from Crawford Canyon Road to Chapman Avenue, and Chapman Avenue to Santiago Canyon Road, a City designated scenic highway (Orange, 2015b). Due to site distance and topography, implementation of the Project would not have the potential to substantially damage scenic resources within City designated scenic corridors. No impacts would occur.

Threshold c: In non-urbanized areas, would the Project substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
The Project site is within an urbanized area of the City. Because the Project is in an urban area, the potential impacts of the Project under this threshold are as sessed based on whether the Project would conflict with applicable zoning and other regulations governing scenic quality. The Project is consistent with the City’s General Plan and zoning designations for the site.

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City of Orange General Plan

Table 5-1, General Plan Consistency Analysis , below discusses t he Project’s consistency with the General Plan goals related to scenic quality.

Table 5-1 General Plan Consistency Analysis
Goals and Policies Project Consistency
Land Use Element
Maximum Intensity

• 1.0 Floor Area Ratio (FAR)

Consistent. The Project site is designated for Light
Industrial uses . The Light Industrial land use
designation allows for a maximum FAR of 1.0. As
shown on the Project’s S ite plans, the Project would
have a maximum FAR of 0.75. Therefore, the Project
would not exceed the maximum permitted FAR.

Height Limit

• 3 Stories

Consistent. The proposed building would be single -
story and constructed up to a height of 45 feet. The
Project would not construct 3 stories and would
therefore not exceed the permitted maximum height
limit identified in the General Plan.

Policy 6.1: Ensure that new development is compatible
with the style and design of established structures and the surrounding environment.

Consistent. The Project would redevelop the Site with
a modern building. The Projec t’s proposed style and
design would be compatible with the surrounding
environment.

Based on the foregoing analysis, the Project would not conflict with the site’s underlying zoning classification or other regulations governing scenic quality. Impacts would be less-than-significant.

City of Orange Municipal Code (OMC)

The Project site is zoned Industrial Manufacturing (M-2) and as such, the Project would be required to comply with the development standards established in OMC Chapter 17.20, Industrial Districts. The intent and purpose of Chapter 17.20 are to encourage industrial facili ties and related uses while recognizing the potential for compatibility between uses through appropriate development and performance standards (Orange, 2021). Chapter 17.20 also intends to promote orderly growth and development through minimal performance standards, sustained property values, protected public safety and health, and further amenities to achieve an environment that is commensurate with prolonged future growth, development, and economic stability. Table 5 -2, Zoning Development Standards Consistency Analysis , addresses the Project’s consistency with applicable development standards outlined in the OMC.

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Table 5-2 Zoning Development Standards Consistency Analysis Applicable Development Standard Project Consistency
Industrial Manufacturing (M-2) Zoning District
Maximum Permitted Building Height

• 45 feet
Consistent. The Project involves the redevelopment of
the Project site with up to a 45 -foot-tall building. The proposed building would not exceed the Z oning
Development Standards ’ height limit of 45 ft.

Accordingly, the Project’s proposed building height
would comply with the City’s permitted height in the
M-2 zone.

Development Setbacks

• Exterior Front, Side, and Rear Yards
o When adjacent to or across from an
alley from a residential zone – 20 feet
o When adjacent to an arterial street – 20
feet
o When adjacent to a local street – 10
feet
• Interior Side and Rear Yards
o When adjacent to a separate parcel – 0
Feet
Consistent. The Project site is located immediately
south of Struck Avenue, a local street. The Project’s
closest setback to Struck Avenue will be approximately
80 feet. The Project site is bordered to the east, south, and west by separate parcels containing existing
development. The Project’s interior side and rear
setbacks will be greater than 0 feet.

Landscaping Requirements

• Promote a comprehensive planning effort in
which all design elements of a project
complement each other and are compatible with
their surroundings. In addition, landscape
design must be suitable for the topography and
coordinated with the preparation of the site
grading plan.

Consistent. The Project would incorporate a Project -
specific landscape plan that is designed to be in
accordance with the City’s Landscape Ordinance. The
Project’s proposed landscaping would include drought
tolerant trees, shrubs, and groundcover . Ornamental
landscaping would be provided along the site’s
northern, eastern, and southern perimeter. Additionally, ornamental trees and shrubs are proposed along the
proposed building’s northern, eastern,
and southern
perimeter.

Screening of Mechanical Equipment

• Shielded from view – All mechanical and air
conditioning equipment shall be shielded and
screened from view from adjacent streets and
properties. The screening shall be
architecturally integrated with the building.

Ground-mounted equipment screening shall
consist of a solid wall, solid fence, or sufficient
landscaping.

Otherwise, such equipment shall
be enclosed in a building.
• Setback Required – Mechanical equipment shall
not be located in required yards or other setback
areas.

Consistent. Roof-mounted mechanical equipment
would be shielded and screened from view from the
neighboring property and Struck Avenue. The
proposed shielding and screening would be integrated
with the building’s design to s eamlessly screen the
mechanical equipment. The Project does not propose
to locate mechanical equipment in yard or setback
areas.

Trash enclosures

Consistent. The proposed trash enclosure for the
Project would screen views on 3 sides with a 6 -foot-
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Applicable Development Standard Project Consistency
• All developments shall be provided with trash
collection areas adequately and conveniently
placed throughout the development . Trash
collection areas shall be screened from view on
3 sides by a 6-foot-high wall. A visually opaque,
self-latching gate shall be provided.
high wall and will provide a visually opaque self -
latching gate to access the trash enclosure.

Undergrounding of Utilities

• Utility lines shall be required to be placed
underground within all commercial or
professional development, planned residential
development, and residential subdivisions.

Consistent. The Project would install new utility lines underground connecting to the existing utility mains
within Struck Avenue.

Threshold d: Would the Project create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
The Project site is currently developed with a manufacturing use (Nursery Supplies, Inc.) and is primarily surrounded by existing industrial development with the exception of Mary’s Kitchen directly to the north. The Project site generates artificial lighting from building-mounted light fixtures . The Project site is within an urbanized area that includes several sources of artificial lighting including interior and exterior building lighting, parking lot lighting, security lighting, and street lighting along Struck Avenue. Other sources of artificial light include vehicle headlights traveling along Struck Avenue.

The Project would introduce new sources of light as necessary for security, safety, and wayfinding.

The Project’s proposed lighting would be similar to existing conditions; therefore, implementation of the Project would not introduce new sources of light that would substantially affect day or nighttime views in the area. Additionally, the Project’s proposed lighting is required to be consistent with OMC Section 17.12.030, Lighting, and Section 17.20.280, Emission of Lighting, Glare, Dust, and Heat, which states that lighting shall be directed, controlled, screened, or shaded in a manner as not to shine directly on surrounding premises (Orange, 2021).

Glare is caused by light reflections from the pavement, vehicles, and building materials such as reflective glass and polished surfaces. During daylight hours, the amount of glare depends on the intensity and direction of sunlight. Glare can create hazards to motorists and can be a nuisance for pedestrians and other viewers. The proposed building is located at the terminus of a cul-de-sac within a buildout area and will be constructed of concrete tilt -up walls . The Project’s proposed building materials would not result in potential glare impacts within the Project site or surrounding areas, and notably at the st reet level. Low-reflective windows would be provided at the proposed office areas .

Implementation of the Project would not introduce new sources of glare that would substantially affect day or nighttime views in the area.

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5.4.2 AGRICULTURE AND FORESTRY RESOURCES
Threshold a: Would the Project convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use?
According to the California Department of Conservation’s (DOC) California Important Farmland Finder, the Project site is classified as “Urban and Built -Up Land” (DOC, 2016b). The “Urban and Built-Up Land” classification describes land that is occupied by structures with a building density of at least 1 unit 10 1.5 acres, or approximately 6 structures to a 10-acre parcel (DOC, 2016b). The nearest Farmland to the Project site is located approximately 0.43 miles north; this land is classified by the DOC as “Unique Farmland,” which describes land that contains lesser quality soils used to produce the State’s leading crops . “Unique Farmland” is usually irrigated, buy may include non-i rrigated orchards or vineyards as found in some climatic zones in California. Due to the S ite’s distance from designated Farmland, the Project would not have the potential to convert the Farmland to non- agricultural use. The Project does not have the potential to convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland) to non-agricultural use. No impacts would occur.

Threshold b: Would the Project conflict with existing zoning for agricultural use, or a Williamson Act contract?
The Project site is zoned as Industrial Manufacturing (M -2) (Orange, 2020). The nearest land zoned for agricultural use is located approximately 4.1 miles northeast of the Project site. As such, the Project does not have t he potential to conflict with existing zoning for agricultural use . No impacts would occur.

The Williamson Act is a Statewide mechanism for the preservation of agricultural land and open space land. The Act provides a comprehensive method for local governments to protect farmland and open space by allowing lands in agricultural use to be placed under contract (agricultural preserve) between local government and landowner. The Project site is not under a Williamson Act contract. Therefore, implementation of the Project does not have the potential to conflict with an existing Williamson Act contract. No impacts would occur.

Threshold c: Would the Project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timbe rland zoned Timberland Production (as defined by Government Code section 51104(g))?
As previously discussed, the Project site is currently zoned as M -2. According to the City’s Zoning Map, there are no lands within the City that are zoned for forest land, timberland, or timberland zoned Timberland Production (Orange, 2020). Therefore, the Project does not have the potential to conflict 534 Struck Avenue Project
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with existing zoning or rezoning of forest land, timberland, or timberland zoned Timberland Production. No impacts would occur.

Threshold d: Would the Project result in the loss of forest land or conversion of forest land to non- forest use?
As discussed under the Agricultural and Forest Resources Threshold c, the Project site is zoned M-2 and there are no lands within the City that are zoned forestland. Additionally, the Project site is developed with a light industrial use. Therefore, the Project would not result in the loss of forest land or conversion of forest land to a non-forest use. No impacts would occur.

Threshold e: Would the involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non -agricultural use or conversion of forest land to non-forest use?
As previously discussed under Agriculture and Forest Resources Threshold a, the Project site is located approximately 0.43-mile southwest of Unique Farmland. Additionally, the Project site is within an urbanized area of the City that contains little open space. Due to the S ite’s distance from the Unique Farmland, the Project does not have the potential to convert Farmland to non-agricultural use. No impacts would occur.

5.4.3 LAND USE AND PLANNING
Threshold a: Would the Project physically divide an established community? The Project site is developed with the Nursery Supplies, Inc. manufacturing facility. Existing industrial development borders the Site to the south and west; the BNSF railroad track borders the S ite to the east; and Struck Avenue and the public facility uses border the site to the north. The Project Applicant would redevelop the Site with another industrial use with associated parking and landscaping improvements. The Project would not have the potential to physically divide an established community. No impacts would occur.

Threshold 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?
Under existing conditions, the Project site is designated for “Light Industrial” land uses by the City of Orange General Plan and “Industrial Manufacturing (M -2)” zone . The Project Applicant would redevelop the Project site in accordance with the underlying land use designations and applicable zoning ordinance development standards. As previously discussed under Aesthetics Threshold c in Table 5-1 and Table 5-2, the Project would not conflict with the General Plan. Although the proposed building would require a CUP for the proposed truck terminal use, the Project would not conflict with the Zoning Code . Because the Project would be consistent with the underlying General Plan designation for the S ite, the Project would not conflict with any applicable goals, objectives, and 534 Struck Avenue Project
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policies of South Coast AQMD’s AQMP and SCAG’s Connect SoCal, which base their assumptions and analyses upon the full build-out of the existing General Plans throughout the region. Refer also to Greenhouse Gas Emissions Threshold b in Section 4.6 of this EIR. No impacts would occur.

5.4.4 MINERAL RESOURCES
Threshold a: Would the Project result in the loss of availability of a known mineral resource that would be of value to the region or the residents of the State? According to Appendix A of the City’s General Plan EIR, the City’s mineral resources are limited to sand and gravel resources (aggregate) along the Santa Ana River and Santiago Creek. The Project site is located within a developed, urbanized area of the City and is located approximately 0.87-mile east of the Santa Ana River and 1.9 miles nort h of the Santiago Creek. As such, no mineral resources are anticipated in the Project area and the implementation of the Project would not result in the loss of availability of a known mineral resource that would be of value to the region and residents of the State.

No impacts would occur.

Threshold 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?
As previously discussed, the Project site is located approximately 0.87-mile east of the Santa Ana River and approximately 2.0 miles north of the Santiago Creek; therefore, the Project does not have the potential to contain any aggregate resources. Additionally, the S ite is not permitted for mining use under the Light Industrial land use designation and Industrial Manufacturing zoning classification.

Because the Project site is not delineated as containing mineral resources on the City’s General Plan, the implementation of the Project does not have the potential to result in the loss of availability of a locally-important mineral resource recovery site. No impacts would occur.

5.4.5 POPULATION AND HOUSING
Threshold 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 Project does not include any residential uses; therefore, the Project does not have the potential to directly induce substantial unplanned population growth. Redevelopment of the Project site has the potential to generate 60 to 130 new jobs . According to the California Employment Development Department (EDD), as of April 2020, the City of Orange has a labor force of 67,200 persons and of that labor force, 8,300 are unemployed (unemployment rate of 12.4 percent) (EDD, 2020). According to SCAG’s 2020-2045 Jurisdiction – Level Growth Forecast, the City of Orange is anticipated to employ approximately 131,300 persons (SCAG, 2020a). Project employment is well within the growth forecasts of the City and implementation of the Project would further balance the City’s employment- to-population ratio. Therefore, the Project’s proposed employees are not likely to relocate to the City, 534 Struck Avenue Project
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rather, the new jobs associated with the Project would provide employment opportunities for individuals already residing in the City.

The Project involves redevelopment of the site with a permitted use within the Light Industrial land use designation and M -2 zoning classification. Accordingly, the Project would not result in growth that was not already anticipated by the City of Orange General Plan and General Plan EIR. Further, the Project site is already developed and contains existing infrastructure that serves the site’s existing use. The Project would improve Struck Avenue along the site’s frontage and connect to the existing utility connections . In doing so, the Project would be in conformance with the General Plan and applicable infrastructure master plans . Therefore, the Project would not induce substantial indirect population growth in the area.

Based on the foregoing analysis, the Project is not anticipated to induce substantial unplanned population growth in the area. Impacts would be less-than-significant.

Threshold b: Would the Project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere? The Project site is developed with an approximate 40,000 sf manufacturing facility and does not contain any residential structures . Implementation of the Project would not displace any housing or people and no replacement housing would be required. No impacts would occur.

5.4.6 PUBLIC SERVICES
Threshold a: Would the Project result in substantial adverse physical impacts associated with the provision of or the need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
i) Fire Protection?
ii) Police Protection?
iii) Schools?
iv) Parks?
v) Other Public Facilities?

i) Fire Protection?

The Orange City Fire Department (OCFD) provides fire and emergency response to the City, including the Project site. According to the City General Plan EIR, the OCFD operates 8 fire stations within the City. OCFD Station No. 5, located at 1345 Maple Street , is the closest fire station to the Project site (located approximately 1.1 miles southwest). According to the OCFD, the average response time in 2019 was 3 minutes and 52 seconds (Stefano, 2020).
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Environmental Impact Report 5.0 Other CEQA Considerations Lead Agency: City of Orange SCH No. 2021090399

As previously discussed, the Project Applicant proposes to demolish the existing on-site structure and redevelop the Site with a building up to 57,900 sf in addition to a maintenance building. Because fire protection services are currently provided to the surrounding area, and based on the S ite’s close proximity to an existing fire station, the City’s existing fire protection facilities would adequately serve the Project. The Project is not anticipated to result in the construction of new or physically altered fire facilities. The Pro ject would be required by the OMC Chapter 15.38, Fire Protection Facilities Program¸ to pay a fire protection facilities fee to aid in offsetting the increased demand for fire services created by non-residential development. This fee is due prior to the issuance of a building permit.

The Project’s proposed building would feature fire safety and suppression design, including the type of building construction, fire sprinklers, a fire hydrant system, and paved access. The proposed building would be a concrete tilt-up construction that contains a low fire hazard risk rating. Additionally, a fire alarm system is proposed to be installed, as well as an Early Suppression, Fast Response (ESFR) ceiling-mounted fire sprinklers. ESFR provides protection that exceeds that of in-rack systems. ESFR high output, high-volume systems are in ceiling spaces as with conventional fire sprinkler systems, but they incorporate large, high-volume, high-pressure heads to provide the necessary fire protection for buildings that may contain high-piled storage. While most other sprinklers are intended to control the growth of a fire, an ESFR sprinkler system is designed to suppress a fire, which knocks the fire down to its source.

Based on the foregoing, the Project would receive adequate fire protection services and would not result in the need for new or physically altered fire protection facilities. Impacts would be less -than- significant.

ii) Police Protection?

The City of Orange Police Department provides law enforcement services to the City, including the Project site. The Orange Police Department is located at 1107 N. Batavia Street, which is located approximately 406 feet northwest of the Project site . Implementation of the Project is anticipated to result in similar service calls (typical of an industrial facility) as the existing manufacturing use.

According to the General Plan Public Safety Element, to maintain the City’s ability to serve current residents and businesses, applicants are required to provide for adequate services and equipment to serve businesses of new developments. Land uses will be evaluated and modified, if necessary, to facilitate access to emergency services, meet service standards, and ensure land use compatibility.

Therefore, it is anticipated that emergency response would occur with acceptable response times.

According to OMC Chapter 3.13, Police Facility Development Fee, the Project Applicant would be required to pay fair share fees to help finance police facilities required by new development to avoid adversely impacting existing police protection facilities. Additionally, the Project plans would be reviewed and approved by the City of Orange Building and Police Departments, whi ch would ensure that adequate safety and crime prevention measures are provided within the Project’s design. 534 Struck Avenue Project
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Therefore, implementation of the Project is not anticipated to result in the new or physically altered police protection facilities. Impacts would be less-than-significant.

iii) Schools?

The City provides school services through the Orange Unified School District. The Project Applicant proposes to demolish the existing manufacturing facility and redevelop the site with a single building.

Implementation of the Project does not have the potential to result in substantial direct growth in the population, nor an increase in student population. The Project would be required to pay appropriate school fees applicable to all new development in accordance with Assembly Bill (AB) 2926 and Senate Bill (SB) 50 to offset potential impacts on school services. No impact would occur.

iv) Parks?

According to the General Plan Natural Resources Element, the City owns and has developed 22 parks (Orange, 2015b). The City provides approximately 1.81 acres of parkland per 1,000 persons. The City anticipates developing approximately 43.5 acres of planned future parks; the nearest park to the Project site is Killefer Park located approximately 0.39-mile southeast. The proposed Project would not introduce new residents to the City necessitating the need for additional parks. No impact would occur.

v) Other public facilities?

Other public facilities include public libraries. The City’s public libraries operate according to the Public Library Facilities Master Plan (2002-2020). This master plan outlines current and projected future demand based on the City’s General Plan buildout; it is intended to ensure tha t the California State Library’s recommended standard of 4 volumes and 0.7 square foot per capita is maintained and that the City’s library service needs are met as future development occurs. The nearest library to the Project site is Charles P. Taft Library, located approximately 1.0-mile northeast. The proposed Project would not introduce new residents to the City necessitating the need for additional libraries or demand for library services. No impact would occur.

5.4.7 RECREATION
Threshold 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?
As previously stated, the City has owned and developed 22 parks and approximately 15 miles of equestrian, biking, and recreational trails. Parks and open space make up 31.8 present of land use in the City (Orange, 2010a). The Project Applicant does not propose to construct any residential uses on the Project site. Therefore, the Project would not create a substantial population increase that would increase the use of existing neighborhood and regional parks or other recreational facilities, resulting in physical deterioration of park facilities. No impact would occur. 534 Struck Avenue Project
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Threshold b: Would the Project include recreational facilities or require the construction or expansion of recreational facilities which might have an adve rse physical effect on the environment?
The Project does not include recreational facilities or require the construction or expansion of recreational facilities. Implementation of the Project would not result in any adverse physical effects on the environment due to the construction of recreational facilities. No impact would occur.

5.4.8 UTILITIES AND SERVICE SYSTEMS
Threshold a: Would the Project require or result in the relocation or construction of new or expanded water, wastewater treatment or storm wate r drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
Water and Wastewater Treatment

The City of Orange Water Division provides potable water servi ce (water supplies include imported water, groundwater, and surface water) to over 139,000 residents within the City’s 32 square -mile planning area. The Orange County Sanitation District (OCSD) provides wastewater services to the City. Under existing condi tions, the Project site is developed with a manufacturing facility.

Implementation of the Project would demolish the existing approximately 40,000 sf manufacturing facility and redevelop the Site with an approximately 57,900 sf building in addition to a maintenance building. The Project would connect a new 3-inch water line, 3-inch fire line and 6-inch sewer lines to the existing 10-inch water line and 8-inch sewer line beneath Struck Avenue. Because the Project Applicant proposes to redevelop the Site with a permitted use under the Light Industrial land use designation and M-2 Zone Classification, the water demand from the Project site was anticipated and analyzed in the City’s Urban Water Management Plan (UWMP). Therefore, the City’s existing water infrastructure and treatment facilities are adequate to serve the Project. OMC Section 13.56.090, Charges for Sewer Mains and Extensions , imposes a sewer main connection fee on non- residential development in the City as a condition precedent to the issuance of a building permits to fund the Project’s fair share of costs to upgrade the City’s sewer system . Additionally, the Project would be required to pay ongoing user fees. Payment of these fees would offset the Project’s potential increase in demand for wastewater collection services.

Although the Project would result in new water and sewer line connecti ons, these connections would occur on-site and would be part of the Project’s construction phase, which is evaluated throughout this EIR. The construction of the Project’s water and sewer lines necessary to serve the Project would not result in any significant physical effects on the environment that are not already identified and disclosed as part of this EIR. Impacts would be less-than-significant.

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Stormwater Drainage

Stormwater originating on the Project site sheet flows from the south to the northwest to an existing curb gutter along Struck Avenue . Runoff from the Project site enters the existing 30-inch storm drainage main beneath Struck Avenue, which then conveys flows to the Orange County storm drain system that discharges runoff to the Santa Ana River.

Refer to the analysis under Section 4.8, Hydrology and Water Quality, Threshold c.ii, of this EIR. As discussed, stormwater runoff would be treated on-site and would not require relocation or construction of new or expanded storm water drainage infrastructure which could cause significant environmental effects. Impacts would be less-than-significant.

Dry Utilities

Under existing conditions, the Project site is served by Southern California Edison (SCE) for electrical power, Southern California Gas Company (SoCal Gas) for natural gas, and AT&T for telephone and fiber optics. Connections to the existing utility networks are available in the Project area and any off- site improvements would occur within improved rights -of-way, which are inherent to the Project’s construction phase and have been evaluated throughout this EIR . Where necessary, mitigation measures have been identified to reduce impacts to a level below significance. Because the Project site has been previously developed with a manufacturing facility that requires electric power, natural gas, and telecommunication services, implementation of the proposed Project is not anticipated to limit the ability of SCE, SoCalGas, or AT&T to provide service to Project. Therefore, the proposed Project would not require or result in the construction or expansion of new facilities, and impacts would be less-than-significant.

Threshold b: Would the Project have su fficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years?
The City of Orange provides water service to the City. Under existing conditions, the City of Orange provides wa ter services to the Project site . The City receives its water from 2 main sources:
groundwater from the Lower Santa Ana River Groundwater Basin, managed by the Orange County Water District (OCWD), and imported water from the MWD, managed by the Municipal Water District of Orange County. Groundwater is pumped from 15 active wells in the City. According to the City’s Urban Water Management Plan (UWMP), the City relies on approximately 6,515 acre -feet per year (AFY) of imported water and 20,372 AFY of groundw ater form the Lower Santa Ana River Groundwater Basin. Additionally, the City relied on 1,757 acre -feet of surface water purchased through the Serrano Water District in 2015.

The City’s UWMP includes an analysis of water supply reliability projected through 2040 under normal years, single dry year, and multiple dry years. The City’s total water demand for 2015 was 534 Struck Avenue Project
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approximately 28,643 AF. The City’s forecasts for projected water demand based on the population projections of the Southern California Associ ations of Governments (SCAG), which rely on the adopted land use designations contained within the general plans that cover the geographic area within City of Orange’s service. Because the Project Applicant would redevelop the site with a use permitted under the Light Industrial land use designation, the Project would be consistent with the City’s General Plan and, therefore, the water demand associated with the Project was considered in the demand anticipated by the 2015 UWMP and analyzed therein. As stated above, the City is anticipated to have adequate water supplies to meet all its demands until the year 2040 under a normal year, single dry year, and multiple dry years. Therefore, the City has sufficient water supplies available to serve the Project from existing entitlements/resources and no new or expanded entitlements are needed. Impacts would be less-than-significant.

Threshold 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? The OCSD provides wastewater treatment for the City of Orange via 2 reclamation plants: Reclamation Plant No.1 in Fountain Valley and Treatment Plant No. 2 in Huntington Beach. Reclamation Plant No. 1 has a total rated primary capacity of 108 million gallons per day (mgd) and a secondary treatment capacity of 80 mgd. Treatment Plant No. 2 has a total rated primary capacity of 168 mgd and a secondary treatment capacity of 90 mgd (Carollo, 2020). According to the City’s General Plan EIR, the City’s Sewer Master Plan estimated a wastewater generation rate of 23.7 mgd in the City, which includes wastewater flow from industrial, commercial, and residential land uses.

The Project site is developed with an approximately 40,000 sf manufacturing facility that requires wastewater treatment services. The Project Applicant would demolish the existing structure and redevelop the Site with an approximately 57,900 sf building in addition to a maintenance building.

The Project Applicant would redevelop the Project site with a use that is consistent with the S ite’s underlying land use designation; therefore, the wastewater generation associated with the Project was considered in the demand anticipated by the City’s General Plan EIR and the City’s Sewer Master Plan and analyzed therein. As such, the OCSD’s existing wastewater treatment facilities are anticipated to have adequate capacity to serve the Project’s project demand in addition to its existing commitments.

Impacts would be less-than-significant.

Threshold 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 City of Orange contracts with a private service provider to collect solid waste, green waste (grass clippings, tree, and shrub clippings), and items for recycling. Waste collected from the City is disposed of at 1 of 3 landfills in Orange County: Olinda Alpha Landfill, Frank R. Bowerman Landfill, and the Pima Deshecha Landfill. The Orange County Integrated Waste Management Department (OCIWMD) owns and operates these landfills.
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According to the California Department of Resources Recycling and Recovery (CalRecycle), the Olinda Alpha Landfill is permitted to accept 8,000 tons per day (tpd), the Frank R. Bowerman Landfill is permitted to accept 11,500 tpd, and the P rima Deshecha Landfill is permitted to accept 4,000 tpd.

Additionally, the Olinda Alpha Landfill has a closure date of December 21, 2021; the Frank R.

Bowerman Landfill has a closure date of December 31, 2053; and the Pima Deshecha Landfill has a closure date of December 31, 2102. (CalRecycle, 2020a; CalRecycle, 2020b; CalRecycle, 2020c) It should be noted that the Project is anticipated to be constructed by the year 2022 and by this time, the Olinda Alpha Landfill is expected to be closed.

Implementation of the Project would generate an incremental increase in solid waste volumes requiring off-site disposal during short-term construction and long-term operational activities. Additionally, the Project would be required to comply with mandatory waste reduction requirements as described below in Utilities and Service Systems Threshold g.

Construction Impact Analysis

Solid waste requiring disposal would be generated by the construction process, primarily consisting of discarded demolition materials and packaging. The Project would reuse 10,905 tons of crushed concrete and asphalt.

Based on the size of the Project (63,300 sf) and the United States Environmental Protection Agency’s (US EPA) construction waste generation factor of 4.34 pounds per sf (lbs/sf) for non-residential uses, approximately 137.4 tons of waste is calculated to be generated during the Project’s construction phase ([63,300 sf x 4.34 lbs/sf]/2,000 lbs/ton = 137.4 tons) (EPA, 2009, p. 10). California Assembly Bill 939 (AB 939) requires that a minimum of 50% of all solid waste be diverted from landfills (by recycling, reusing, and other waste reduction strategies); therefore, the Project is estimated to generate approximately 68.7 tons during its construction phase. The Project’s construction phase is anticipated to last for approximately 220 days; therefore, the Project is calculated to generate approximately 0.31 tons of solid waste per day requiring landfill during its construction phase.

The Project’s non-recyclable construction waste generated by the Project would be disposed of at 1 of the 3 landfills as described above . The Project’s estimated total construction solid waste would represent approximately 0.9 percent of the daily tpd at Olinda Alpha Landfill, 0.6 percent at the Frank R. Bowerman Landfill, and 1.7 percent at the Prima Deshecha Landfill. As previously stated, the Olinda Alpha Landfill has a closure date of December 31, 2021, and the Project’s construction is anticipated to be completed by 2022. Although the Olinda Alpha Landfill will be closed during a portion of the Project’s construction phase, the Frank R. Bowerman and Pima Deshecha Landfill will be open during the Project’s entire construction phase. These 2 landfills have sufficient daily capacity to accept solid waste generated by the Project’s construction phase. Impacts would be less -than- significant.

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Operational Impact Analysis

Based on a daily waste generation factor of 1.42 lbs of waste per 100 sf of industrial building obtained from CalRecycle, long-term, on-going operation of the Project would generate up to approximately

0.45 tons ([63,300 sf x {1.42 lbs/100sf}]/2,000 lbs/ton= 0.45 tons) of solid waste per day (CalRecycle, 2006). Implementation of the Project would result in an approximately 0.45-ton net daily increase in solid waste generation. It should be noted that by the time the Project is operational, the Olinda Alpha Landfill will be closed; however, the Frank R. Bowerman Landfill and Prima Deshecha Landfill are anticipated to be open during the lifetime of the Project. Although the implementation of the Project would increase the amount of solid wa ste generated at the Project site, the Project’s projected solid waste would be below the Frank R. Bowerman and Prima Deshecha Landfill daily disposal volume.

Additionally, according to AB 939, at least 50 percent of the Project’s solid waste is required to be diverted from landfills; therefore, the Project would generate approximately 0.23 tons of solid waste per day requiring landfilling (0.45 tons per day x 50% = 0.23 tons per day).

The non-recyclable solid waste generated during the long-term operatio n of the Project would be disposed at 1 of the 2 landfills described above. The Project’s estimated solid waste is well below the maximum daily capacities of any of the 2 landfills. The Project is not anticipated to cause these landfills to exceed their maximum daily permitted solid waste amounts. Impacts would be less-than-significant.

Threshold e: Would the Project comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
AB 939 requires that local jurisdictions divert at least 50 percent of all solid waste generated by January 1, 2000. SB 2202 clarified that local governments shall continue to diver 50 percent of all solid waste on and after January 1, 2000. SB 1016 introduced a per capita di sposal measurement system that measures the 50 percent diversion requirement using a disposal measurement equivalent. For the 2017 reporting year, the City’s per employee disposal rate was 7.10 lbs/person/day, which is less than the City’s Disposal Rate Target of 14.4 lbs/person/day.

Additionally, in accordance with the California Solid Waste Reuse and Recycling Act of 1991 (Cal Pub Res. Code Section 42911), the Project is required to provide adequate areas for collecting and loading recyclable materials w here solid waste is collected. The collection areas are required to be shown on construction drawings and be in place before occupancy permits are issued. Additionally, in compliance with AB 341 (Mandatory Commercial Recycling Program), the future occu pant of the Project would be required to arrange for recycling services, if the occupant generates four (4) or more cubic yards of solid waste per week. The implementation of these mandatory requirements would reduce the amount of solid waste generated by the Project and diverted to landfills, which in turn will aid in the extension of the life of affected disposal sites. The Project would be required to comply with all applicable solid waste statutes and regulations. Impacts would be less-than-significant.

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Environmental Impact Report 5.0 Other CEQA Considerations Lead Agency: City of Orange SCH No. 2021090399

5.4.9 WILDFIRE
If located in or near state responsibility areas or lands classified as very high fire hazard severity zones:

Threshold a: Would the Project substantially impair an adopted emergency response plan or emergency evacuation plan?
Threshold b: Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, would the Project thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
Threshold c: 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?
Threshold d: 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 State Responsibility Area (SRA) is the land where the State of California is financially responsible for the preservation and suppression of wildfires . The SRA does not include lands within city boundaries or in federal ownership; therefore, the Project site does not have the potential to be in an SRA. Based on the review of Figure PS -1, Environmental and Natural Hazard Policy Map, of the City’s General Plan Public Safety Element, the Project site is not within a Very High Fire Hazard Severity Zone (VHFHSZ) (Orange, 2010b). Additionally, according to CalFire, the Project site is not within a VHFHSZ (CalFire, 2011). As such, no impacts related to wildfire would occur.

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6.0 ALTERNATIVES TO THE PROJECT

6.1 INTRODUCTION
An Environmental Impact Report (EIR) must identify ways to mitigate or avoid the significant effects that a project may have on the environment. In compliance with Section 15126.6(a) of the California Environmental Quality Act (CEQA) Guidelines, an EIR mus t “describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any significant effects of the project, and evaluate the comparative merits of the alternatives”. This section identifies potential alternatives to the Project and evaluates them, as required by CEQA.

Key provisions of the State CEQA Guidelines on alternatives (Section 15126.6[b] – 15126.6[f]) are provided below to explain the foundation and requirements for the alternatives analysis in the EIR.

• The discussion of alternatives shall focus on alternatives to the project or its location which are capable of avoiding or substantially lessening any significant effects of the project, even if these alternatives would impede to some degree the attainment of the project objective, or would be more costly (Section 15126.6[b]).
• The specific alternative of ‘no project’ shall also be evaluated along with its impa ct (Section 15126.6[e][1]).
• The “no project” analysis shall discuss the existing conditions at the time the Notice of Preparation is published, and at the time the environmental analysis is commenced, as well as what would reasonably be expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services. If the environmentally superior alternative is the “no project” alternative, the EIR shall also identify an environmentally superior alternative among the other alternatives (Section 15126.6[e][2]).
• The range of alternatives required in an EIR is governed by the “rule of reason” that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice. The alternatives shall be limited to ones that would avoid or substantially lessen any of the significant effects of the project. Of those alternatives, the EIR need examine in detail only the ones that the lead agency determines could fe asibly attain most of the basic objectives of the project. The range of feasible alternatives shall be selected and discussed in a manner to foster meaningful public participation and informed decision making. Among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries, and whether the proponent can reasonabl y acquire, control or otherwise have access to the alternative site (or the site is already owned by the proponent) (Section 15126.6[f]).
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• For alternative locations, “only locations that would avoid or substantially lessen any of the significant effects of the project need be considered for inclusion in the EIR” (Section 15126.6[f][2][A]).
• If the lead agency concludes that no feasible alternative locations exist, it must disclose the reasons for this conclusion, and should include the reasons in the EIR. For example, in some cases there may be no feasible alternative locations for a geothermal plant or mining project which must be in close proximity to natural resources at a given location (Section 15126.6[f][2][B]).
• An EIR need not consider an alternative whose effect cannot be reasonably ascertained and whose implementation is remote and speculative (Section 15126.6[f][3]).

6.2 PROJECT OBJECTIVES
As stated in Section 3.0 of this EIR, and pursuant to Section 15124 of the CEQA Guidelines, the objectives that have been established for the Project are listed below.

1. Create a professional, well -maintained and attractive environment for the development of a truck terminal consistent with the underlying zoning adjacent to nearby transportation infrastructure such as the SR-57 and I-5.

2. Provide the entitlements and framework for the development of a truck terminal with warehouse and office spaces that are responsive to local and regional trade demands.

3. Provide development that will enhance the City’s economic well -being and employment opportunities for community residents.

4. Develop the site with a use that has architectural design and operational characteristics that are compatible with other existing and planned development in the local area.

5. Provide a fully secured premise with active management to strengthen the security and safety for the local area.

6. Redevelop the Project site with a new modern building that meet current California Building Code and California Green Building Code Standards with increased energy efficiency with existing available infrastructure.

6.3 SUMMARY OF SIGNIFICANT AND UNAVOIDABLE IMPACTS
As demonstrated in Section 4.0 of this EIR, implementation of the Project would not result in significant adverse environmental effects that cannot be mitigated to below a level of significance after the implementation of Project design features, mandatory regulatory requirements, and feasible mitigation measures.
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It should be noted that although the Project would not result in any significant and unavoidable impacts, Project-level mitigation measure s are required to reduce potentially significant impacts to levels considered less than significant for the following topical issues: Biological Resources (due to the potential to impact nesting migratory birds protected by the MBTA and California Fish and Game Code); Cultural Resources (due to the potential to encounter buried archaeological resources); Geology and Soils (due to the potential to encounter buried paleontological resources); Hazards and Hazardous Materials (due to the potential to uncover contaminated soils); and Tribal Cultural Resources (due to the potential to encounter buried tribal cultural resources) . These potentially significant impacts are associated with construction activities, not operation of the Project.

6.4 ALTERNATIVES CONSIDERED BUT NOT CARRIED FORWARD FOR DETAILED ANALYSIS An EIR is required to identify any alternatives that were considered by the Lead Agency but were rejected as infeasible. Among the factors described by CEQA Guidelines Section 15126.6 in determining whether to exclude alternatives from detailed consideration in the EIR are: a) failure to meet most of the basic project objectives, b) infeasibility, or c) inability to avoid significant environmental impacts. With respect to the feasibility of potential alternatives to the Project, CEQA Guidelines Section 15126.6(f)(1) notes:

“Among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability , availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries…and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site…”

In determining an appropriate range of alternatives to be evaluated in this EIR, a number of possible alternatives were initially considered and, for a variety of reasons, rejected. Alternatives were rejected because either: 1) they could not accomplish the basic objectives of the Project, 2) they would not have resulted in a reduction of significant adverse environmental impacts, or 3) they were considered infeasible to construct or operate. A summary of the alternatives that were considered but rejected are described below.

6.4.1 ALTERNATIVE SITE
CEQA requires that the discussion of alternatives focus on alternatives to the Project or its location that are capable of avoiding or substantially lessening any significant effects of the Project. The key question and first step in the analysis is determining whether any of the significant effects of the project would be avoided or substantially lessened by developing the project at another location. Only locations that would avoid or substantially lessen any of the significant effects of the project need be considered for inclusion in the EIR (CEQA Guidelines Section 15126.6(f)(2)).

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To meet the Project Objectives and implement the Project, the Alternative Site for consideration in this analysis could include other parcels within the Light Industrial land use areas where the City of Orange anticipates future industrial development. For this alternative, any development within these areas would need to be consistent with the Project, the Project O bjectives, and development anticipated in the area, as presented in City of Orange General Plan and zoning. Implementing the Project on a different parcel would require acquisition of developed property, demolition of existing operational structures, and discontinuing existing land uses, which is likely to disrupt existing businesses and operations, and would result in environmental impacts similar to those identified for the Project.

The Pr oject’s potentially significant impacts – all of which are related to aspects of the Project’s construction and would be reduced to less than significant levels with the application of mitigation measures identified in this EIR – are also likely to occur at other sites in the City. Development at an Alternative Site would only move Project impacts to a different location . Additionally, the Project- related increase in truck and vehicular trips and the associated air pollutant emissions, off-site increases in traffic-related noise, and GHG emissions, which would be less than significant with the Project, would also occur with development at an alternative site.

It would not be feasible for the owner to control or otherwise have access to another site of a sim ilar size to the Project site. CEQA does not require the consideration of infeasible sites that are not owned by the landowner or that could not be reasonably acquired by the landowner to be analyzed as alternatives to the Project (State CEQA Guidelines, Section 15126.6[f][1]).

6.4.2 ALTERNATIVE DEVELOPMENT PROJECT ON-SITE
It is typical to consider alternative development scenarios for a Project (reduced intensity, reduced development area, alternative site plan, alternative use, etc.) when identifying potential alternatives to avoid or reduce potential significant impacts resulting from construction or operation of a project to a less than significant level. As previously identified, and as demonstrated through the analysis presented in Section 4.0 of this EIR, the Project would not result in any significant and unavoidable impacts. The Project’s potential impacts are less than significant with incorporation of the Project-level mitigation measures in this EIR.

Implementation of an alternative development scen ario at the Project s ite that could potentially meet the established Project Objectives would require the removal of the existing building, site preparation, grading/excavation, and building construction. All impacts that require Project-level mitigation are associated with construction activities, not operation, and would therefore also occur under a potential alternative development scenario onsite. For that reason, there is no need to further evaluate alternative development scenarios.

6.4.3 ALTERNATIVE LAND USE
An Alternative Land Use was considered in response to public comment received during the scoping meeting requesting an alternative that considered dev elopment of the site with smaller buildings for 534 Struck Avenue
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small businesses. To accommodate this request, the Alternative Land Use assumes the development of a total of 60,000 sf of business park uses within a single building or multiple buildings with multiple small business tenants. The ITE Trip Generation Manual includes trip ge neration rates for Business Park (ITE Land Use Code 770). This rate includes business park uses that consists of a group of flex- type or incubator one- or two-story buildings served by a common roadway system. Tenants may be start-up companies or small mature companies that require a variety of space. The space may include offices, retail and wholesale stores, restaurants, recreational areas and warehousing, manufacturing, light industrial, or scientific research functions. Based on 60,000 sf of business pa rk uses, this alternative would generate 81 AM peak hour, 73 PM peak hour, and 746 average daily trips.

Because t his alternative would involve redevelopment of the site, impacts related to biological resources, cultural resources, paleontological resources, hazardous materials, and tribal cultural resources would remain the same as the Project . Mitigation measures are required to reduce these potentially significant impacts to a level of less than significant. Under this alternative, the projected trips would increase from 396 to 746 average daily trips, resulting in an increase in impacts related to air quality, energy, GHG emissions, and off-site traffic related noise impacts. Because this alternative would increase environmental impacts and would not reduce any of the Project’s significant impacts, this alternative was rejected from further evaluation.

6.5 ALTERNATIVES ANALYSIS
When considering potential alternatives to the Project, the City focused on alternatives that are required by CEQA or that would a void or reduce the potentially significant impacts. As discussed previously, because the Project’s potentially significant impacts, prior to mitigation, are related to construction, alternatives that would avoid these impacts are : 1) a no project/no development alternative and 2) an alternative that considers retention and reuse of the existing building.

Section 15126.6(e) of the State CEQA Guidelines requires than an EIR evaluate a “no project” alternative to allow decision makers to compare the impacts of approving a project with the impacts of not approving that project. Section 15126.6(e)(3) of the State CEQA Guidelines describes the two general types of no project alternatives: (1) when the project is the revision of an existing land use or regulatory plan, policy, or ongoing operation, the no project alternative would be the continuation of that plan ; and (2) when the project is other than a land use/regulatory plan (such as a specific development on an identifiable property), the no project alternative is the circumstance under which the project does not proceed. Both no project alternatives have been evaluated herein.

For the alternatives evaluated below, it is assumed that relevant regulatory requirements and Project - specific mitigation measures would also be implemented and thus serve to reduce or avoid potential significant impacts similar to the Project.

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6.5.1 NO PROJECT/NO DEVELOPMENT ALTERNATIVE
The No Project/No Development Alternative considers no development on the Project site beyond what occurs on the site under existing conditions (as described in EIR Section 3.0). As such, the Project site would remain with an existing vacated 40,000 square foot concrete tilt-up manufacturing building.

Under this alternative, no future operations or improvements would be made to the Project site and none of the Project’s parking, utility, and infrastructure improvements would occur.

A. Comparative Analysis of Environmental Impacts
The focus of this analysis is to determine if the No Project/No Development Alternative is capable of eliminating or reducing the potentially significant environmental effects of the Project. The No Project/No Development Alternative would leave the site vacant with the existing manufacturing building and associated parking, therefore, no environmental impacts would occur. This alternative would eliminate the Project’s construction-related impacts to biological resources, cultural resources, paleontological resources, and tribal cultural resources.

B. Conclusion
The No Project/No Development Alternative would result in no physical environmental impacts to the Project site. However, this alternative would fail to meet all of the Project’s objectives, as described in Subsection 6.2.

6.5.2 NO PROJECT/EXISTING ZONING ALTERNATIVE
The No Project/Existing Zoning Alternative considers redevelopment of the Project site with a warehouse building that would be allowed under the existing M-2 zoning. Under this alternative, the site would be redeveloped with a 201,520 square foot warehouse buildi ng which represents continuation of development consistent with the existing community development type and zoning designations.

A. Comparative Analysis of Environmental Impacts
The focus of this analysis is to determine if the No Project/Existing Zoning Alternative is capable of eliminating or reducing the potentially significant environmental effects of the Project. Because this alternative would result in redevelopment of the Project site, it would result in the same construction- related impacts to biological resources, cultural resources, paleontological resources, hazardous materials, and tribal cultural resources as the Project.

B. Conclusion
Avoid or Substantially Lessen the Significant Impacts of the Project

As presented in Section 4.0 of this EIR, all potentially significant impacts of the Project can be mitigated to less than significant and no significant and unavoidable impacts would occur. Project - 534 Struck Avenue
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level mitigation measures are required to reduce potentially significant i mpacts to levels considered less than significant for inadvertent discovery of archaeological, paleontological, or tribal cultural resources. In addition, Project-level mitigation measures are required to reduce potentially significant impacts to levels considered less than significant for biological resources (potential to impact nesting migratory birds protected by the MBTA and California Fish and Game Code) and hazardous materials (potential contaminated soils). The No Project/Existing Zoning Alternative would not avoid or substantially lessen any of the Project’s significant impacts.

Attainment of Project Objectives

The No Project/Existing Zoning Alternative would involve redevelopment of the site with a 201,520 square foot warehouse building. This alternative would not fully meet Project Objectives 1 (Create a professional, well -maintained and attractive environment for the development of a truck terminal consistent with the underlying zoning adjacent to nearby transportation infrastructure such as the SR- 57 and I-5) and 2 (Provide the entitlements and framework for the development of a truck terminal with warehouse and office spaces that are responsive to local and regional trade demands) because the site would not be developed with a truck terminal use. The remaining Project Objectives 3–6 as listed under Subsection 6.2, would be attained with this alternative.

6.5.3 REUSE ALTERNATIVE
The Reuse Alternative addressed in this section assumes the Project does not proceed and the existing 40,000 square-foot concrete tilt-up manufacturing building and parking lot would remain and be reused by a future tenant. Until the end of 2020, the Project site was occupied by Nursery Supplies, Inc., a manufacturer of plastic nursery planting pots. Under the Reuse Alternative, the existing building and associated facilities on-site would be retained and reoccupied for use with a similar manufacturing use that is consistent with that allowed by-right pursuant to the M-2 zone. The M-2 zone intends to provide the continuation and development of heavy manufacturing industries in a location where they are compatible with and will not adversely impact adjacent land uses.

A. Comparative Analysis of Environmental Impacts
The focus of this analysis is to determine if the Reuse Alternative is capable of eliminating or reducing the potentially significant environmental effects of the Project. As previously noted, the Project would not result in any significant and unavoidable impacts; therefore, the analysis addresses significant effects that might occur if the identified Project-level mitigation measures are not applied.

With respect to archaeological, paleontological, and tribal cultural resources, the Reuse Alternative would not involve any excavation or grading activities. Therefore, the potential to discover previously unidentified archaeological, paleontological, and tribal cultural resources is eliminated. Reuse of the existing building would not require removal of trees on site. As such, the potential for impacts t o biological resources under the Reuse Alternative would be less than with the Project. However, the Reuse Alternative would not result in remediation of the site in the event that unknown contaminated 534 Struck Avenue
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soils are present. Additionally, this alternative would result in increased operational energy demand and GHG emissions compared to the Project, because it would not redevelop the Project site with a new modern building that meets current California Building Code and California Green Building Code Standards with increased energy efficiency with existing available infrastructure.

The Project would not result in any significant impacts before mitigation for any other topical issues and therefore do not need to be assessed under the Reuse Alternative.

B. Conclusions
Avoid or Substantially Lessen the Significant Impacts of the Project

As presented in Sections 4.0 of this EIR, the Project would not result in any significant and unavoidable impacts; therefore, the Reuse Alternative would not avoid or substantially lessen a significant and unavoidable impact. However, Project -level mitigation measures are required to reduce potentially significant impacts to levels considered less than significant for inadvertent discovery of archaeological, paleontological, or tribal cultural resources . In addition, Project -level mitigation measures are required to reduce potentially significant impacts to levels considered less than significant for biological resources (potential to impact nesting migratory birds protected by the MBTA and California Fish and Game Code) and hazardous materials (potential discovery of contaminated soils).

These potentially significant impacts are associated with construction activities, not operation of the Project. As described above, the Reuse Alternative would eliminate these impacts and mitigation measures would not be required, because no grading would occur. However, as noted above, the Reuse Alternative would not result in remediation of the site in the event that unknown contaminated soils are present. Additionally, this alternative would result in increased operational energy demand and GHG emissions compared to the Project, because it would not redevelop the Project site with a new modern building that meet s current California Building Code and California Green Building Code Standards with increased energy efficiency with existing available infrastructure.

Attainment of Project Objectives

The discussion below addresses the ability of the Reuse Alternative to attain the project objectives.

1. Create a professional, well-maintained and attractive environment for the development of a truck terminal consistent with the underlying zoning adjacent to nearby transportation infrastructure such as the SR-57 and I-5. The Reuse Alternative would not involve the redevelopment of the Project site with a truck terminal, rather it would involve the continued use or reuse of the existing building and facilities at the Project site for manufacturing use. Therefore, the Reuse Alternative does not meet the overa ll intent of this Project objective and redevelopment of the Project site is necessary to accomplish this objective.

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2. Provide the entitlements and framework for the development of a truck terminal with warehouse and office spaces that are responsive to local and regional trade demands. The Reuse Alternative would not include entitlements for redevelopment responsive to local and regional trade demands. Additionally, the existing outdated and underutilized building would not have the ability to attract a hig h-quality tenant responsive to local and regional trade demands. The Reuse Alternative does not meet the overall intent of this Project objective and redevelopment of the Project site is necessary to accomplish this objective.

3. Provide development that will enhance the City’s economic well-being and employment opportunities for community residents. While the Reuse Alternative could conceivably continue to generate revenue and employment opportunities , th e existing outdated and underutilized building constructed in 1977 would not have the ability to attract a high -quality tenant to enhance additional property tax revenue and employment opportunities for the City.

Therefore, the Reuse Alternative would not meet this objective.

4. Develop the site with a use that has architectural design and operational characteristics that are compatible with other existing and planned development in the local area. The existing building is compatible with other existing development in the local area. However, the Reuse Alternative would not result in a new modern building that would complement new and planned development in the local area . Therefore, the Reuse Alternative partially meets this objective.

5. Provide a fully secured premise with active management to strengthen the security and safety for the local area. The Reuse Alternative would not include the installation of an approximately 8-foot-high tubular steel fencing along the site’s perimeter to protect visitors and/or employees on-site from vandalism and theft and from traversing the OCTA/SCRRA Railroad track immediately east of the site. In addition, the Reuse Alternative would not provide active management on-site for safety and security. Therefore, the Reuse Alternative would not meet this objective.

6. Redevelop the Project site with a new modern building that meet current California Building Code and California Green Building Code Standards with increased energy efficiency with existing available infrastructure. The Reuse Alternative would not involve the redevelopment of the Project site, rather it would involve the continued use or reuse of the existing building that was constructed in 1977. The Project would not result in the development of a modern building that meets current building code standards and would not be as energy efficient as redevelopment of the site. Therefore, the Reuse Alternative would not meet current California Building Code and California Green Building Code standards.

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6.6 ENVIRONMENTALLY SUPERIOR ALTERNATIVE
CEQA requires the identification of an environmentally superior alternative. As discussed above, the No Project/No Development Alternative, would not require grading or construction and would not cause construction-related impacts.

Section 15126.6(e)(2) of the CEQA Guidel ines states that, if the No Project/No Development Alternative is the environmentally superior alternative, then the EIR shall also identify an environmentally superior alternative among the other alternatives. The Reuse Alternative has been selected as the environmentally superior alternative. This alternative would not avoid or substantially lessen a significant and unavoidable impact. Because no grading would occur under the Reuse Alternative, impacts related to archaeological resources, biological resources, paleontological resources, hazardous materials, and tribal cultural resources would be eliminated. However, the Reuse Alternative would not result in remediation of the site in the event that unknown contaminated soils are present during grading. Additionally, this alternative would result in increased operational energy demand and GHG emissions compared to the Project, because it would not redevelop the Project site with a new modern building that meets current California Building Code and California Green Building Code standards with increased energy efficiency with existing available infrastructure . As described above, the Reuse Alternative does not meet the overall intent of Project Objectives 1, 2, 3, 5, and 6; and only partially meets Project Objective 4.

For the reasons outlined in Section 6.4 above, there is no need to further evaluate alternative sites or alternative development scenarios (reduced intensity, reduced development area, alternative site plan, etc.) compared to the Project. Any alternative development scenario would have similar impacts as the Project related to construction activities, and the Project would not result in any significant operational impacts that would be avoided by a development alternative.

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7.0 REFERENCES

7.1 PERSONS CONTRIBUTING TO EIR PREPARATION

7.1.1 CITY OF ORANGE
Robert Garcia, Senior Planner

7.1.2 T&B PLANNING, INC.

Nicole Morse, Esq.

Principal

Kristen Goddard, AICP
Senior Planner

Tracy Chu
Assistant Project Manager

Cristina Maxey
Graphic Specialist

Rhea Smith
GIS/Graphics Technician

7.2 DOCUMENTS APPENDED TO THIS EIR
The following reports, studies, and supporting documentation were used in preparing the 534 Struck Avenue Project EIR and are bound separately as Techni cal Appendices . A copy of the Technical Appendices is available for review at the City of Orange, Planning Division, Community Development Department, 300 East Chapman Avenue, Orange, CA 92866.

Appendix A1: Written Comments on the Mitigated Negative Declaration (MND)

Appendix A2: Notice of Preparation (NOP), and Written Comments on the NOP.

Appendix B1: Urban Crossroads, 2023a. 534 Struck Avenue Air Quality Impact Analysis. January 12, 2023.

Appendix B2: Urban Crossroads, 202 3b. 534 Struck Avenue Mobile Source Health Risk Assessment. January 12, 2023.

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Appendix C: Noreas, Inc., 2023 Struck Avenue Project General Biological Technical Report.

February 2023.

Appendix D: Duke Cultural Resources Management, 2021. Cultural and Paleontological Resource Letter Report for the 534 Struck Avenue Project, City of Orange, Orange County, California. April 30, 2021.

Appendix E: Urban Crossroads, 2023c. 534 Struck Avenue Energy Analysis. January 12, 2023.

Appendix F: GeoTek, 2020a. Geot echnical and Infiltration Evaluation, Proposed Warehouse Facility, 534 West Struck Avenue, Orange, Orange County, California. March 31, 2020.

Appendix G: Urban Crossroads, 2023d. 534 Struck Avenue Greenhouse Gas Analysis . January 12, 2023

Appendix H1: GeoTek, 2020b. Phase I Environmental Site Assessment, Assessor’s Parcel Number (APN) 375-331 -04, 534 Struck Avenue, Orange, Orange County, California 92867. March 31, 2020.

Appendix H2: GeoTek, 2020c . Limited Phase II Environmental Site Assessment, 534 Str uck Avenue, Orange, Orange County, California 92867. June 30, 2020.

Appendix H3: Ramboll, 2020. Soil Management Plan, Proposed Industrial Development, 534 Struck Avenue, Orange, California. August 12, 2020.

Appendix I1: Albert A. Webb Associates, 2021a . Priority Water Quality Management Plan.

November 2021.

Appendix I2: Albert A. Webb Associates, 2021b. Preliminary Drainage Study. February 2021.

Appendix J: Urban Crossroads, 2022a. 534 Struck Avenue Noise and Vibration Analysis, City of Orange. October 23, 2022.

Appendix K1: Urban Crossroads, 2022b. 534 Struck Avenue Traffic Analysis. October 26, 2022.

Appendix K2: Urban Crossroads, 2023e . 534 Struck Avenue Vehicle Miles Travelled (VMT) Screening Evaluation. January 5, 2023.

534 Struck Avenue Project
Environmental Impact Report 7.0 References
Lead Agency: City of Orange SCH No. 2021090399

7.3 DOCUMENTS INCORPORATED BY REFERENCE
The following reports, studies, and supporting documentation were used in the preparation of this EIR and are incorporated by reference within this EIR. A copy of the following re ports, studies, and supporting documentation is a matter of public record and is generally available to the public at the location listed.

Cited As: Citation:

Orange,
2010a
City of Orange, 2010. General Plan EIR. March 2010. Accessed January 27, 2022.

Available on-line:
https://www.cityoforange.org/our-city/departments/community- development/general-plan
Orange,
2010b
City of Orange, 2010. City of Orange General Plan. March 2010. Accessed January 13, 2022. Available on-line:
https://www.cityoforange.org/our-city/departments/community- development/general-plan
Orange,
2011
City of Orange, 2011. Stormwater Local Implementation Plan. July 2011.

Available on-line: https://www.cityoforange.org/our-city/departments/public- works/engineering-division/storm-water/local-implementation-plan Orange,
2015a
City of Orange, 2015. General Plan Land Use Element. December 2015. Accessed January 12, 2022. Available on-line:
https://www.cityoforange.org/home/showpublisheddocument/208/6376981725556 30000
Orange,
2015b
City of Orange, 2015. General Plan Natural Resources Element. December 8, 2015.

Accessed January 12, 2022. Available on-line:
https://www.cityoforange.org/home/showpublisheddocument/210/6376981725592 70000
Orange,
2015c
City of Orange, 2015. General Plan Cultural Resources & Historic Preservation .

December 2015. Accessed January 12, 2022. Available on-line:
https://www.cityoforange.org/home/showpublisheddocument/196/6376981725343 00000
Orange,
2015d
City of Orange, 2015. General Plan Circulation and Mobility Element. December 8, 2015. Accessed January 12, 2022. Available on-line:
https://www.cityoforange.org/home/showpublisheddocument/192/6376981725259 70000
Orange,
2020
City of Orange, 2020. Zoning Map. September 1, 2020. Accessed January 12, 2022.

Available on-line:
https://www.cityoforange.org/home/showpublisheddocument/40/63770760741330 0000
Orange,
2021
City of Orange, 2021. City of Orange Municipal Code. November 9, 2021. Accessed January 12, 2022. Available on-line:
https://library.qcode.us/lib/orange_ca/pub/municipal_code 534 Struck Avenue Project
Environmental Impact Report 7.0 References
Lead Agency: City of Orange SCH No. 2021090399

7.4 DOCUMENTS AND WEBSITES CONSULTED
Cited As: Citation:

BSC, n.d. Building Standards Commission, n.d. California Building Standards Code. No date.

Accessed Available on-line: https://www.dgs.ca.gov/BSC/Codes CAB, n.d. California Architects Board, n.d. Essential Services Building Seismic Safety Act. No date. Available on-line: https://www.cab.ca.gov/general_information/esbssa.shtml CA
Legislative
Info, n.d.

CA Legislative Information, n.d. Fish and Game Code, Division 4, Chapter 2 . No date. Accessed Available on-line:
http://www.leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?division=4.& chapter=1.&part=2.&lawCode=FGC
CA
Legislative
Info, n.d.

CA Legislative Information, n.d. Public Resources Code, Section 5097.98. No date.

Accessed January 27, 2022. Available on-line:
https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PRC &sectionNum=5097.98
CA
Legislative
Info, n.d.

CA Legislative Information, n.d. Health and Safety Code 7050.5. No date. Accessed January 27, 2022. Available on-line:
https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=HSC &sectionNum=7050.5
CA
Legislative
Info, n.d.

CA Legislative Information, n.d. Alquist-Priolo Earthquake Fault Zoning Act. No date. Available on-line:
https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?division=2.&chap ter=7.5.&lawCode=PRC
CA
Legislative
Info, n.d.

CA Legislative Information, n.d. Natural Hazards Disclosure Act. No date.

Available on-line:
https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=1 103.2.&lawCode=CIV
CA
Legislative
Info, n.d.

CA Legislative Information, n.d. Hazardous Waste Control Law. No date.

Available on-line:
https://leginfo.legislature.ca.gov/faces/codes_displayexpandedbranch.xhtml?tocCo de=HSC&division=20.&title=&part=&chapter=6.5.&article=
CA
Legislative
Info, n.d.

CA Legislative Information, n.d. California Water Code. No date. Available on- line:
http://leginfo.legislature.ca.gov/faces/codesTOCSelected.xhtml?tocCode=WAT&t ocTitle=+Water+Code+-+WAT
CalFire,
2011
California Department of Forestry and Fire Protection. 2011. Very High Fire Hazard Severity Zones in LRA. October 2011. Accessed January 27, 2022. Available on-line:
https://osfm.fire.ca.gov/media/5892/c30_orange_vhfhsz_2.pdf CalRecycle,
2006
California Department of Resources Recycling and Recovery. 2006. Estimated Solid Waste Generation Rates. 2006. Accessed January 27, 2022. Available on-line:
https://www2.calrecycle.ca.gov/WasteCharacterization/General/Rates 534 Struck Avenue Project
Environmental Impact Report 7.0 References
Lead Agency: City of Orange SCH No. 2021090399

CalRecycle,
2020a
California Department of Resources Recycling and Recov ery, 2020. Olinda Alpha Landfill. 2020. Accessed January 27, 2022. Available on-line:
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/2757?siteID=2093 CalRecycle,
2020b
California Department of Resources Recycling and Recovery, 2020. Frank R.

Bowerman Landfill. 2020. Accessed January 27, 2022. Available on-line:
https://www2.calrecycle.ca.gov/SolidWaste/Site/Summary/2103 CalRecycle,
2020c
California Department of Resources Recycling and Recovery , 2020. Pima Deschecha Landfill. 2020. Accessed January 27, 2022. Available on-line:
https://www2.calrecycle.ca.gov/SolidWaste/Site/Summary/2085 Caltrans,
2019
California Department of Transportation. 2019. List of Eligible and Officially Designated State Scenic Highway. August 2019. Accessed January 27, 2022.

Available on-line:
https://dot.ca.gov/-/media/dot-media/programs/design/documents/desig-and- eligible-aug2019_a11y.xlsx
Carollo,
2020
Carollo Engineers, Inc. (Carollo). 2020. Upgrades to Plants Nos. 1 and 2. Accessed May 12, 2020. Available:
https://www.carollo.com/projects/ocsd-upgrades-to-plant-nos-1-and-2 CBSC, 2019 California Building Standards Code, 2019. Guide to Title 24 California Building Standards Code. Available on -line: https://www.dgs.ca.gov/BSC/Resources/Page- Content/Building-Standards-Commission-Resources-List-Folder/Guidebooks--- Title-24
CDC, n.d. California Department of Conservation. n.d. Seismic Hazards Mapping Act. No date.

Available on-line: https://www.conservation.ca.gov/cgs/shma CDFW, n.d. California Department of Fish and Wildlife , n.d. Threatened and Endangered Species. No date. Accessed January 27, 2022. Available on-line:
https://www.wildlife.ca.gov/Conservation/CESA
CDFW, n.d. California Department of Fish and Wildlife, n.d. Natural Community Conservation Planning (NCCP). No date. Accessed January 27, 2022. Available on-line:
https://www.wildlife.ca.gov/conservation/planning/nccp
Center for
Climate and
Energy
Solutions,
2015
Center for Climate and Energy Solutions, 2015. Outcomes of the U.N. Climate Change Conference in Paris . December 12, 2015. Available on-line:
https://www.c2es.org/wp-content/uploads/2015/12/outcomes-of-the-u-n-climate- change-conference-in-paris.pdf
CNRA, 2019 California Natural Resources Agency , 2019. CEQA Article 5. 2019. Accessed January 27, 2022. Available on-line:
https://resources.ca.gov/CNRALegacyFiles/ceqa/docs/2019_CEQA_Statutes_and_ Guidelines.pdf
DOC, 2016a California Department of Conservation, 2016. Earthquake Zones of Required Investigation. 2016. Available on-line:
https://maps.conservation.ca.gov/cgs/EQZApp/
534 Struck Avenue Project
Environmental Impact Report 7.0 References
Lead Agency: City of Orange SCH No. 2021090399

DOC, 2016b California Department of Conservation , 2016. Calfornia Important Farmland Finder. 2016. Accessed January 27, 2022. Available on-line:
https://maps.conservation.ca.gov/DLRP/CIFF/
DTSC, n.d. California Department of Toxic Substances Control, n.d. Official California Code of Regulations (CCR), Title 22, Division 4.5. No date. Available on-line:
https://dtsc.ca.gov/title22/
DTSC, 2019 California Department of Toxic Substances Control, 2019. Hazardous Waste and Hazardous Substances Law Code Excerpts. Available on-line:
https://dtsc.ca.gov/wp-content/uploads/sites/31/2019/06/HSC-2018-Full-Doc.pdf DWR, n.d. California Department of Water Resources, n.d. Sustainable Groundwater Management Act (SGMA). No date. Available on-line:
https://water.ca.gov/Programs/Groundwater-Management/SGMA-Groundwater- Management
DWR, 2020 California Department of Water Resources, 2020. Basin Prioritization. May 1, 2020. Available on-line: https://water.ca.gov/Programs/Groundwater- Management/Basin-Prioritization
EDD, 2020 California Employment Development Department. 2020. Monthly Labor Force Data for Cities and Census Designated Places - April 2020, Orange County . 2020.

Accessed January 27, 2022. Available on-line:
https://www.labormarketinfo.edd.ca.gov/data/labor-force-and-unemployment-for- cities-and-census-areas.html
EDR, 2016 EDR, 2016. Guidance on ASTM's REC -HERC-CREC Definitions. April 18, 2016.

Accessed January 27, 2022. Available on-line:
https://edrnet.com/guide-rec-definitions/
EPA, 2009 United States Environmental Protection Agency, 2009. Estimating 2003 Building - Related Construction and Demolition Materials Amounts . 2009. Accessed January 27, 2022. Available on-line:
https://www.epa.gov/sites/production/files/2017-
09/documents/estimating2003buildingrelatedcanddmaterialsamounts.pdf EPA, 2019 United States Environmental Protection Agency, 2019. Summary of the Occupational Safety and Health Act . Available on-line: https://www.epa.gov/laws- regulations/summary-occupational-safety-and-health-act
EPA, 2020a United States Environmental Protection Agency, 2020. Summary of Clean Water Act. September 9, 2020. Available on-line: https://www.epa.gov/laws- regulations/summary-clean-water-act
EPA, 2020b United States Environmental Protection Agency, 2020. Summary of the Comprehensive Environmental Response, Compensation, and Liability Act .

Available on-line: https://www.epa.gov/laws-regulations/summary-comprehensive- environmental-response-compensation-and-liability-act
EPA, 2020c United States Environmental Protection Agency, 2020. Summary of t he Resource Conservation and Recovery Act . Available on-line: https://www.epa.gov/laws- regulations/summary-resource-conservation-and-recovery-act 534 Struck Avenue Project
Environmental Impact Report 7.0 References
Lead Agency: City of Orange SCH No. 2021090399

EPA, 2020d United States Environmental Protection Agency, 2020. Summary of the Toxic Substances Control Act . Available on -line: https://www.epa.gov/laws- regulations/summary-toxic-substances-control-act
EPA, 2020e United States Environmental Protection Agency, 2020. Summary of the Noise Control Act . Available on-line: https://www.epa.gov/laws-regulations/summary- noise-control-act
FEMA, 2009 Federal Emergency Management Agency, 2009. FEMA FIRM No. 06059C0161J .

December 3, 2009. Accessed January 27, 2022. Available on-line:
https://msc.fema.gov/portal/search?AddressQuery=534%20struck%20avenue%2C %20orange%2C%20ca#searchresultsanchor
FHWA,
2017
Federal Highway Administration, 2017. Highway Traffic Noise . June 6, 2017.

Accessed January 27, 2022. Available on-line:
https://www.fhwa.dot.gov/environment/noise/
FTA, 2006 Federal Transit Administration, 2006. Transit Noise and Vibration Impact Assessment. May 2006. Accessed January 27, 2022. Available on-line:
https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/FTA_Noise_and_Vibration _Manual.pdf
FTA, 2018 Federal Transit Administration, 2018. Transit Noise and Vibration Impact Assessment Manual. September 2018. Available on-line:
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
Google Earth
Pro, 2021
Google Earth Pro, 2021. Multiple Dates. Version 7.3.2.5776. Computer Software.

NAHC, n.d. Native American Heritage Commission, n.d. State Laws and Codes . No date.

Accessed January 27, 2022. Available on -line: http://nahc.ca.gov/codes/state-laws- and-codes/
NOAA, n.d. National Oceanic and Atmospheric Administration, n.d. American Indian Religious Freedom Act. No date. Accessed January 27, 2022. Available on-line:
https://coast.noaa.gov/data/Documents/OceanLawSearch/Summary%20of%20Law %20-%20American%20Indian%20Religious%20Freedom%20Act.pdf NPS, n.d. National Parks Service, n.d. California Administrative Code, Title 14, Section 4308.

No date. Accessed January 27, 2022. Available on-line:
https://www.parks.ca.gov/pages/627/files/california%20code%20of%20regulations .doc
NPS, n.d. National Parks Service, n.d. Fossils and Paleontology Laws, Regulations, and Policies. No date. Available on-line: https://www.nps.gov/subjects/fossils/fossil- protection.htm
NPS, 2021a National Park Service, 2021. The National Historic Preservation Program:

Overview. October 20, 2021. Accessed January 27, 2022. Available on-line:
https://www.nps.gov/archeology/tools/laws/nhpa.htm
534 Struck Avenue Project
Environmental Impact Report 7.0 References
Lead Agency: City of Orange SCH No. 2021090399

NPS, 2021b National Park Service, 2021. National Historic Landmarks Program. September 3, 2021. Accessed January 27, 2022. Available on -line:
https://www.nps.gov/orgs/1582/index.htm
NPS, 2021c National Park Service, 2021. The Native American Graves Protection and Repatriation Act. March 30, 2021. Accessed January 27, 2022. Available on-line:
https://www.nps.gov/archeology/tools/laws/nagpra.htm
NPS, 2021d National Park Service, 2021. About the Antiquities Act. October 20, 2021. Accessed January 27, 2022. Available on-line:
https://www.nps.gov/archeology/sites/antiquities/about.htm NPS, 2020 National Park Service, 2020a. National Register of Historic Places FAQ. September 23, 2021. Accessed January 27, 2022. Available on-line:
https://www.nps.gov/subjects/nationalregister/faqs.htm
OHP, n.d. Office of Historic Preservation, n.d. California Register of Historical Resources. No date. Accessed January 27, 2022. Available on-line:
http://ohp.parks.ca.gov/?page_id=21238
OPR, 2005 Governor’s Office of Planning and Research, 2005. Tribal Consultation Guidelines.

November 14, 2005. Accessed January 27, 2002. Available on-line:
http://opr.ca.gov/docs/011414_Updated_Guidelines_922.pdf OPR, 2017a Governor’s Office of Planning and Research, 2017. General Plan Guidelines. 2017.

Accessed January 27, 2022. Available on-line:
https://www.opr.ca.gov/planning/general-plan/guidelines.html OPR, 2017b Governor’s Office of Planning and Research, 2017. Technical Advisory AB 52 and Tribal Cultural Resources in CEQA . June 2017. Accessed January 27, 2022.

Available on-line:
http://nahc.ca.gov/wp-content/uploads/2017/06/Technical-Advisory-AB-52-and- Tribal-Cultural-Resources-in-CEQA.pdf
OPR, 2019 Governor’s Office of Planning and Research , 2019. Guidelines for the Implementation of the California Environmental Quality Ac t. 2019. Accessed January 27, 2022. Available on-line:
http://resources.ca.gov/ceqa/docs/2018_CEQA_FINAL_TEXT_122818.pdf OSHA, 2002 Occupational Safety and Health Administration, 2002. Hearing Conservation. 2002.

Accessed January 27, 2022. Available on-line:
https://www.osha.gov/sites/default/files/publications/osha3074.pdf OSHA, n.d. Occupational Safety and Health Administration, n.d. Trucking Industry. No date.

Available on-line: https://www.osha.gov/trucking-industry OSHA, n.d. Occupational Safety and Health Administration, n.d. California State Plan. No date.

Available on-line: https://www.osha.gov/dcsp/osp/stateprogs/california.html

SARWQCB,
2019
Santa Ana Regional Water Quality Control Board, 2019 . Santa Ana River Basin Water Quality Control Plan. June 2019. Accessed January 14, 2022. Available on- line:
https://www.waterboards.ca.gov/santaana/water_issues/programs/basin_plan/ 534 Struck Avenue Project
Environmental Impact Report 7.0 References
Lead Agency: City of Orange SCH No. 2021090399

SAWPA,
2019
Santa Ana Watershed Project Authority, 2019. Integrated Regional Water Management Plan (IRWM). February 19, 2019. Accessed January 14, 2022.

Available on-line: https://sawpa.org/owow/owow-irwm-plans/ SCAG, 2018 Southern California Association of Governments, 2018. Industrial Warehousing in the SCAG Region. April 2018. Available on-line:
https://scag.ca.gov/sites/main/files/file-
attachments/final_report_03_30_18.pdf?1604268012
SCAG,
2020a
Southern California Association of Governments, 2020. 2020-2045 RTP/SCS .

September 3, 2020. Accessed January 27, 2022. Available on-line:
https://scag.ca.gov/sites/main/files/file-attachments/0903fconnectsocal- plan_0.pdf?1606001176
SCAG,
2020b
Southern California Association of Governments, 2020. Connect SoCal Demographics and Growth Forecast . September 3, 2020. Accessed January 27, 2022. Available on-line:
https://scag.ca.gov/sites/main/files/file-
attachments/0903fconnectsocal_demographics-and-growth-
forecast.pdf?1606001579
SCEC, 1999 Southern California Earthquake Center, 1999. Guidelines for Analyzing and Mitigating Liquefaction in CA. March 1999. Accessed January 27, 2022. Available on-line:
https://www.tugraz.at/fileadmin/user_upload/Institute/IAG/Files/33_Liquefaction_ Mitigation-DMG_SP117.pdf
SWRCB,
2014
California State Water Resources Control Board, 2014. 0A – Federal, State and Local Laws, Policy and Regulations . June 23, 2014. Available on-line:
http://waterboards.ca.gov/water_issues/programs/nps/encyclopedia/0a_laws_policy .shtml
SWRCB,
2016
California State Water Resources Control Board, 2016. A Compilation of Water Quality Goals. January 2016. Available on-line:
http://www.waterboards.ca.gov/water_issues/programs/water_quality_goals/docs/ wq_goals_text.pdf
SWRCB,
2017
California State Water Resources Control Board, 2017. Watershed Management.

August 3, 2017. Available on-line:
http://www.waterboards.ca.gov/water_issues/programs/watershed/ USFWS,
2017
United States Fish and Wildlife Service, 2017. ESA Basics. February 2017. Accessed January 27, 2022. Available on-line:
https://www.fws.gov/law/endangered-species-act
USFWS,
2020
United States Fish and Wildlife Service, 2020. Migratory Bird Treaty Act. April 16, 2020. Accessed January 27, 2022. Available on-line:
https://www.fws.gov/birds/policies-and-regulations/laws-legislations/migratory- bird-treaty-act.php

534 Struck Avenue Project
Environmental Impact Report 7.0 References
Lead Agency: City of Orange SCH No. 2021090399

7.5 PERSONS CONSULTED/WRITTEN OR VERBAL COMMUNICATION

7.5.1 PUBLIC SERVICE CORRESPONDENCE
Orange City Fire Department
Robert Stefano, Deputy Chief of Operations

7.5.2 TRIBAL CONSULTATION
Gabrieleno Band of Mission Indians – Kizh Nation
Andrew Salas, Chairman

Gabrielino/Tongva Nation
Samuel Dunlap, Cultural Resources Director

San Gabriel Band of Mission Indians
Anthony Morales, Chief

Torres Martinez Desert Cahuilla Indians
Michael Mirelez, Cultural Coordinator