Attachment 8 Environmental Review No 1889, Addendum to Certified EIR (SCH No. 2021090399)

534 W. Struck Avenue Project

Addendum to the 534 Struck Avenue EIR (SCH No.
2021090399) -1889

Lead Agency:

City of Orange
Community Development Department • Planning Division
300 East Chapman Avenue
Orange, CA 92866-1591
(714) 744-7220
(714) 744-7222 (Fax)
www.cityoforange.org

Prepared by:

T&B Planning Inc.
3200 El Camino Real
Irvine, CA 92602
Contact: Nicole Morse, Esq., Principal
(714) 505-6360

Date: March 2025

TABLE OF CONTENTS

Sections Page

1.0 ADDENDUM - 1889 ........................................................................................................ 1-1

2.0 ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED ................................... 2-1

3.0 ENVIRONMENTAL IMPACT ISSUES: ........................................................................ 3-1 AESTHETICS............................................................................................................... 3-1 AGRICULTURE & FOREST RESOURCES. ............................................................. 3-6 AIR QUALITY. ............................................................................................................ 3-9 BIOLOGICAL RESOURCES. ................................................................................... 3-20 CULTURAL RESOURCES. ...................................................................................... 3-25 ENERGY. ................................................................................................................... 3-28 GEOLOGY AND SOILS. .......................................................................................... 3-32 GREENHOUSE GAS EMISSIONS. .......................................................................... 3-39 HAZARDS AND HAZARDOUS MATERIALS. ..................................................... 3-41 HYDROLOGY AND WATER QUALITY. ............................................................... 3-50 LAND USE/PLANNING. .......................................................................................... 3-61 MINERAL RESOURCES. ......................................................................................... 3-63 NOISE. ........................................................................................................................ 3-65 POPULATION AND HOUSING. .............................................................................. 3-74 PUBLIC SERVICES. ................................................................................................. 3-76 RECREATION. .......................................................................................................... 3-80 TRANSPORTATION. ................................................................................................ 3-82 TRIBAL CULTURAL RESOURCES. ....................................................................... 3-89 UTILITIES/SERVICE SYSTEMS. ............................................................................ 3-92 WILDFIRE. ................................................................................................................ 3-98 MANDATORY FINDINGS OF SIGNIFICANCE. ................................................. 3-100

4.0 REFERENCES ................................................................................................................. 4-1 PREPARERS AND PERSONS CONSULTED ........................................................... 4-3

5.0 MITIGATION MONITORING AND REPORTING PROGRAM .................................. 5-1

6.0 APPENDICES .................................................................................................................. 6-1

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List of Figures

Figure Number and Title Page

Figure 1 Regional Location Map ........................................................................................ 1-8 Figure 2 Local Vicinity Map .............................................................................................. 1-9 Figure 3 Existing Site Plan ............................................................................................... 1-10 Figure 4 Overall Site Plan ................................................................................................ 1-14 Figure 5 Architectural Elevations ..................................................................................... 1-15 Figure 6 Conceptual Landscape Plan ............................................................................... 1-16 Figure 7 Proposed Grading Plan ...................................................................................... 1-18 Figure 8 Proposed Utility Plan ......................................................................................... 1-19 Figure 9 Sensitive Receptor Locations ............................................................................. 3-17 Figure 10 Water Quality Management Plan ....................................................................... 3-54 Figure 11 Noise Receiver Locations .................................................................................. 3-67 Figure 12 Truck Circulation ............................................................................................... 3-88

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List of Tables

Table Number and Title Page

Table 1 General Plan Consistency Analysis ..................................................................... 3-3 Table 2 Zoning Development Standards Consistency Analysis ....................................... 3-4 Table 3 Revised Project Construction Emissions ........................................................... 3-12 Table 4 Revised Project Operational Emissions ............................................................. 3-13 Table 5 Original Project Localized Construction-Source Emissions .............................. 3-14 Table 6 Original Project Localized Significance Summary of Operations ..................... 3-14 Table 7 Revised Project Localized Construction Emissions .......................................... 3-15 Table 8 Revised Project Localized Operational Emissions ............................................ 3-16 Table 9 Comparison of Original Project and Revised Project Cancer and Non-Cancer Risks .............................................................................................. 3-18 Table 10 Original Project Annual Operational Energy Demand Summary ...................... 3-29 Table 11 Revised Project GHG Emissions ....................................................................... 3-40 Table 12 Original Project Peak Flows .............................................................................. 3-57 Table 13 Revised Project Peak Flows ............................................................................... 3-57 Table 14 Revised Project Construction Noise Level Compliance .................................... 3-68 Table 15 Revised Project Operational Noise Level Compliance ...................................... 3-69 Table 16 Existing with Revised Project Traffic Noise Level Increases ........................... 3-70 Table 17 Opening Year Cumulative with Revised Project Traffic Noise Level Increases ................................................................................................... 3-70 Table 18 Revised Project Construction Equipment Vibration Levels .............................. 3-72

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1.0 ADDENDUM - 1889

Project Title:
534 W. Struck Avenue Warehouse Project
Reference Application Numbers:

Conditional Use Permit - 3221
Major Site Plan Review - 1166
Design Review - 5140
Addendum – 1889

Lead Agency:

City of Orange
300 East Chapman Avenue
Orange, CA92866

Contact Person and Telephone No.:

Monique Schwartz, Senior Planner
Robert Garcia, Senior Planner
(714) 744-7224
Project Proponent and Address:

Prologis
2141 Rosecrans Ave, Suite 1151
El Segundo, CA 90245

Contact Person and Telephone No.:

Maggie Xu, Director of Project Management
(310) 338-3273

Project Location:
534 W. Struck Avenue
Orange, CA 92867

Existing General Plan Designation:

Light Industrial Max 1.0 Floor Area Ratio (FAR),
3-story height limit
Existing Zoning Classification:

Industrial (M-2)

INTRODUCTION

Prior CEQA Compliance:

A Mitigated Negative Declaration (MND) was originally prepared for the proposed 534 W. Struck Avenue Project 1 (referred to herein as the “Original Project”). On September 23, 2021, the City circulated a Notice of Intent to Adopt Mitigated Negative Declaration No. 1870-20 for the project.

The MND was circulated for public review from September 23 to October 25, 2021. During the 30-day public review period, comments received requested additional technical analysis (e.g., air quality and noise modeling, traffic). Therefore, in order to address the environmental concerns raised, additional technical analyses were prepared and an E nvironmental Impact Report (EIR) was prepared to provide a highly conservative and comprehensive environmental review of the Original Project. The Draft EIR was available for public review for 45 days, beginning on March 31, 2023 and ending on May 15, 2023. The Dr aft EIR was distributed to various public agencies, organizations, and individuals on March 30, 2023.

The City of Orange City Council, on August 22, 2023, approved Resolution No. 11487 certifying the 534 Struck Avenue Final EIR No. 1870- 20 [State Clearinghouse (SCH) No. 2021090399]

1 Entitled as “534 Struck Avenue Final EIR No. 1870-20” (State Clearinghouse No. 2021090399)

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(“2023 Certified EIR”), adopting a Mitigation Monitoring and Reporting Program and Findings of Fact; and approving Conditional Use Permit No. 3137- 21, Major Site Plan Review No. 1039- 21, and Design Review No. 5028- 21. The Original Project would result in demolition of an existing 40,000 square feet manufacturing facility and site redevelopment with a 57,900 sf truck terminal that includes 52,900 sf of warehouse space, 5,000 sf of office space, and an accessory 5,400 sf maintenance building. The 2023 Certified EIR and its technical appendices are inc orporated by reference pursuant to California Environmental Quality Act (CEQA) Guidelines Section 15150.

The 2023 Certified EIR concluded that the Original Project would not result in any significant and unavoidable environmental impacts. Project-level mitigation measures were 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 Migratory Bird Treaty Act (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 M aterials (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.

Project Overview:

This document is an Addendum to the 2023 Certified EIR. The purpose of this Addendum is to evaluate the potential environmental impacts of the proposed 534 W. Struck Avenue Warehouse Project (referred to herein as the “Revised Project”). In accordance with the CEQA, this Addendum analyzes the Revised Project and demonstrates that all potential environmental impacts associated with the Revised Project at buildout would be within the envelope of impacts already evaluated in the certified EIR, herein referred to as 2023 Certified EIR.

The Revised Project requires approval of Conditional Use Permit - 3221, Major Site Plan Review - 1166, Design Review - 5140, and Addendum - 1889. Approval of the Revised Project entitlements would allow for redevelopment of the site with a 214,956 square foot (sf) 45-foot (ft) tall industrial building that includes 200,956 sf of warehouse space and 14,000 sf of office space, a 450 sf detached pump room, auto and truck parking, and landscaping in accordance with the City of Orange standards. The Revised Project would provide 104 standard automobile parking stalls, 4 motorcycle stalls (324 sf) and 47 trailer parking stalls.

As with the Original Project, the Revised Project would require the demolition of the existing 40,000 sf manufacturing facility, associated parking, and removal of an unused portion of a private railroad spur located on the east side of the site.

The remainder of this section provides a description of the Revised Project’s location , characteristics and CEQA methodology. Section 2.0 describes the potential environmental impacts of the proposed Revised Project in the context of the 2023 Certified EIR.

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California Environmental Quality Act:

CEQA, a statewide environmental law contained in Public Resources Code Sections 21000-21177, applies to most public agency decisions to carry out, authorize, or approve actions that have the potential to adversely affect the environment. CEQA requires that public agencies inform their decision-makers of the environmental consequences of their discretionary actions and to consider alternatives and mitigation measures (MMs) that could avoid or reduce the discretionary actions’ significant, adverse environmental effects. CEQA also gives other public agencies and the public an opportunity to participate in the environmental review process.

CEQA Rules and Requirements for an Addendum:

The CEQA Guidelines allow for the preparation of an Addendum to a previously approved/certified CEQA document when a subsequent project is within the scope of the analysis of the earlier approved CEQA document and when some changes or additions to the original CEQA document are necessary but none of the following conditions are met:

a. Substantial changes are proposed in the project which will require major revisions of the previous EIR due to the involvement of environmental effects or a substantial increase in the severity of previously identified significant effects;

b. Substantial changes occur with respect to the circumstances under which the project is undertaken, which will require major revisions of the previous EIR due to the involvement of new significant environmental effects or a substantial increase in the sever ity of previously identified significant effects; or

c. New information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete, shows any of the following:

1. The project will have one or more significant effects not discussed in the previous EIR;

2. Significant effects previously examined will be substantially more severe than shown in the previous EIR;

3. Mitigation measures or alternatives previously found not to be feasible would in fact be feasible, and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the MM or alternatives; or

4. Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the MM or alternative (See CEQA Guidelines Section 15162).

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If none of the circumstances listed above occur and only minor technical changes or additions are necessary to update the previously approved/certified CEQA document, an Addendum may be prepared (See CEQA Guidelines Section 15164).

Finding for the Revised Project:

As discussed above, the Original Project would result in the redevelopment with a 57,900 sf truck terminal while the Revised Project would consist of a 214,956 sf industrial building, resulting an increase of 157,056 sf. However, the Revised Project’s development footprint is the same as the Original Project’s development footprint analyzed under the 2023 Certified EIR, therefore, the physical impacts to the site would be the same as the Original Project. Additionally , as demonstrated in the analysis herein, construction -related air quality and noise impacts would be less than significant.

Under operational activities, the hours of operation would remain the same under the Revised Project. Moreover, the Revised Project is anticipated to result in a net reduction in daily trips of 24 two-way trips per day as compared to the Original Project. The Original Project was anticipated to generate 396 two-way trips per day, with 26 trips during the AM peak hour and 23 trips during the PM peak hour while the Revised Project would generate 372 two- way trips per day with 35 AM peak hour trips and 39 PM peak hour trips. Therefore, operational air quality emissions, noise volumes, and greenhouse gas emissions would be similar or reduced due to the decrease in vehicle trips. The Original Project would employ a total of 60 to 130 employees and the Revised Project has the potential to generate 120 to 200 employees. Although the Revised Project would result in a potential increase of approximately 70 employees, the increase in employees does not result in a significant impact because it is within the S outhern California Association of Governments’ (SCAG) growth projections for the City and would not induce substantial growth. Accordingly, this Addendum provides an analysis of the Revised Project and verification that the Revised Project will not result in any new, increased or substantially different impa cts, other than those previously considered and addressed in the 2023 Certified EIR.

The City, serving as the CEQA Lead Agency for the Revised Project (See CEQA Guidelines Sections 15050–15051), determined in its independent judgment that the Revised Project does not meet any of the circumstances provided in CEQA Guidelines Section 15162 and that an Addendum to the 2023 Certified EIR is the appropriate CEQA compliance document for the Revised Project.

The City’s finding is based on the following facts:

a. As demonstrated in Section 3.0 of this document, the Revised Project would not require major revisions to the 2023 Certified EIR because implementation of the Revised Project would neither result in any significant impacts to the physical environment that were not already disclosed in the 2023 Certified EIR nor result in substantial increases in the severity of the environmental impacts previously disclosed in the 2023 Certified EIR.

b. Subsequent to the certification of the 2023 Certified EIR, no substantial changes in the circumstances under which the Revised Project would be undertaken have occurred that would require major revisions to the 2023 Certified EIR due to the involvement of new

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significant environmental effects or a substantial increase in the severity of previously identified significant effects.

c. There is no evidence in the public record that new information of substantial importance has become available that is applicable to the Revised Project and/or the City (Project site), was not known and could not have been known with the exercise of reasona ble diligence at the time the 2023 Certified EIR was certified and would alter the conclusions of the 2023 Certified EIR.

Format and Content of this EIR Addendum:

The following components comprise the EIR Addendum in its totality:

a. Section 1.0 provides the Introduction, the Existing Setting, and the Project Description.

b. The environmental impact analysis (Section 3.0), which concludes that implementation of the Revised Project would neither result in any new, significant environmental impacts that were not previously disclosed in the 2023 Certified EIR nor substantially increase the severity of the significant environmental impacts beyond the levels disclosed in the 2023 Certified EIR.

c. Seven (7) technical reports and other documentation that evaluate the Revised Project, which are attached as EIR Addendum Technical Appendices A-F.

Appendix A Supplemental Air Quality, Greenhouse Gas, and Health Risk Assessment Appendix B.1 Preliminary Water Quality Management Plan
Appendix B.2 Drainage Study.

Appendix C Noise and Vibration Analysis
Appendix D Trip Generation Assessment.

Appendix E Vehicle Miles Traveled (VMT) Screening Evaluation Appendix F Updated Traffic Index Calculations

d. Section 4.0 includes the Mitigation Monitoring and Reporting Program (MMRP) from the 2023 Certified EIR. All mitigation measures in the MMRP from the 2023 Certified EIR apply to the Revised Project.

e. The 2023 Certified EIR and Technical Appendices , Findings and Statement of Facts, as well as all associated staff reports, memoranda, public comments and other materials relating to the Original Project are all herein incorporated by reference pursuant to CEQA Guidelines Section 15150 and are available for review at City of Orange, Planning Division, Community Development Department, 300 East Chapman Avenue, Orange, CA 92866.

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EXISTING SETTING

Regional Setting:

The Project site is located at 534 W. Struck Avenue in the City of Orange, Orange County, California. As shown in, Figure 1, Regional Location Map, the City of Orange is in the north - central portion of Orange County. The City of Anaheim borders the City to the north, northwest and west. The City of Garden Grove borders the west and the cities of Santa Ana and Tustin, and unincorporated Orange County border the City to the east and south . Interstate 5 (I-5) is located approximately 2.0 miles southwest of the Project site and State Route 57 (SR -57) is located approximately 1.26 to the west. Regional access to the site is provided by SR -57 via Katella Avenue located approximately 1.26 miles west.

Local Setting and Existing Site Conditions:

As shown in Figure 2, Local Vicinity Map, the approximate 9.94-acre Project site (Assessor Parcel Number [APN] 375-331-04) is generally located north of Collins Avenue, east of Batavia Street, south of W. Struck Avenue, and west of the Orange County Transportation Authority/Southern California Regional Rail Authority (OCTA/SCRRA) Railroad. The Project site is developed with an approximate 40,000 square-foot concrete tilt-up building and parking lot and was occupied until the end of 2020 by Nursery Supplies, Inc. manufacturing facility as shown in Figure 3, Existing Site Plan. The site is accessed via three two-way driveways along W. Struck Avenue. The Project site contains ornamental landscaping along the site’s frontage at W. Struck Avenue.

Additionally, there is an existing, private railroad track on the eastern portion of the Project site that connects to the OCTA/SCRRA Railroad track. The previous operator, Nursery Supplies, Inc., did not utilize this private railroad spur on-site, but utilized the larger off-site OCTA/SCRRA Railroad track located east of the on-site private railroad track.

General Plan:

The Project site is designated Light Industrial (LI) in the City of Orange General Plan. The Light Industrial designation allows for the manufacturing, processing, and distribution of goods including warehouse uses . Wholesale activities associated with industrial operations, as well as small-scale, support retail, service commercial, and office use may also be established in areas with ready access to major circulation routes. A 3-story building height limit and maximum floor area ratio of 1.0 applies within the Light Industrial designation. (Orange, 2015a)

Zoning:

According to the City of Orange Zoning Map, the site is zoned as Industrial (M-2) (Orange, 2020).

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. Additionally, the M-2 zone allows for storage and warehousing uses. This zone classification implements the Light Industrial General Plan land use designation.

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Surrounding Land Uses:

The surrounding properties possess an urban and industrial character like the Project site.

Surrounding land uses are as follows:

North:

The property 31 feet north of the Project site is designated for Public Facility uses and includes the City of Orange Corporate Yard and Public Works Department and the former Mary’s Kitchen, a social services organization. The former Mary’s Kitchen site i s now operated by HUB OC, a nonprofit organization that offers hot meals, showers, laundry, restroom, mail, and occasional social and medical services at 517 W. Struck Avenue, Monday through Saturday from 9:00 am to 3:00 pm. The operation, known as the HUB Resource Center, is run by employees and volunteers.

No overnight stays or services are provided. All of the services are currently operated outside or in a rented mobile trailer (i.e., an office trailer, laundry trailer, shower trailer, etc.). On average , the HUB Resource Center serves anywhere between 80-85 meals at breakfast and 85-90 meals at lunch.

Additionally, an affordable residential development project is located north of HUB OC, 245 feet from the Project site.

Northeast/East:

The property northeast and east of the Project site, on the opposite side of the OCTA/SCRRA Railroad, is developed with multi -family and industrial uses, respectively. The multi -family residences are located approximately 126 feet northeast of the Project site. The area to the east contains industrial buildings and a storage yard containing various vehicles and storage facilities.

South/West:

The properties to the immediate south and west are designated for light industrial uses and include several industrial and commercial businesses.

57 91
55 22
5 91
S.P .P . RailroadS.P .P . Railroad
OCTA/SCRRA RailroadOCTA/SCRRA Railroad
OCTA/SCRRA RailroadOCTA/SCRRA Railroad
OCTA/SCRRA RailroadOCTA/SCRRA Railroad
261
OCTA/SCRRA RailroadOCTA/SCRRA Railroad
Project Site

ANAHEIM
ORANGE
SANT A
ANA
TUSTIN

FULLERTON
YORBA
LINDA

PLACENTIA
GARDEN
GROVE
IRVINE
VILLA
P ARK

FOUNT AIN
VALLEY
Regional Location Map
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0 0.75 1.50.375
Miles
Source(s): Esri, OC Public Works (2024) Figure 1
57 S.P .P . RailroadS.P .P . Railroad
OCTA/SCRRA RailroadOCTA/SCRRA Railroad
Project Site
OCTA/SCRRA RailroadOCTA/SCRRA Railroad
OCTA/SCRRA RailroadOCTA/SCRRA Railroad

ANAHEIM
ORANGE
Walnut AveWalnut Ave
Collins AveCollins Ave
Katella AveKatella Ave
Taft AveTaft Ave
Cambridge StCambridge St
Glassel StGlassel StBatavia StBatavia St
Main StMain St
Chapman AveChapman Ave
Batavia StBatavia St
Taft AveTaft Ave
Glassel StGlassel St
Cambridge StCambridge St
Meats AveMeats Ave
Collins AveCollins Ave
Main StMain StFlower StFlower St
Eckhoff StEckhoff St
Struck AveStruck Ave
Wagner AveWagner Ave
Grove AveGrove Ave
Douglass RdDouglass Rd
Local Vicinity Map
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0 500 1,000250
Feet
Figure 2Source(s): Esri, OC Public Works (2024)

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PROJECT DESCRIPTION

The purpose of the Revised Project is to implement the City’s vision of redeveloping underutilized parcels with light industrial uses, such as warehousing or fulfillment (non-sort). The Revised Project involves the demolition of the existing 40,000 sf manufacturing facility, see Figure 3 , Existing Site Plan, and redevelopment of the Project site. Redevelopment of the Project site would also include the removal of the existing, private unused railroad spur located on the east side of the site.

The Revised Project requires Conditional Use Permit - 3221, Major Site Plan Review - 1166, Design Review - 5140, and Addendum - 1889. The Project Applicant is proposing to redevelop the site with a 214,956 sf industrial warehouse building that includes 200,956 sf of warehouse space and 14,000 sf of office space, a 450 sf detached pump room, auto and truck parking, and landscaping in accordance with the City of Orange standards as shown in Figure 4, Overall Site Plan. The proposed building would be built up to 45 feet tall and include 27 dock doors on the east elevation of the building. The Revised Project would provide automobile parking stalls in compliance with the requirements (104 automobile parking stalls) of the Orange Municipal Code (OMC) and 4 motorcycle stalls (324 sf). The total automobile parking spaces include 25 electric vehicle (EV) parking stalls and 5 Americans with Disabilities Act (ADA) compliant parking stalls.

Additionally, the Revised Project would provide 45 trailer parking stalls. Ornamental landscaping, lighting, and walls would be installed per compliance with the OMC.

The future tenant (s) is/are currently unknown. However, for purposes of the analysis in this Addendum, the building is assumed to operate 24 hours a day, 7 days a week. It is anticipated that the facility would employ a total of 120 – 200 employees.

Site and Building Design Features

The Project has been designed to improve the pedestrian experience and consider the neighboring business and residential community. While the City of Orange has not adopted a Good Neighbor Policy, the Project has been designed to respect the neighboring uses and ensure compatibility with the surrounding community. Specifically, the following project design components are incorporated into the Project:

• Building Orientation: The building has been designed so that the truck court is located on the southeast side of the project - tucked behind the 8’ screen wall facing Struck Ave. and the OCTA railroad running along the eastern property line; and away from the sensitive receptors.
• Landscape Enhancement: In addition to the 10’ landscape setback along Struck Ave., the proposed project also includes a large landscape area at the northeast of the property which set the truck court 215’ back from the nearest sensitive receptor to the North. The proposed landscaping includes a variety of new trees, shrubs, accents, and groundcover and will comply with OMC Chapter 16.50, Landscape Requirements • Sidewalk Improvements: Sidewalk improvements will be installed along the Project site’s frontage along W. Struck Avenue.

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• Fencing: A 6-foot to 8-foot high metal fence will be installed along all four sides of the property, as well as 8- foot high screening walls and motorized metal gates at the truck court entrance facing W. Struck Avenue, to enhance security and safety. • Separate Access: Site access for Project passenger vehicles and non-heavy trucks will be separated from truck access to eliminate conflicts between pedestrians and truck traffic. • Truck Access: Truck access will be provided at the northeast and northwest corner of the Project site and these driveways will be designed to accommodate the wide turning radius of heavy trucks. Project design will allow for adequate circulation and prevent trucks from backing up onto W. Struck Avenue.
• Lighting and Glare: Exterior lighting will be installed on -site, as necessary, for safety and security. Decorative architectural lighting will also be installed to accent building entries as focal points throughout the site. Lighting on the site will be directed, controlled, and screened in such a manner so as to refrain from shining directly on surrounding properties.
• Signage and Truck Routes: On-site signage will be provided for directional guidance to trucks entering and exiting the property to minimize traffic conflicts . In addition, Trucks will be required to utilize City -designated truck routes to and from the Project site.

Approved truck routes will be posted on the property. Future tenants will be responsible for training drivers on truck routes.
• Anti-idling Signs: Anti-idling signs will be posted on- site to stipulate a 5-minute idling restriction pursuant to Title 13 of the California Cod of Regulations Section 2485.

Further details on these Project design components are described in further detail below.

Architecture and Design Features

Development of the warehouse building would replace the existing building with a new modern building elevation. As shown in Figure 5, Architectural Elevations, the proposed building would consist of concrete tilt-up panels. The building would feature a neutral color palette consisting of grays with white accents and green reflective glazing. The east elevation would consist of 27 dock doors (cross-dock configuration). The 45- foot-tall building would be setback approximately 82 feet from W. Struck Avenue. The final design and architectural style of the proposed buildings are subject to review and approval by the City’s Design Review Committee.

Site Access

Vehicular access to the site is currently provided via three two -way driveways in the northern portion of the site along W. Struck Avenue. Under the Revised Project, vehicular access to the Project site would be provided via three driveways at the site’s northern border along W. Struck Avenue. Truck access would be provided at the northeast and northwest corner of the Project site.

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Truck Trailer Routes

The proposed building would generate truck -trailer trips, and trucks would be required to utilize City-designated truck routes to and from the Project site. The implementation of the Revised Project would not require widening of surrounding roadways to accommodate truck-trailer traffic.

Truck-trailers would travel to and from the site from SR -57 at Katella Avenue. Katella Avenue adjacent to the Project is identified as a truck route. Consistent with the Original Project, t ruck- trailer travel would be limited to:

• Truck-trailers exiting the site would travel west on W. Struck Avenue, turn right onto northbound Batavia Street and turn left onto westbound Katella Avenue to access SR-57.

• Truck-trailers entering the site would exit SR-57 at Katella eastbound, turn right at Batavia Street southbound, and turn left onto W. Struck Avenue eastbound.

• Traveling eastbound from SR -57 on Katella Avenue, truck -trailers would be prohibited from turning right onto W. Struck Avenue to access the site. West of Batavia Street, all eastbound and westbound truck-trailer movement will occur on Katella Avenue.

Landscaping, Lighting, and Walls

As depicted in Figure 6, Conceptual Landscape Plan, the Project Applicant will incorporate ornamental landscaping along the southern, western, northeastern portion of the site and along the site’s frontage near W. Struck Avenue. The proposed landscaping includes a variety of new trees, shrubs, accents, and groundcover. The Project would be required to comply with the landscape standards established in the OMC (Chapter 16.50, Landscape Requirements).

Exterior lighting would be installed on- site, as necessary, for safety and security. Decorative architectural lighting would also be installed to accent building entries as focal points throughout the site.

All existing chain link fence around the Project site would be removed and replaced. The Project Applicant would install an approximately 6-foot-high metal fencing along the Project site’s perimeter to enclose the proposed building and parking area. An 8- foot-high screen wall is proposed to enclose the truck court, and loading dock area. The fence would also serve as a safety precaution 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.

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Construction and Phasing

The Project would be developed in one phase for a duration of 16 months. Project construction activities include, but are not limited to the following:

• Demolition of existing pavements
• Demolition of existing structures
• Grading and re-compaction of on-site soils
• Grading to include pavement forming and pouring
• Installation of new utility infrastructure to support the new building • Building construction and architectural coating
• Concrete paving of new parking areas
• Installation of new security perimeters

As shown in Figure 7, Proposed Grading Plan, approximately 1,725 cubic yards of exported soil is required to balance the Project site.

Dry Utilities and Service Systems

Plans for utilities that would serve the Project would include the provision of electricity by Southern California Edison (SCE), Southern California Gas Company (SoCal Gas) for natural gas, telecommunications facilities including telephone and fiber-optic lines by AT&T, and solid waste by CR&R Environmental Services. All new dry utility infrastructure would be installed underground and within the Project site.

Infrastructure Improvements

Water

The City’s Public Works Water Division provided potable water service to the former manufacturing facility and would do so for the Revised Project. As shown in Figure 8, Proposed Utility Plan, potable water to the site is provided via internal water lines that connect to the existing public water 10-inch and 12-inch mains along W. Struck Avenue.

Wastewater

The City’s Public Works Department provided wastewater collection services to the former manufacturing facility and would do so for the Revised Project. Wastewater collected by the City flows through a system of regional trunk lines to Reclamation Plant No. 1 (located within the City of Fountain Valley) and No.2 (located within the City of Huntington Beach) for treatment; the reclamation plants are owned and operated by the Orange County Sanitation District (OCSD).

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As shown in Figure 8, Proposed Utility Plan , the Revised Project would include internal wastewater lines that connect to the existing public 8 -inch sewer main along W. Struck Avenue that is operated by the City’s Public Works Department. Proposed wastewater infrastructure improvements would entail trenching and exposing existing lines on -site for connection, and installing new lines, and a break- in connection to the exis ting mainline. No off-site sewer main construction or upsizing would be required to accommodate the Revised Project. However, some construction may occur within W. Struck Avenue to make the necessary infrastructure connections. The sewer main within W. Struck Avenue would continue to be maintained by the City, and the proposed lateral connections and other on- site sewer lines would be maintained by the property owner.

Stormwater

Stormwater on site would emulate the existing drainage pattern and will flow from the south to the north and to the northwest corner . The Revised Project will incorporate ribbon gutters along the proposed trailer parking areas on the south and east sides of the proposed building. Multiple inlets along the western and eastern ribbon gutter are proposed to collect flows and deposit them into the onsite storm drain facilities. All onsite runoff that is captured would be directed towards a proposed manhole located in the northwest corner of the Project site. The outlet structure is designed to divert the minimum water quality flow rate towards the proposed Modular Wetlands Systems (MWS) vaults in order to treat for water quality requirements.

A detailed description of the proposed drainage system for the Project site is provided in the Revised Project’s Water Quality Management Plan (WQMP) (Appendix B.1) and Drainage Study (Appendix B.2).

Other Public Agencies Whose Approval is Required (Responsible or Trustee Agencies):

The City of Orange, as Lead Agency, has discretionary authority over the Revised Project . To implement the Revised Project, the Applicant would need to obtain the following permits/approval from the City:

• Certification of the Addendum to the 534 W. Struck Ave EIR (Addendum – 1889) • Conditional Use Permit - 3221
• Major Site Plan Review - 1166
• Design Review 5140
• Demolition permits for on-site structures and other improvements • Grading and Building Permits to grade and construct the Revised Project

2.0 ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED
The environmental factors checked below would be potentially affected by this project , involving at least one impact that is a "Potentially Significant Impact" as indicated by the checklist on the following pages. □ Aesthetics □ Minera l Resources
□ Agriculture & Forest Resources □ Noise
□ Air Quality □ Population/Housing
~ Biological Resources □ Public Services
~ Cultural Resources □ Recreation
□ Energy □ Transportation
~ Geology/Soils ~ Tribal Cultural Resources
□ Greenhouse Gas Emissions □ Utilities/Service Systems
0 Hazards & Hazardous Materials □ Wildfire
□ Hydrology/Water Quality □ Mandatory Findings of Significance □ Land Use/Planning
DETERMINATION. On the basis of this initial evaluation:

1. I find that the project could not have a significant effect on the environment , and a NEGATIVE D DECLARATION will be prepared.

2. I find that although the proposed project could have a significant effect on the environment, there D will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.

3. I find the proposed project may have a significant effect on the environment, and an D ENVIRONMENT AL IMP ACT REPORT is required.

4. I find that the proposed project may have a "potentially significant impact" or "potentially D significant unless mitigated impact" on the environment, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets.

An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.

5. I find that although the propo sed project could have a significant effect on the environment, ~ because all potentially significant effects (a) have been analyzed adequately in an earlier EIR or Negative Declaration pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or Negative Declaration, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required.

City of Orange
Signature Lead Agency
MomuJvt ~Ghwarfi-, Sintor \)\~nncv
Name, TiVle 1 Date
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3.0 ENVIRONMENTAL IMPACT ISSUES:

1. AESTHETICS.

Except as provided in Public Resources Code Section 21099, would the project:

(c) In non -urbanized areas, s ubstantially 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 or other regulations governing scenic quality?

(d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?

Impact Analysis

a) Have a substantial adverse effect on a scenic vista?

Significance Determination: No Impact

2023 Certified EIR Finding: The 2023 Certified EIR disclosed that 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 area is within a highly urbanized industrial area. The 2023 Certified EIR concluded that the Project site does not contain any scenic resources and there are no scenic vistas within proximity to the site .

Implementation of the Original Project would not have an impact to a scenic vista.

Analysis of the Revised Project: The visual conditions of the Project site and surrounding area are similar to the conditions that were described in the 2023 Certified EIR. As disclosed above, 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 remains within a highly urbanized industrial area. Consistent with the findings of the 2023 Certified EIR, the Project site does not contain any scenic resources and there are no scenic vistas within proximity to the site. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway?

Significance Determination: No Impact

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2023 Certified EIR Finding: The 2023 Certified EIR concluded that implementation of the Original Project would not have the potential to substantially damage scenic resources within a State scenic highway corridor. Due to site distance and topography, implementation of the Original Project would not have the potential to substantially damage scenic resources within City designated scenic corridors.

According to 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. No impacts would occur.

Analysis of the Revised Project: Consistent with the findings of the 2023 Certified EIR, due to Project site distance and topography, the Revised Project would have no impact on any scenic resources within a State scenic highway corridor and, likewise, would have no impact on any scenic resources within a local scenic route. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

c) In non-urbanized areas, 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 or other regulations governing scenic quality?

Significance Determination: Less than Significant Impact.

2023 Certified EIR Finding: The 2023 Certified EIR stated that the Project site is within an urbanized area of the City. The Original Project would not conflict with the Project site’s underlying General Plan and zoning classification, zoning development standards, or other regulations governing scenic quality.

Impacts would be less-than-significant.

Analysis of the Revised Project: As discussed above, the Project site is within an urbanized area of the City. Because the Project site is in an urban area, the potential impacts of the Revised Project under this threshold are assessed based on whether the Revised Project would conflict with applicable zoning and other regulations governing scenic quality. The Revised Project is consistent with the City’s General Plan and zoning designations for the Project site.

City of Orange General Plan

Table 1, General Plan Consistency Analysis, below discusses the Revised Project’s consistency with the General Plan goals related to scenic quality.

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

• 1.0 Floor Area Ratio (FAR)

No Conflict . 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 overall site plan (Figure 4), the Revised Project would have a FAR of 0.486. Therefore, the Revised Project would not exceed the maximum permitted FAR.

Height Limit

• 3 Stories

No Conflict. The proposed building would be two-stories and constructed up to a height of 45 feet. The Revised
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.

No Conflict. The Revised Project would redevelop the site with a modern building . The Revised Project’s proposed style and design would be compatible with the surrounding environment.

Consistent with the findings of the 2023 Certified EIR , the Revised Project would not conflict with the site’s underlying General Plan land use classification or other regulations governing scenic quality.

City of Orange Municipal Code (OMC)

The Project site is zoned Industrial (M-2) and as such, the Revised 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 is to encourage industrial facilities and related uses while recognizing the potential for compatibility between uses through appropriate development and performance standards (Orange, 2024). 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 2 , Zoning Development Standards Consistency Analysis , addresses the Revised Project’s consistency with applicable development standards outlined in the OMC. Consistent with the findings of the 2023 Certified EIR, the Revised Project would not conflict with the site’s underlying General Plan and zoning classification, zoning development standards, or other regulations governing scenic quality.

Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

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

• 45 feet
No Conflict . The Revised Project involves the
redevelopment of the Project site with up to a 45-foot-tall building. The proposed building would not exceed the
Zoning Development Standards ’ height limit of 45 ft.

Accordingly, the Revised 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
No Conflict. The Project site is located immediately south of W. Struck Avenue, a local street. The Revised Project’s closest building setback to W. Struck Avenue is
approximately 82 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 would 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.

No Conflict . The Revised Project would incorporate a
Project-specific landscape plan, as shown in Figure 6, that is designed to be in accordance with the City’s Landscape Ordinance. The Revised Project’s proposed landscaping
would include drought tolerant trees, shrubs, and
groundcover. Landscaping would be provided along the
site’s northern, northeastern, western, and southern
perimeter. Additionally, o rnamental trees and shrubs are proposed along the proposed building’s northern,
northeastern, and northwestern, perimeters.

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 suf ficient 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.

No Conflict. Roof-mounted mechanical equipment would
be shielded and screened from view from the neighboring property and W. Struck Avenue . The proposed shielding
and screening would be integrated with the building’s
design to seamlessly screen the mechanical equipment. The Revised Project does not propose to locate mechanical
equipment in yard or setback areas.

Trash enclosures

• 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.

No Conflict . The two trash enclosure s proposed for the Revised Project would screen views on 3 sides with a 6 - foot-high wall and would provide a visually opaque self - latching gates to access the trash enclosures.

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Applicable Development Standard Revised Project Consistency Undergrounding of Utilities

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

No Conflict. The Revised Project would install new utility lines underground connecting to the existing utility mains within W. Struck Avenue.

Mitigation Measures: Mitigation measures are not required.

d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?

Significance Determination: Less than Significant Impact.

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Original Project’s proposed lighting would be similar to existing conditions; therefore, implementation of the Original Project would not introduce new sources of light that would substantially affect day or nighttime views in the area. The Original Project’s proposed building materials would not result in potential glare impacts within the Project site or surrounding areas, and notably at the street level. Implementation of the Original Project would not introduce new sources of glare that would substantially affect day or nighttime views in the area, and impacts would be less than significant.

Analysis of the Revised Project: Implementation of the Revised Project would result in the development of a light industrial warehouse building. Consistent with the findings of the 2023 Certified EIR, the Revised Project would introduce new sources of light as necessary for security, safety, and wayfinding. The Revised Project’s proposed lighting would be similar to the previous uses and existing surrounding conditions. The Revised Project would be required to comply with the same outdoor lighting requirements that were applied to the Original Project and that were disclosed in the 2023 Certified EIR.

Therefore, implementation of the Project would not introduce new sources of light that would substantially affect day or nighttime views in the area.

The proposed building is located at the terminus of a cul -de-sac within a buildout area and would be constructed of concrete tilt-up walls. The Revised Project’s proposed building materials would not result in potential glare impacts within the Project site or surrounding areas, and notably at the street level .

Low-reflective windows would be provided at the proposed office areas. Implementation of the Revised Project would not introduce new sources of glare that would substantially affect day or nighttime views in the area. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

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2. AGRICULTURE & FOREST RESOURCES.

(In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Department of Conservation as an optional model to use in assessing impacts on agriculture and farmland.) In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the Californi a Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board.) Would the project:

(b) Conflict with existing zoning for agricultural use, or a Williamson Act contract?
(c) 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 timberland zoned Timberland Production (as defined by Government Code section 51104(g))?

(d) Result in the loss of forest land or conversion of forest land to non- forest use?
(e) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use?

Impact Analysis:

a) 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?

Significance Determination: No Impact.

2023 Certified EIR Finding: The 2023 Certified EIR concluded the nearest Farmland to the Project site is located approximately 0.43 miles north; this land is classified by the California Department of Conservation (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, but may include non- irrigated orchards or vineyards as found in some climatic zones in California . Due to the Project site’s distance from designated Farmland, the Original Project would not have the potential to convert the Farmland to non- agricultural use. The Original 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.

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Analysis of the Revised Project: The Revised Project’s development footprint is the same as the Original Project’s development footprint analyzed under the 2023 Certified EIR. Consistent with the findings of the 2023 Certified EIR, the Project site does not contain a ny lands designated as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance as mapped by the DOC Farmland Mapping and Monitoring Program. The Revised Project would not convert mapped farmland to nonagricultural use. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

b) Conflict with existing zoning for agricultural use, or a Williamson Act contract?

Significance Determination: No Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Project site is not under a Williamson Act contract. Therefore, implementation of the Original Project does not have the potential to conflict with an existing Williamson Act contract. No impacts would occur.

Analysis of the Revised Project: As discussed previously, t he 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. Consistent with the findings of the 2023 Certified EIR, the Project site is not under a Williamson Act contract . Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

c) 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 timberland zoned Timberland Production (as defined by Government Code section 51104(g))?

Significance Determination: No Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that there are no lands within the City that are zoned for forest land, timberland, or timberland zoned Timberland Production. Therefore, the Original Project does not have the potential to conflict with existing zoning or rezoning of forest land, timberland, or timberland zoned Timberland Production. No impacts would occur.

Analysis of the Revised Project: 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). Consistent with the findings of the 2023 Certified EIR, the Project does not have the potential to conflict with existing zoning or rezoning of forest land, timberland, or timberland zoned Timberland Production. Therefore, the Revised

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Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

d) Result in the loss of forest land or conversion of forest land to non-forest use?

Significance Determination: No Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Original Project would not result in the loss of forest land or conversion of forest land to a non-forest use. No impacts would occur.

Analysis of the Revised Project: As discussed under the Agricultur e and Forest Resources Threshold c, the Project site is zoned M -2 and there are no lands within the City that are zoned forest land.

Consistent with the findings of the 2023 Certified EIR , the Revised Project would not result in the loss of forest land or conversion of forest land to a non-forest use. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

e) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use?

Significance Determination: No Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that due to the Project site’s distance from the Unique Farmland, the Original Project does not have the potential to convert Farmland to non- agricultural use. No impacts would occur.

Analysis of the Revised Project: As previously discussed under Agriculture and Forest Resources Threshold a, the Project site is located approximately 0.43 miles south of Unique Farmland. Additionally, the Project site is within an urbanized area of the City that contains little open space. Consistent with the findings of the 2023 Certified EIR, due to the site’s distance from the Unique Farmland, the Revised Project does not have the potential to convert Farmland to non- agricultural use. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

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3. AIR QUALITY.

(Where available, the significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make the following determinations.) Would the project:

Was
Impact
Analyzed
in the 2023
Certified
EIR?
New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
New
Information
Requiring
New
Analysis or
Verification
?
Does
2023
Certified
EIR
Address/
Resolve
Impacts?
(a) Conflict with or obstruct implementation of the applicable air quality plan?
(b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non -attainment under an applicable federal or state ambient air quality standard?

(c) Expose sensitive receptors to substantial pollutant concentrations? (d) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?

Impact Analysis:

Urban Crossroads, Inc. (Urban Crossroads) prepared a Supplemental Air Quality/Greenhouse Gas/Energy/Health Risk Assessment Memorandum for the Revised Project that involves evaluation of the potential criteria and hazardous air pollutant emissions that could result from the Revised Project’s construction and operation. The memorandum was prepared to compare the revised emissions, health risk, and energy use to the Original Project’s emissions . This memorandum is included as Technical Appendix A to this EIR Addendum and its findings are incorporated into the analysis presented herein.

a) Conflict with or obstruct implementation of the applicable air quality plan?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Original Project would not have the potential to result in or cause National Ambient Air Quality Standards (NAAQS) or California Ambient Air Quality Standards (CAAQS) violations. The Original Project’s proposed uses are consistent with the General Plan land use designation and would not exceed the regional or localized construction and operational thresholds. Therefore, the Original Project is consistent with the 2016 Air Quality Management Plan (AQMP).

Analysis of the Revised Project: The Project site is within the South Coast Air Basin ( SCAB), which is governed by the South Coast Air Quality Management District (South Coast AQMD) . Since certification of the 2023 Certified EIR, a new AQMP was adopted by the South Coast AQMD . In December 2022, South Coast AQMD released the Final 2022 AQMP (2022 AQMP). The 2022 AQMP continues to evaluate current integrated strategies and control measures to meet the CAAQS, as well as explore new and innovative methods to reach its goals. Similar to the 2016 AQMP, the 2022 AQMP incorporates scientific and technological information and planning assumptions, including the 2020- 2045 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), a planning document that supports the integration of land use and transportation to help the region meet the federal California Ambient Air (CAA) requirements.

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Criteria for determining consistency with the AQMP are defined in Chapter 12, Section 12.2, and Section

12.3 of the South Coast AQMD’s 1993 CEQA Air Quality Handbook. The Revised Project’s consistency with 2022 AQMP and these criteria is discussed below.

Consistency Criterion No. 1: The Project will not result in an increase in the frequency or severity of existing air quality violations or cause or contribute to new violations or delay the timely attainment of air quality standards or the interim emissions reductions specified in the AQMP.

Construction Impacts – Consistency Criterion 1

The violations that Consistency Criterion No. 1 refers to are the CAAQS and NAAQS. CAAQS and NAAQS violations c ould occur if regional or localized significance thresholds are exceeded. As evaluated under Air Quality Threshold b, below, in comparison to the Original Project, Volatile Organic Compounds (VOC) and Carbon Monoxide (CO) construction emissions would increase, nitrogen oxides (NOx) would decrease, and no change in emissions would occur for sulfur oxides (S Ox), particulate matter that is 10 micrometers or less in diameter (PM 10), and particulate matter that is 25 micrometers or less in diameter (PM2.5). The Revised Project localized construction emissions would remain the same when compared to the Original Project. Although there would be increases in some criteria pollutant emissions, the Revised Project’s regional and localized construction-source emissions would not exceed applicable regional significance threshold and localized significance threshold (LST).

Operational Impacts – Consistency Criterion 1

As evaluated under Air Quality Threshold b, below, in comparison to the Original Project, NO x and SOx
operational emissions would be reduced while VOC, CO, PM10 and PM2.5 would slightly increase under the Revised Project. The Revised Project localized operational emissions would result in increased pollutant concentrations of CO, NO
X, PM10, and PM2.5 when compared to the Original Project. Although there would be increases in several pollutant emissions, the Revised Project would not exceed the applicable regional significance thresholds and LST thresholds for operational activity . Therefore, the Revised Project would not conflict with the AQMP according to this criterion . Based on the preceding discussion, the Revised Project is determined to be consistent with the first criterion.

Consistency Criterion No. 2: The Project will not exceed the assumptions in the AQMP based on the years of Project build-out phase.

The 2022 AQMP demonstrates that the applicable ambient air quality standards can be achieved within the timeframes required under federal law. Growth projections from local general plans adopted by cities in the district are provided to the SCAG, which develops regional growth forecasts, which are then used to develop future air quality forecasts for the AQMP . Development consistent with the growth projections in City of Orange General Plan is consistent with the AQMP.

The Revised Project proposes to convert an existing manufacturing use to a light industrial warehouse use, which would be a similar type of industrial land use as the surrounding area and consistent with the underlying zoning and land use designations. A General Plan amendment or re-zoning would not be required. Because the Revised Project is consistent with the underlying land use designation, the number

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of employees generated at the Project site are anticipated within the growth projections and the development would not result in an unanticipated increase in population within the SCAB . Therefore, implementation of the Revised Project would not have the potential to substantially affect demographic projections beyond what is accounted for in the current 2022 AQMP. As such, the Revised Project is determined to be consistent with the second criterion.

AQMP Consistency Conclusion

Consistent with the Original Project, the Revised Project would not have the potential to result in or cause NAAQS or CAAQS violations. The Revised Project’s proposed use is consistent with the General Plan land use designation and would not exceed the regional or localized construction and operational thresholds as discussed above in Consistency Criterion 1. As such, the Revised Project is consistent with the AQMP (Urban Crossroads, 2024a). Impacts would be less than significant. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the maximum daily construction emissions (pounds per day) for VOC, NO
X, CO, SO X, PM10, and PM 2.5 are 14.50, 19.40, 31.00, 0.05,

5.45, and 2.78, respectively. The maximum daily operational emissions (pounds per day) in the summer for VOC, NO
X, CO, SOX, PM10, and PM2.5 are 3.07, 10.34, 30.77, 0.09, 1.96, and 0.55, respectively. The maximum daily operational emissions (pounds per day) in the winter for VOC, NO X, CO, SOX, PM10, and PM2.5 are 2.61, 10.71, 27.52, 0.09, 1.96, and 0.55, respectively. The 2023 Certified EIR concluded that the Original Project construction- and operational-related activities would not exceed the applicable South Coast AQMD regional thresholds of significance. As such, Original Project-related emissions would not violate South Coast AQMD air quality standards or contribute to the non-attainment of ozone standards in the SCAB, and impacts would be less than significant.

Analysis of the Revised Project: Similar to the Original Project, the Revised Project would contribute to local and regional air pollutant emissions during its construction (short- term) and operation (long- term). As discussed below, although the Revised Project would result in increases to s ome criteria pollutant emissions when compared to the Original Project, the Revised Project construction and operation would not result in exceedances of South Coast AQMD daily thresholds for Revised Project- specific impacts that could subsequently cause cumulatively considerable increase s in emissions of pollutants for which the SCAB is designated as non-attainment.

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Construction Impacts

Table 3 , Revised Project Construction Emissions, presents the criteria pollutant emissions from the Revised Project construction, as well as a comparison to the Original Project construction emissions. As shown below, in comparison to the Original Project, VOC and CO construction emissions would increase, NO
x would decrease, and no change in emissions would occur for SO x, PM 10, and PM 2.5.

Additionally, the Revised Project construction emissions would not exceed the regional numerical thresholds of significance established by the South Coast AQMD for any criteria pollutant and impacts would be less than significant . Therefore, the Revised Project would not result in the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects, other than those considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Table 3 Revised Project Construction Emissions
Year
Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
Summer
2025 0.69 14.80 23.90 0.04 2.68 1.20
Winter
2024 0.52 15.00 20.30 0.05 2.69 0.69
2025 1.19 17.90 31.70 0.05 5.45 2.78
2026 36.50 19.30 33.50 0.05 2.03 0.64
Maximum Daily Emissions 36.50 19.30 33.50 0.05 5.45 2.78 South Coast AQMD Regional Threshold 75 100 550 150 150 55 Threshold Exceeded? NO NO NO NO NO NO
2023 Certified EIR Analysis 14.50 19.40 31.00 0.05 5.45 2.78 Source: (Urban Crossroads, 2024a)

Operational Impacts

Table 4 , Revised Project Operational Emissions presents the criteria pollutant emissions that would result from operation of the Revised Project, as well as a comparison to operational emissions associated with the Original Project. In comparison to the Original Project, NO x and SOx operational emissions
would be reduced while VOC, CO, PM 10 and PM2.5 would slightly increase under the Revised Project.

Similar to the Original Project, the Revised Project emissions would remain below the South Coast AQMD regional significance thresholds and impacts would be less than significant. Therefore, the Revised Project would not result in the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects, other than those considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

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Table 4 Revised Project Operational Emissions
Operational Activities –
Summer Scenario
Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
Area Source 6.71 0.08 9.34 0.00 0.02 0.01
Energy Source 0.06 1.11 0.93 0.01 0.08 0.08
Mobile Source 0.92 7.15 10.60 0.07 3.57 0.99
On-Site Equipment Source 0.12 0.38 16.44 0.00 0.03 0.03 Total Maximum Daily Emissions 7.81 8.72 37.31 0.08 3.70 1.11 South Coast AQMD Regional Threshold 55 55 550 150 150 55 Threshold Exceeded? NO NO NO NO NO NO
2023 Certified EIR Analysis 3.07 10.34 30.77 0.09 1.96 0.55 Operational Activities –
Winter Scenario
Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
Area Source 5.18 0.00 0.00 0.00 0.00 0.00
Energy Source 0.06 1.11 0.93 0.01 0.08 0.08
Mobile Source 0.91 7.46 10.10 0.07 3.57 0.99
On-Site Equipment Source 0.12 0.38 16.44 0.00 0.03 0.03 Total Maximum Daily Emissions 6.27 8.95 27.47 0.08 3.68 1.10 South Coast AQMD Regional Threshold 55 55 550 150 150 55 Threshold Exceeded? NO NO NO NO NO NO
2023 Certified EIR Analysis 2.61 10.71 27.52 0.09 1.96 0.55 Source: (Urban Crossroads, 2024a)

Mitigation Measures: Mitigation measures are not required.

c) Expose sensitive receptors to substantial pollutant concentrations?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Original Project would not exceed the South Coast AQMD localized significance thresholds for assessing localized health impacts from criteria air pollutants during construction or operation. Table 5 , Original Project Localized Construction-Source Emissions and Table 6 , Original Project Localized Significance Summary of Operations presents the Original Project localized construction and operational emissions. Furthermore, Original Project construction and operation would not exceed South Coast AQMD’s cancer and non - cancer thresholds during construction or operation. Further, Original Project traffic would not create or result in a CO “hotspot.” Therefore, sensitive receptors would not be exposed to substantial pollutant concentrations due to the Original Project, and impacts would be less than significant.

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Table 5 Original Project Localized Construction-Source Emissions Construction
Activity Year Scenario
Emissions (lbs/day)
NOX CO PM10 PM2.5
Demolition 2023
Summer 11.90 18.20 1.84 0.44
Winter 11.90 18.20 1.84 0.44
Maximum Daily Emissions 11.90 18.20 1.84 0.44
South Coast AQMD Localized Threshold 81 485 8 5
Threshold Exceeded? NO NO NO NO
Site Preparation 2023
Summer n/a n/a n/a n/a
Winter 14.70 28.30 5.21 2.73
Maximum Daily Emissions 14.70 28.30 5.21 2.73
South Coast AQMD Localized Threshold 98 600 10 7
Threshold Exceeded? NO NO NO NO
Grading 2023
Summer n/a n/a n/a n/a
Winter 12.60 21.80 1.94 0.98
Maximum Daily Emissions 12.60 21.80 1.94 0.98
South Coast AQMD Localized Threshold 81 485 8 5
Threshold Exceeded? NO NO NO NO
Source: Table 4.1-7 of the 2023 Certified EIR

Table 6 Original Project Localized Significance Summary of Operations Scenario
Emissions (lbs/day)
NOX CO PM10 PM2.5
Summer 2.80 22.52 0.12 0.07
Winter 2.87 20.04 0.12 0.07
Maximum Daily Emissions 2.87 22.52 0.12 0.07
South Coast AQMD Localized Threshold 183 1,253 7 3
Threshold Exceeded? NO NO NO NO
Source: Table 4.1-8 of the 2023 Certified EIR

Analysis of the Revised Project:

Construction Emissions

As discussed under the Air Quality Threshold b, the Revised Project’s construction emissions would not exceed South Coast AQMD’s regional significance thresholds. Table 7 , Revised Project Localized Construction Emissions presents the localized criteria pollutant concentrations that would result from

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construction of the Revised Project. As was the case in the Original Project analysis, the Revised Project localized construction emissions analysis represents a worst -case scenario. Since the Revised Project construction limits are identical to the Original Project construction limits, t he results of the analysis indicate that the construction emissions from the Revised Project would remain the same when compared to the Original Project. The pollutant concentrations would remain below South Coast AQMD localized significant thresholds for all pollutants. Consistent with the Original Project, construction of the Revised Project would not result in the exposure of any sensitive receptors to substantial pollutant concentrations, and impacts would be less than significant.

Table 7 Revised Project Localized Construction Emissions On-Site Emissions
Emissions (lbs/day)
NOX CO PM10 PM2.5
Demolition
Maximum Daily Emissions 11.90 18.20 1.84 0.44
South Coast AQMD Localized Threshold 81 485 8 5
Threshold Exceeded? NO NO NO NO
2023 Certified EIR Analysis 11.90 18.20 1.84 0.44
Site Preparation
Maximum Daily Emissions 14.70 28.30 5.21 2.73
South Coast AQMD Localized Threshold 98 600 10 7
Threshold Exceeded? NO NO NO NO
2023 Certified EIR Analysis 14.70 28.30 5.21 2.73
Grading
Maximum Daily Emissions 12.60 21.80 1.94 0.98
South Coast AQMD Localized Threshold 81 485 8 5
Threshold Exceeded? NO NO NO NO
2023 Certified EIR Analysis 12.60 21.80 1.94 0.98
Source:(Urban Crossroads, 2024a)

Operational Emissions

As discussed under the Air Quality Threshold b, the Project’s operational emissions would not exceed South Coast AQMD regional significance thresholds. Table 8, Revised Project Localized Operational Emissions presents the localized criteria pollutant concentrations that would result from operation of the Revised Project. The results of the analysis indicate that operational emissions from the Revised Project would result in increased pollutant concentrations of CO, NO X, PM10, and PM 2.5. However, pollutant
concentrations would remain below South Coast AQMD localized significance threshold for all pollutants. Consistent with the Original Project, operation of the Revised Project would not result in the exposure of any sensitive receptors to substantial pollutant concentrations, and impacts would be less than significant.

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Table 8 Revised Project Localized Operational Emissions Scenario
Emissions (lbs/day)
NOX CO PM10 PM2.5
Maximum Daily Emissions 3.15 29.48 0.28 0.16
South Coast AQMD Localized Threshold 183 1,253 7 3
Threshold Exceeded? NO NO NO NO
2023 Certified EIR Analysis 2.87 22.52 0.12 0.07
Source: (Urban Crossroads, 2024a)

Health Risk Comparison

The Revised Project development footprint remains the same as what was analyzed in the 2023 Certified EIR. Thus, the sensitive receptors analyzed in the 2023 Certified EIR would be applicable to the Revised Project, see Figure 9, Sensitive Receptor Locations. Localized air quality impacts were evaluated at sensitive receptor land uses nearest the Project site. All distances are measured from the Project site boundary to the outdoor living areas (e.g., backyards) or at the building façade, whichever is closer to the Project site.

R1: Location R1 represents the City of Orange Department of Public Works at 637 W. Struck Avenue, approximately 96 feet north of the Project site. Receptor R1 is placed at the building façade.

R2: Location R2 represents the proposed multi-family residential project north of W. Struck Avenue, approximately 245 feet north of the Project site. Receptor R2 is placed at the planned future residential building façade.

R3: Location R3 represents OC HUB at 517 W. Struck Avenue, approximately 31 feet north of the Project site. Receptor R3 is placed at the future building façade.

R4: Location R4 represents the Citrus Grove Apartments at 1120 North Lemon Street, approximately 126 feet northeast of the Project site. Since there are no private outdoor living areas (backyards) facing the Project site, receptor R4 is placed at the building façade.

R5: Location R5 represents the existing residence at 618 West Collins Avenue, approximately 563 feet south of the Project site. Since there are no private outdoor living areas (backyards) facing the Project site, receptor R5 is placed at the building façade.

R6: Location R6 represents Meter Tech Services & Equipment located at 1035 N. Parker Street, approximately 22 feet west of the Project site. Receptor R6 is placed at the building façade.

The residential land use with the greatest potential exposure to Project operational- source diesel particulate matter (DPM) emissions is Location R4 which is located approximately 126 feet northeast of the Project site at an existing residence located at 1120 North Lemon Street.

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The worker receptor land use with the greatest potential exposure to Project operational -source DPM emissions is Location R6, which represents the potential worker receptor approximately 22 feet west of the Project site.

Table 9, Comparison of Original Project and Revised Project Cancer and Non-Cancer Risks presents a comparison in operational health risk and combined construction and operational health risk between the Original Project and the Revised Project. As shown below, cancer risks would decrease under the Revised Project construction and operational activities in comparis on to the Original Project. It should be noted that the cancer risk under the Revised Project remains below the South Coast AQMD significance threshold of 10 in one million. Non-cancer health risks would remain at less than 0.01 under all scenarios, below the South Coast AQMD significance threshold of 1.0.

Table 9 Comparison of Original Project and Revised Project Cancer and Non-Cancer Risks
Time Period Location
Maximum Lifetime Cancer Risk (Risk per Million)
Original Project Revised Project
Construction Cancer and Non-Cancer Risks

1.34 Year Exposure Maximum Exposed Sensitive Receptor1 2.36 2.01 Operational Cancer and Non-Cancer Risks
30 Year Exposure Maximum Exposed Sensitive Receptor1 0.62 0.55 25 Year Exposure Maximum Exposed Worker Receptor2 0.16 0.10 Construction and Operational Cancer and Non-Cancer Risks 30 Year Exposure Maximum Exposed Sensitive Receptor2 2.66 2.00 1Based on Location R4, located approximately 126 feet northeast of the Project site at an existing residence located at 1120 North Lemon Street.
2Based on Location R6, potential worker receptor approximately 22 feet west of the Project site.

Source: (Urban Crossroads, 2024a)

Consistent with the Original Project, the Revised Project would not exceed the South Coast AQMD localized significance thresholds for assessing localized health impacts from criteria air pollutants during construction or operation. Furthermore, Revised Project construction and operation would not exceed South Coast AQMD’s cancer and non -cancer thresholds during construction or operation. Therefore, sensitive receptors would not be exposed to substantial pollutant concentrations due to the Project, and impacts would be less than significant. Therefore, the Revised Project would not res ult in the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects, other than those considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary

Mitigation Measures: Mitigation measures are not required.

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d) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that although short-term construction activities and long -term operational land uses could produce objectionable odors, compliance with standard construction requirements and regulations established by the City of Orange and South Coast AQMD would reduce odor im pacts to less- than-significant levels. Near - and long-term odor impacts would be less than significant.

Analysis of the Revised Project: Similar to the Original Project, the Revised Project does not contain land uses typically associated with emitting objectionable odors. The Revised Project would be subject to standard construction and operational requirements, including the use of low -VOC architectural coatings as required by South Coast AQMD Rule 1113, Table of Standards; and compliance with South Coast AQMD Rule 402, Nuisance, which requires that a person shall not discharge air contaminants or other materials that would cause health or safety hazards to any considerable number of persons or the public. Consistent with the Original Project, odors associated with the Revised Project construction and operation would not adversely affect a substantial number of people, and Project impacts would be less than significant. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

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4. BIOLOGICAL RESOURCES.

Would the project:

Was Impact
Analyzed in
the 2023
Certified
EIR?
New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
New
Information
Requiring
New
Analysis or
Verification?
Does
2023
Certified
EIR
Address/
Resolve
Impacts?
(a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?

(b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?

(c) Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?

(d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?

(e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?

(f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?

Impact Analysis:

The physical conditions of the Project site are unchanged since approval of the 2023 Certified EIR in 2023. Therefore, the analysis below relies on information contained in the biological resources assessment prepared for the Original Project as this information continues to be relevant to the Project Site (refer to 2023 Certified Draft EIR Technical Appendix C). As noted earlier in this EIR Addendum, the 2023 Certified EIR and its technical appendices, including the biological resources assessment, are incorporated by reference pursuant to pursuant to CEQA Guidelines Section 15150.

a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fis h and Game or U.S. Fish and Wildlife Service?

Significance Determination: No Impact

2023 Certified EIR Finding: The 2023 Certified EIR determined that no federal or State listed plant or wildlife species were observed within the study area. The Project site does not include U.S. Fish and Wildlife Service (USFWS)-designated critical habitat for plants or wildlife and the Project site does not include the substantive habitat requirements necessary to support special -status plants and wildlife. As

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such, implementation of the Original Project would not have the potential to have an adverse effect either directly or indirectly through habitat modifications on any species identified as a candidate, sensitive, or special-status species in the local or regional plans, policies or regulation, or by the California Department of Fish and Wildlife. No impacts would occur.

Analysis of the Revised Project: As discussed previously, the condition of the Project site is the same as what was described and analyzed under the 2023 Certified EIR. The Project site is in the western portion of the City and is fully developed with a manufacturing facility. Additionally, t he properties surrounding the Project site are fully developed and urbanized. Consistent with the findings of the 2023 Certified EIR, there are no natural habitats or sensitive species on the Project site or immediately surrounding area. As such, implementation of the Revised Project would not have the potential to have an adverse effect either directly or indirectly through habitat modifications on any species identified as a candidate, sensitive, or special status species in the local or regional plans, policies or regulation, or by the California Department of Fish and Game and Wildlife Service. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addr essed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?

Significance Determination: No Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Project site is located approximately 1.9 miles north of the Santiago Creek. No riparian, river, or obvious indicators of a well- defined water conveyance bed, bank, or channel were detected within the Project site. Therefore, implementation of the Original Project would not have an adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service.

Analysis of the Revised Project: As discussed previously, the condition of the Project site is the same as what was described and analyzed under the 2023 Certified EIR . The Project site is located approximately 1.9 miles north of the Santiago Creek and there are no other riparian habitat or other sensitive natural communities present on the Project site or within the site’s vicinity. Consistent with the findings of the 2023 Certified EIR, implementation of the Revised Project would not have an adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or U.S. Fish and Wildlife Service.

Mitigation Measures: Mitigation measures are not required.

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c) Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?

Significance Determination: No Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Project site and surrounding
area are fully developed and do not contain any wetlands. The nearest wetland habitat to the Project site is the Santiago Creek located approximately 1.9 miles south. Therefore, the implementation of the Original Project would not have an adverse effect on S tate or federally protected wetlands. No impacts would occur.

Analysis of the Revised Project: As discussed previously, the condition of the Project site is the same as what was described and analyzed under the 2023 Certified EIR. The Project site and surrounding area are fully developed and do not contain any wetlands . The nearest wetland habitat to the Project site is the Santiago Creek located approximately 1.9 miles south. Consistent with the findings of the 2023 Certified EIR, the implementation of the Project would not have an adverse effect on state or federally protected wetland s. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?

Significance Determination: Less than Significant Impact with Mitigation Incorporated

2023 Certified EIR Finding: The 2023 Certified EIR concluded that there are no areas within the Original Project’s vicinity which could function as a wildlife corridor or nursery site for wildlife.

Therefore, implementation of the Original Project would not have the potential to interfere with the movement of any native resident or migratory fish or wildlife species with established native resident or migratory wildlife corridors or impede the use of native wildlife nursery sites.

No nesting birds, remnant raptor nests, or bat guano were detected within the Project site. The Original Project required removal of existing ornamental trees within the northern portion of the site. The 2023 Certified EIR concluded that in order to reduce the Original Project’s potential impacts on migratory birds, the Project would implement Mitigation Measure s (MM) 4.2-1 and 4.2-2, which requires a pre - construction nesting bird clearance survey to determine the presence/absence, location, and status of any active nests on or adjacent to the Project site. If the nesting bird clearance survey indicates the presence of nesting birds, MM 4.2 -1 requires buffers to ensure that any nesting birds are protected according to the MBTA. MM 4.2-2 requires training all field staff on applicable local, State, and federal regulatory requirements, environmental laws, and regulations associated with working around biological resources.

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With the implementation of MM 4.2-1 and 4.2-2, the Project’s potential construction-related impacts to migratory birds would be less than significant.

Analysis of the Revised Project: The Project site is fully developed within an urbanized setting and is located outside the identified wildlife corridors. Consistent with the findings of the 2023 Certified EIR, there are no areas within the Revised Project’s vicinity which could function as a wildlife corridor or nursery site for wildlife. Therefore, implementation of the Revised Project would not have the potential to interfere with the movement of any native resident or migratory fish or wildlife species with established native resident or migratory wildlife corridors or impede the use of native wildlife nursery sites.

The Revised Project requires removal of existing ornamental trees within the northern portion of the site.

Consistent with the findings of the 2023 Certified EIR, in order to reduce the Revised Project’s potential impacts on migratory birds, the Revised Project would implement 2023 Certified EIR MM 4.2-1 and MM 4.2-2. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures:

MM 4.2-1 In the event that vegetation and tree removal should occur between January 15 and September 15, the Project Applicant shall retain a qualified biologist to conduct a nesting bird survey no more than 3 days prior to commencement of construction activities . The biologist conducting the clearance survey shall document the negative results if no active bird nests are observed on the Project site or within the vicinity during the clearance survey with a brief letter report, submitted to the City of Orange Commun ity Development Department prior to construction, indicating that no impacts to active bird nests would occur before construction can proceed. If an active avian nest is discovered during the pre-construction clearance survey, construction activities shall stay outside of a 200-foot buffer around the active nest. For listed and raptor species, this buffer shall be 500-feet. A biological monitor shall be present to delineate the boundaries of the buffer area and to monitor the active nest to ensure that nesting behavior is not adversely affected by the construction activity. Prior to the commencement of construction activities and the issuance of any permits, results of the pre- construction survey and any subsequent monitoring shall be provided to the City of Orange Community Development Department.

MM 4.2-2 Prior to approval of a grading permit, a note shall be placed on grading plans that “no personnel working within Project limits will “take” or destroy plants, animals, or active nests (or eggs) of birds that are protected under the Federal or State Endangered Species Acts and Migratory Bird Treaty Act (MBTA).” During pre -construction surveys, a biologist shall train all field staff on appliable local, state, and federal regulatory requirements, environmental laws, and regulations associated with wo rking around biological resources. Verification of training shall be provided to the Community Development Director.

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e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Original Project would not conflict with any local policies or ordinances protecting biological resources following compliance with OMC Section 12.32.030 and impacts would be less than significant.

Analysis of the Revised Project: The Revised Project would result in the removal of ornamental trees.

According to OMC Section 12.32.030, the Project Applicant would be required to obtain a Tree Removal Permit. According to OMC Section 12.32.060, the Revised Project’s ornamental trees are not considered Historical Trees. Consistent with the findings of the 2023 Certified EIR , the Revised Project would not conflict with any local policies or ordinances protecting biological resources following compliance with OMC Section 12.32.030. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?

Significance Determination: No Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that implementation of the Original Project does not have the potential to conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation plan. No impacts would occur.

Analysis of the Revised Project: According to General Plan EIR Figure 5.4- 2, the Project site is not within an Natural Community Conservation Planning ( NCCP) Habitat Reserve Area (Orange, 2010a).

No other approved local, regional, or State habitat conservation plans apply to the Project site. Consistent with the findings of the 2023 Certified EIR, implementation of the Revised Project does not have the potential to conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation plan. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, oth er than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

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5. CULTURAL RESOURCES.

Would the project:

Was
Impact
Analyzed
in the 2023
Certified
EIR?
New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
New
Information
Requiring
New Analysis
or
Verification?
Does
2023
Certified
EIR
Address/
Resolve
Impacts?
(a) Cause a substantial adverse change in the significance of a historical resource pursuant to in §15064.5?
(b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5?
(c) Disturb any human remains, including those interred outside of dedicated cemeteries?

The physical conditions of the Project site are unchanged since approval of the 2023 Certified EIR in 2023. Therefore, the analysis below relies on information contained in the cultural and paleontological resources report prepared for the Original Project as this information continues to be relevant to the Project Site (refer to 2023 Certified Draft EIR Technical Appendix D). As noted earlier in this EIR Addendum, the 2023 Certified EIR and its technical appendices are incorporated by reference pursuant to pursuant to CEQA Guidelines Section 15150.

Impact Analysis:

a) Cause a substantial adverse change in the significance of a historical resource pursuant to in §15064.5?

Significance Determination: No Impact

2023 Certified EIR Finding: The 2023 Certified EIR disclosed that there were two potential historic resources were recorded within one-half mile of the Original Project: P-30-176663 and P-30-159932 but due to the Project site’s location and limited physical disturbance area, implementation of the Original Project does not have the potential to result in a substantial adverse change to these resources. The Project site’s existing structures are not 50 years old and do not meet the criteria listed above and, therefore, are not considered historically significant. Therefore , redevelopment of the Project site would not impact historical resources; no impacts would occur.

Analysis of the Revised Project: As discussed previously, the condition of the Project site is the same as what was described and analyzed under the 2023 Certified EIR .

No sites within the Revised Project
are designated as a historic resource nor is the Project site proposed as a historic resource. Additionally, no listed or designated historical resources are in proximity to the Project site; most of the resources identified are in the Old Towne Historic District and Plaza District (Orange, 2015c). Consistent with the findings of the 2023 Certified EIR, the Project site’s existing structures are not 50 years old and are not considered historically significant . Redevelopment of the Project site would not impact historical resources; no impacts would occur. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

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b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5?

Significance Determination: Less than Significant Impact with Mitigation Incorporated

2023 Certified EIR Finding: The 2023 Certified EIR determined that given the highly disturbed condition of the Project site and its surroundings, the potential for the Project’s construction activities to affect an unidentified archaeological resource is considered low. However, while unlikely, the presence of previously undiscovered subsurface archaeological resources on the Project site remains possible . It is possible that subsurface disturbance would occur at levels not previously disturbed (e.g., deeper excavation) or may uncover undiscovered archaeological resources at the site . Therefore, impacts are potentially significant.

Implementation of Mitigation Measure MM 4.3 -1 would ensure the proper identification and subsequent treatment of any significan t archaeological resources that may be encountered during ground- disturbing activities associated with Project grading activities. With implementation of the required mitigation, the Project’s potential impacts to important archaeological resources would be reduced to less-than-significant.

Analysis of the Revised Project: As discussed previously, the condition of the Project site is the same as what was described and analyzed under the 2023 Certified EIR.

The Project site is developed with a
manufacturing facility and associated parking within an urbanized portion of the City and is surrounded by existing industrial uses. Because the Project site is developed, the site was subject to construction and ground-disturbing activities similar to that which would occur under the Revised Project. Similar to the Original Project, under the Revised Project, a potentially significant impact would occur if a known or unknown archaeological resource were removed, altered, or destroyed as a result of the pro posed development.

Consistent with the findings of the 2023 Certified EIR, t he Revised Project would implement MM 4.3- 1, which would ensure that the Project’s potential impacts on archaeological resources less than significant. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures:

MM 4.3-1 In the event a potentially significant cultural resource is encountered during subsurface earthwork activities, all construction activities within a 100 -foot radius of the find shall cease and workers should avoid altering the materials until a qualified archaeologist who meets the Secretary of Interior’s Professional Qualification Standards for archaeology has evaluated the resource . The Applicant shall include a standard inadvertent discovery clause in every construction contract to inform contra ctors of this requirement. Any previously undiscovered resource found during construction -related activities shall be recorded on the appropriate Department of Parks and Recreation (DPR) forms and evaluated for significance in terms of CEQA criteria by a qualified archaeologist .

Potentially significant cultural resources consist of but are not limited to stone, bone, glass, ceramics, wood, or shell artifacts, or features including hearths, structural remains,

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or historic dumpsites . If the resource is determined to be significant under CEQA Guidelines Section 15064.5, the qualified archaeologist shall prepare and implement a research design and archeological data recovery plan that will capture those categories of data for which the s ite is significant in accordance with Section 15064.5 of the State CEQA Guidelines. The archaeologist shall also perform appropriate technical analyses, prepare a comprehensive report complete with methods, results, and recommendations, and provide for the permanent curation or repatriation of the recovered resources in cooperation with the designated most likely descendant as needed. The report shall be submitted to the City of Orange, the South-Central Coastal Information Center, and the State Historic Preservation Office, if required.

c) Disturb any human remains, including those interred outside of dedicated cemeteries?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that in the unlikely event that human remains are discovered during Project grading or other ground disturbing activities, the Project would be required to comply with the applicable provisions of California Health and Safety Code Section 7050.5 and California P ublic Resources Code Section 5097 et seq . Mandatory compliance with State law would ensure that any discovered human remains are appropriately treated and would preclude the potential for significant impacts.

Analysis of the Revised Project:

As with the Original Project, discovery of human remains under the Revised Project is unlikely during construction due to the level of past disturbance in the City. Consistent with the findings of the 2023 Certified EIR, the Revised Project would be required to comply with the applicable provisions of California Health and Safety Code Section 7050.5 and California Public Resources Code Section 5097 et seq to ensure impacts to human remains are less than significant.

Mitigation Measures: Mitigation measures are not required.

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6. ENERGY.

Would the project:

(b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency?

Impact Analysis:

Urban Crossroads, Inc. (Urban Crossroads) prepared a Supplemental Air Quality/Greenhouse Gas/Energy/Health Risk Assessment Memorandum for the Revised Project that involves evaluation of the potential criteria and hazardous air pollutant emissions that could result from the Revised Project’s construction and operation. The memorandum compared the Revised Project’s energy use to the Original Project’s emissions. This memorandum is included as Technical Appendix A to this EIR Addendum and its findings are incorporated into the analysis presented herein.

a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that t he amount of energy and fuel consumed by construction and operation of the Project would not be inefficient, wasteful, or unnecessary. Table 10, Original Project Annual Operational Energy Demand Summary presents the Original Project’s annual energy demand. The Original Project proposed conventional industrial uses reflecting contemporary energy efficient/energy conserving designs and operational programs. The Original Project did not propose uses that are inherently energy intensive and the energy demands in total would be comparable to other industrial uses of similar scale and configuration. Furthermore, the Original Project would not cause or result in the need for additional energy facilities or energy delivery systems. Accordingly, the Project’s impacts associated with energy consumption would be less than significant.

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Table 10 Original Project Annual Operational Energy Demand Summary Land Use Natural Gas Demand
(kBTU/year)
Electricity Demand
(kWh/year)
Office
1,220,180 296,267 Warehouse
Maintenance Building
Parking 0 99,594
Other Asphalt Surfaces 0 0
Total Project Energy Demand 1,220,180 395,861
Source: Table 4.4-4 of the 2023 Certified EIR

Analysis of the Revised Project:

Project Construction

As with the Original Project, during the Revised Project construction, energy would be consumed in the form of electricity associated with the conveyance of water used for dust control and, on a limited basis, power lights, electronic equipment, or other construction activities necessitating electrical power.

Construction activities, including the construction of the new building, typically do not involve the consumption of natural gas . The Revised Project construction would consume energy in the form of petroleum-based fuels associated with the use of off -road construction vehicles and equipment on the Project site, construction worker travel to and from the Project site, and delivery and haul truck trips.

As concluded in the 2023 Certified EIR, the equipment used for construction would conform to California Air Resources Board (CARB) regulations and California emissions standards. There are no unusual characteristics or construction processes that would require the use of equipment that would be more energy intensive than is used for comparable activities; or equipment that would not conform to current emissions standards (and related fuel efficiencies). Equipment employed in construction of the Revised Project would therefore not result in inefficient, wasteful, or unnecessary consumption of fuel.

The Revised Project would utilize construction contractors who regularly comply with applicable CARB regulation regarding retrofitting, repowering, or replacement of diesel off-road construction equipment.

Additionally, CARB has adopted the Airborne Toxic Control Measure to limit heavy-duty diesel motor vehicle idling in order to reduce public exposure to diesel particulate matter and other Toxic Air Contaminants. Compliance with anti -idling and emissions re gulations would result in a more efficient use of construction- related energy and the minimization or elimination of wasteful or unnecessary consumption of energy. Idling restrictions and the use of newer engines and equipment would result in less fuel combustion and energy consumption. Additional construction‐source energy efficiencies would occur due to required California regulations and best available control measures (BACM). As supported by the preceding discussions, the Revised Project’s temporary construction energy consumption would not be considered inefficient, wasteful, or otherwise unnecessary. Therefore, the Revised Project would not result in the involvement of new significant environmental effects or a substantial increase in the

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severity of previously identified significant effects, other than those considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Project Operation

As with the Original Project, energy consumption in support of or related to the Revised Project operations would include transportation fuel demands (fuel consumed by passenger car and truck vehicles accessing the Project site), fuel demands from operational equipment, and facilities energy demands (energy consumed by building operations and site maintenance activities). The Revised Project’s electricity demand is approximately 1,051,528 kilowatt- hour (kWh) per year and natural gas demand is approximately 4,150,574 kilo British thermal units (kBTU) per year. Due to the increase in building size, building energy demands would increase and the Revised Project w ould increase electricity demand by 655,667 kWh per year and natural gas demand by 2,930,394 kBTU per year .

However, t he Revised Project proposes conventional industrial uses reflecting contemporary energy efficient/energy conserving designs and operational programs. The Revised Project does not propose uses that are inherently energy intensive and the energy demands in total would be comparable to other industrial uses of similar scale and configuration. The Revised Project would comply with the applicable Title 24 standards. Compliance itself with applicable Title 24 standards would ensure that the Revised Project energy demands would not be inefficient, wasteful, or otherwise unnecessary.

Additionally, energy efficiency/energy conservation attributes of the Revised Project would be complemented by increasingly stringent state and federal regulatory actions addressing vehicle fuel economies and vehicle emissions standards; and enhanced building/utilities energy efficiencies mandated. Therefore, the Revised Project would not result in the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects, other than those considered and addressed in the 2023 Certif ied EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Project would not conflict with or obstruct a State or local plan for renewable energy or energy efficiency and impacts would be less than significant.

Analysis of the Revised Project: Similar to the Original Project, the Revised Project is subject to California Building Code (CBC) requirements. New buildings must achieve compliance with 2022 Building and Energy Efficiency Standards and the 20 22 California Green Building Standards requirements. The Revised Project would be required to comply with the applicable standards in place at the time plan check submittals are made.

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The Revised Project would provide for, and promote, energy efficiencies equal to or beyond those required under other applicable federal and State standards and regulations, and in so doing would meet or exceed all CBC Title 24 standards. Moreover, energy consumed by the Revised Project’s operation is calculated to be comparable to, or less than, energy consumed by other industrial uses of similar scale and intensity that are constructed and operating in California . On this basis, the Revised Project would not conflict with or obstruct a State or local plan for renewable energy of energy efficiency . Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

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7. GEOLOGY AND SOILS.

Would the project:

Was Impact
Analyzed in
the 2023
Certified
EIR?
New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
New
Information
Requiring
New Analysis
or
Verification?
Does
2023
Certified
EIR
Address/
Resolve
Impacts?
(a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault ? Refer to Division of Mines and Geology Special Publication 42.

ii) Strong seismic ground shaking?
iii) Seismic-related ground failure, including liquefaction? iv) Landslides?
(b) Result in substantial soil erosion or the loss of topsoil? (c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse?

(d) Be located on expansive soil, as defined in Table 18 -1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property?

(e) Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water?

(f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?

The physical conditions of the Project site are unchanged since approval of the 2023 Certified EIR in 2023. Therefore, the analysis below relies on information contained in the geotechnical and cultural and paleontological resources report prepared for the Original Project as this information continues to be relevant to the Project site (refer to 2023 Certified Draft EIR Technical Appendices F and D, respectively). As noted earlier in this EIR Addendum, the 2023 Certified EIR and its technical appendices are incorporated by reference pursuant to pursuant to CEQA Guidelines Section 15150.

Impact Analysis:

a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:

i. Rupture of a known earthquake fault, as delineated on the most recent Alquist -Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault ? Refer to Division of Mines and Geology Special Publication 42?

Significance Determination: No Impact

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2023 Certified EIR Finding: The 2023 Certified EIR disclosed that the nearest active faults to the Project site are the San Joaquin Hills and Elsinore fault zones located approximately 7.5 miles to the south and 8.3 miles to the northeast, respectively. Fault rupture would not occur on the Project site since no active faults cross the Project site. Therefore, no impacts would occur.

Analysis of the Revised Project: Consistent with the findings of the 2023 Certified EIR, the Project site is not within a State of California Alquist-Priolo Earthquake Fault Zone. Additionally, the Project site is not within any other fault zone. The nearest active faults to the Project site are the San Joaquin Hills and Elsinore fault zones located approximately 7.5 miles to the south and 8.3 miles to the northeast, respectively. Fault rupture would not occur on the Project site since no active faults cross the Project site. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

ii. Strong seismic ground shaking?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Original Project’s proposed building would be constructed in accordance with the 2019 CBC and OMC Section 15.04.010, CBC Adopted by Reference , structures built for human occupancy must be designed to meet or exceed the CBC standards for earthquake resistance. Following compliance with the CBC, impacts concerning seismic ground shaking would be less than significant.

Analysis of the Revised Project: The Project site is located within the highly seismic Southern California region within the influence of several fault systems. The San Joaquin Hills and Elsinore fault zones located approximately 7.5 miles to the south and 8.3 miles to the northeast, respectively, of the Project site. As a result, the Revised Project would likely experience strong seismic ground shaking during its design life.

Consistent with the findings of the 2023 Certified EIR, the Revised Project’s proposed building would be constructed in accordance with the CBC and OMC Section 15.04.010, CBC Adopted by Reference, structures built for human occupancy must be designed to meet or exceed the CBC standards for earthquake resistance. Additionally, State Building Codes and other applicable regulatory requirements with which the Revised Project must comply with have been strengthened to be more protective against earthquakes and other seismic activity since the time the EIR was certified. The City of Orange Building Division would ensure incorporation of the Geotechnical Investigation’s recommended design criteria as a standard condition of approval. Following compliance with the CBC, impacts concerning seismic ground shaking would be les s than significant. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

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iii. Seismic-related ground failure, including liquefaction?

Significance Determination: No Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that according to the Geotechnical Investigation and the DOC Earthquake Zones of Required Investigation Map, the Project site is not within a Liquefaction Zone. The Original Project does not have the potential to expose people or structures to seismic-related liquefaction. Therefore, no impacts would occur.

Analysis of the Revised Project: Consistent with the findings of the 2023 Certified EIR, the Project site is not within a Liquefaction Zone. The Revised Project does not have the potential to expose people or structures to seismic-related liquefaction. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required

iv. Landslides?

Significance Determination: No Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that according to the DOC Earthquake Zones of Required Investigation Map, the Project site is not within a Landslide Zone. The Project does not have the potential to expose people or structures to seismic-related landslides. Therefore, no impacts would occur.

Analysis of the Revised Project: Consistent with the findings of the 2023 Certified EIR, the Project site is not within a Landslide Zone . The Revised Project does not have the potential to expose people or structures to seismic -related landslides. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

b) Result in substantial soil erosion or the loss of topsoil?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that implementation of the Original Project would not result in substantial soil erosion or loss of topsoil . The Project Applicant would be required to obtain a
National Pollutant Discharge Elimination System (NPDES) permit for construction activities and adhere to a Storm Water Pollution Prevention (SWPPP) and prepare an erosion control plan to minimize water and wind erosion. Following completion of development, the Project’s owner or operator would be required by law to implement a WQMP during operation, which would preclude substantial erosion impacts in the long-term.

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Analysis of the Revised Project: Under the Revised Project, because the Project site is fully developed and contains very little exposed soils, erosion occurring on the site is minimal. Consistent with the findings of the 2023 Certified EIR, grading and earthwork activities associated with Project construction would expose soils to potential short-term erosion by wind and water. The Revised Project construction would be required to comply with the water quality management measures identified in OMC Section

7.01.050, Controls for Water Quality Management . As discussed under Hydrology and Water Quality Threshold a, the Revised Project would be required to comply with the NPDES program to control direct storm water discharges, which involves the preparation and implementation of a SWPPP for construction-related activities, including grading . Additionally, the Revised Project would also be required to demonstrate compliance with South Coast A QMD Rule 403, which would reduce the potential for wind erosion during construction through the implementation of dust contr ol measures.

Following compliance with the established regulatory framework (i.e., OMC Chapter 7.01.050 and South Coast AQMD Rule 403), impacts during construction would be less than significant.

Long-term operational impacts related to soil erosion or loss of topsoil would be required to comply with the requirements outlined in the Revised Project’s WQMP in compliance with OMC Chapter 7.01, Water Quality and Stormwater Discharges . The Project’s WQMP is included as Appendix B 1 to this Addendum. The WQMP includes structural and non- structural best management practices (BMPs) to ensure water quality standards are upheld. Consistent with the findings of the 2023 Certified EIR, t he BMPs identified in th e Revised Project’s WQMP would reduce the Revised Project’s potential operational impacts concerning soil erosion or loss of topsoil. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that there is no potential for the Original Project’s construction or operation to cause, or be impacted by, on- or off-site landslides or lateral spreading. Potential hazards associated with unstable soils would be precluded through mandatory adherence to the recommendations contained in the site -specific geotechnical report during Project construction.

Analysis of the Revised Project:

Landslide

Refer to Geology/Soils Threshold a.iv. As discussed previously, the conditions of the Project site and surrounding area are unchanged from the conditions described in the 2023 Certified EIR. The Revised

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Project does not have the potential to be located on a geologic unit or soil that would result in on- or off- site landslides.

Lateral Spreading

The Project site’s potential for lateral spreading is considered low based on the site’s relatively flat topography, distance from slopes, and no potential for liquefaction. The Revised Project does not have the potential to be located on a geologic unit or soil that would result in lateral spreading.

Subsidence/Shrinkage

Consistent with the findings of the 2023 Certified EIR, the Revised Project would implement the recommendations identified within the Geotechnical Investigation in accordance with CBC requirements and to preclude impacts related to subsidence and shrinkage. Additionally, the City of Orange Building Division would ensure incorporation of the Geotechnical Investigation’s recommended actions as a standard condition of approval to the Revised Project’s building permit.

Liquefaction

Refer to Geology/Soils Threshold a.iii. The Revised Project does not have the potential to be located on a geologic unit or soil that would result in liquefaction.

Compliance with the recommendations in the Geotechnical Investigation report and the City’s Municipal Code would ensure that impacts under the Revised Project are less than significant. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Project site contains soils with low susceptibility to expansion; therefore, the Original Project would not create substantial direct or indirect risks to life or property associated with the presence of expansive soils. Less-than-significant impacts would occur.

Analysis of the Revised Project:

Consistent with the Original Project, development under the Revised Project would be required to comply with applicable Building and Safety regulations and the CBC as adopted and amended by the City of Orange. T he City of Orange Building Division would ensure incorporation of the Geotechnical Investigation’s recommended actions as a standard condition of approval to the Revised Project’s building permit. Following the implementation of the Geotechnical

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Investigation recommendations, impacts would be less than significant. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

e) Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water?

Significance Determination: No Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that no septic tanks or alternative wastewater disposal systems are proposed to be installed on the Project site. Accordingly, no impact would occur associated with soil compatibility for wastewater disposal systems.

Analysis of the Revised Project: Consistent with the findings of the 2023 Certified EIR, the Revised Project would not involve the use of septic tanks or alternative waste water disposal systems . The Revised Project would connect to the City’s exi sting wastewater service, which currently provides service to the site and surrounding area. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?

Significance Determination: Less than Significant Impact with Mitigation Incorporated

2023 Certified EIR Finding: The 2023 Certified EIR concluded that Mitigation Measure MM 4.5 -1 would ensure the proper identification and subsequent treatment of any paleontological resources that may be encountered during ground-disturbing activities associated with implementation of the proposed Project. Therefore, with implementation of Mitigation Measure MM 4.5-1, the Project’s potential impact to paleontological resources would be reduced to less-than-significant.

Analysis of the Revised Project: Consistent with the findings of the 2023 Certified EIR, a lthough the Project site was previously disturbed, the Revised Project’s construction activities have the potential to increase the depth of excavation and uncover unidentified paleontological resources . The Revised Project would implement MM 4.5-1 requiring all Project grading and construction efforts to halt until a paleontologist examines the site, identifies the paleontological significance of the resource, and recommends a course of action. Following the implementation of MM 4.5-1, the Revised Project would not significantly impact paleontological resources, and impacts would be less than significant. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than

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those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures:

MM 4.5-1 Prior to the issuance of a grading permit, the Applicant shall provide written evidence to the Community Development Department that the Applicant has retained a qualified paleontologist to respond on an as-needed basis to address unanticipated paleontological discoveries.

In the event that paleontological resources are encountered during ground- disturbing activities, all construction activities within 100 foot vicinity of the find shall halt until the qualified paleontologist identifies the paleontological significance of the find . If determined to be significant, the fossil shall be collected and prepared to the point of identification, identified to the lowest taxonomic level possible, cataloged, and curated into the permanent collections of a museum repository . At the conclusion of curation, a report of findings shall be prepared to document the results of the monitoring program .

Construction shall not resume within the vicinity until the site paleontologist states in writing that the proposed construction activities would not significantly damage paleontological resources.

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8. GREENHOUSE GAS EMISSIONS.

Would the project:

Impact Analysis:

Urban Crossroads, Inc. (Urban Crossroads) prepared an Air Quality/Greenhouse Gas/Energy/Health Risk Assessment Memorandum for the Revised Project that involves evaluation of the potential criteria and hazardous air pollutant emissions that could result fro m the Revised Project’s construction and operation. This memorandum is included as Technical Appendix A to this EIR Addendum and its findings are incorporated into the analysis presented herein.

a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the annual GHG emissions associated with the operation of the Original Project are estimated to be approximately 1,736.21 Metric tons of carbon dioxide equivalent (MT CO
2e) per year, which would not exceed the 3,000 MTCO2e per year threshold. Therefore, project -related emissions would not have a potential significant direct or indirect impact on GHG and climate change. Impacts related to GHG emissions would be less than significant.

Analysis of the Revised Project: Similar to the Original Project, the Revised Project would result in direct and indirect GHG emissions generated by construction, related vehicle trips and operations associated with the proposed building. Table 11 , Revised Project GHG Emissions , presents the GHG emissions that would result from operation of the Revised Project, as well as a comparison associated with the Original Project. As shown below, the Revised Project would result in a decrease of GHG emissions as compared to the Original Project. Additionally, the Revised Project would not exceed the South Coast AQMD’s numeric threshold of 3,000 MTCO
2e/yr. As such, the Revised Project-related
emissions would not have a potential significant direct or indirect impact on GHG and climate change and impacts would be less than significant . Therefore, the Revised Project would not result in the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects, other than those considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

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Table 11 Revised Project GHG Emissions
Emission Source
Emissions (MT/yr)
CO2 CH4 N2O Refrigerants Total CO2e
Annual construction-related emissions
amortized over 30 years 28.13 1.33E-03 1.33E-03 0.01 28.53 Area Source 4.36 0.00 0.00 0.00 4.37
Energy Source 386.00 0.04 0.00 0.00 388.00
Mobile Source 941.00 0.05 0.11 1.23 978.00
On-Site Equipment 47.38
Waste 18.00 1.80 0.00 0.00 63.00
Water Usage 69.20 1.62 0.04 0.00 121.00
Total CO2e (All Sources) 1,630.28
Threshold of Significance (MTCO2e/yr) 3,000
Impact? No
2023 Certified EIR Analysis 1,736.21
Source: (Urban Crossroads, 2024a)

Mitigation Measures: Mitigation measures are not required.

b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Original Project would not conflict with applicable plans, policies, and regulations adopted for the purpose of reducing the emissions of GHG emissions. Therefore, impacts were determined to be less than significant.

Analysis of the Revised Project: Pursuant to CEQA Guidelines Section 15604.4, a lead agency may rely on qualitative analysis or performance -based standards to determine the significance of impacts from GHG emissions. As discussed above, the Revised Project would result in decreased GHG emissions as compared to the Original Project. Furthermore, t he Revised Project would not exceed the 3,000 MTCO
2e/yr threshold of significance. Since certification of the 2023 Certified EIR, CARB adopted the 2022 Scoping Plan which lays out a path to achieve targets for carbon neutrality and reduce anthropogenic GHG emissions by 85 percent below 1990 levels no later than 2045, as directed by Assembly Bill 1279. Since the Revised Project would not exceed the efficiency based GHG emissions target, the Revised Project would not have the potential to conflict with the 2022 Scoping Plan. Thus, impacts would be less than significant. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

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9. HAZARDS AND HAZARDOUS MATERIALS.

Would the project:

Was
Impact
Analyzed
in the 2023
Certified
EIR?
New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
New
Information
Requiring
New Analysis
or
Verification?
Does
2023
Certified
EIR
Address/
Resolve
Impacts?
(a) Create a significant hazard to the public or the environment through the routine transport, use or disposal of hazardous materials? (b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?

(c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school?

(d) Be located on a site which is included on a list of hazardous materials sites complied pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?

(e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?

(f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
(g) Expose people or structures , either directly or indirectly to a significant risk of loss, injury or death involving wildland fires?

The physical conditions of the Project site are unchanged since adoption of the 2023 Certified EIR in 2023. Therefore, the analysis below relies on information contained in the Phase I Environmental Site Assessment (ESA), Limited Phase II Environmental Site Assessment, and Soil Management Plan (SMP) prepared for the Original Project as the information in this report continues to be relevant to the Project site (refer to 2023 Certified Draft EIR Technical Appendices H1, H2, and H3).

Impact Analysis:

a) Create a significant hazard to the public or the environment through the routine transport, use or disposal of hazardous materials?

Significance Determination: Less than Significant With Mitigation Incorporated

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Project site contains soils contaminated with VOC although not expected to pose a substantial risk to the environment or people on the Project site, could require remediation. Remediation of existing contamination would result in an improved long-term environmental condition at the Project site.

Implementation of Mitigation Measure
MM 4.7-1 would ensure that any contaminated soils or other contaminated materials encountered during Project construction that are determined to be hazardous by an applicable government oversight agency are appropriately remediated so that they would not pose a hazard to the public or the environment during construction or in the long -term. As such, implementation of the Original Project would result in an improved environmental condition by addressing and remediating any existing environmental hazards.

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Accordingly, the impacts would be less than significant after the implementation of Mitigation Measure MM 4.7-1.

Analysis of the Revised Project:

Project Construction

General Construction Hazardous Waste

Consistent with the findings of the 2023 Certified EIR, heavy equipment (e.g., dozers, excavators, tractors) would operate on the subject property during construction of the Project . Also, materials such as paints, adhesives, solvents, and other substances typically used in building construction would be located on the Project site during construction. Construction contractors would be required to comply with all applicable federal, State, and local laws and regulations regarding the transport, use, and storage of hazardous construction‐related materials, including but not limited requirement s imposed by the Environmental Protection Agency (EPA), California Department of Toxic Substances Control (DTSC), South Coast AQMD, and Santa Ana Regional Water Quality Control Board (RWQCB). With mandatory compliance with applicable hazardous materials regulations, the Revised Project would not create a significant hazard to the public or the environment through routine transport, use, or disposal of hazardous materials during the construction phase. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Impacted Soils

Similar to the Original Project, construction activities required to develop the Project site would involve the disturbance of on -site soils. There is the potential for the discovery of contamination during these activities due to past reported evidence of soil contamination and underground storage tanks.

As disclosed in the 2023 Certified EIR, the Project site has reported past evidence of soil contamination and underground storage tanks . Additionally, the Project site has reported compliance violations from the County of Orange Health Care Agency – Environmental Health regarding spill control and secondary containment for bulk storage containers on site . Based on the historic recognized environmental condition and on-site conditions, the Phase I ESA recommended additional soil sampling to ensure the Project site has been cleaned prior to construction. A limited Phase II ESA was prepared to conduct soil and soil vapor sampling consistent with the recommendations of the Phase I ESA. Detectable quantities of the VOC constituents freon 113; 1,1,1- trichloroethene; dichlorodifluoromethane; trichlorofluoromethane; trichloroethene; and tetrachloroethene were detected from all borings during the limited Phase II ESA . VOC concentrations for the constituents trichloroethene and tetrachloroethene were detected above screening levels for industrial air in two of the 16 borings, which include B-11 and B-12. These two borings are in the southwest corner, within the proposed parking area and/or stormwater disposal area of the Project site . Therefore, contaminated soils encountered during construction could pose a health risk to workers and the general public during removal, handling, and transport.

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Contaminated soils would be removed and disposed of offsite in accordance with all applicable regulatory guidelines which include:

• South Coast AQMD Rule 1166 requirements: The rule requires monitoring of soils contaminated with VOCs during excavation or grading. A Rule 1166 permit must be obtained from South Coast AQMD prior to the start of work. Field monitoring will be conducted as required under Rule 1166 and soils will be monitored for VOCs in accordance with the South Coast AQMD Executive Officer. In the event that VOC detections reach or exceed 50 parts per million, further grading or excavation activities would be conducted in a ccordance with Rule 1166 to minimize releases of VOCs to air . Monitoring and record keeping would be submitted to the South Coast AQMD.
• South Coast AQMD Rule 403: Best available dust control measures and monitoring for fugitive dust would be conducted in accordance with South Coast AQMD’s Rule 403. In order to minimize exposure of on-site grading workers to dust and minimize dust from migrating off-site, various dust control measures would be implemented, including: spraying water on soil, limiting vehicle speeds on site to 5 miles per hour or less, controlling excavation activities, cleaning up track-outs at the end of each work day, minim izing drop heights during vehicle loading, and covering exposed stockpiles.
• SWRCB General Construction Permit: A SWPPP for construction would need to be in place prior to the start of grading. A SWPPP requires the incorporation of best management practices to control sediment, erosion, and hazardous materials contamination of runoff during construction and prevent contaminants from reaching receiving water bodies. • Certification. Contractors performing work directly involving impacted soil will be required to possess an active California State contractor’s license with a Hazardous Substances Removal certification.

Soil Management Plan

As disclosed in the 2023 Certified EIR, t he Original Project’s Phase I and Phase II ESA identified environmental concern s related to the historical widespread chemical use, storage, and disposal operations/practices at the Project site, which resulted in soil contamination that was the subject of prior remedial actions. The facility historically maintained numerous Underground Storage Tanks (USTs) and discrepancies reportedly exist as to the number and type of USTs and their decommissioning/removal status. There are no known USTs currently at the Project site.

Consistent with the findings of the 2023 Certified EIR, there is a potential for the Project site to contain impacted soil or other subsurface features (pits, sumps, clarifies, or USTs) that may need to be appropriately and expeditiously managed due to additional agency oversight and/or any permitting necessary to properly abandon such features . Implementation of Mitigation Measure MM 4.7-1 would ensure compliance with the Soil Management Plan (SMP), which would reduce potential impacts related to routine t ransport, use, or disposal of contaminated or potentially contaminated soils to less than significant.

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Demolition

Consistent with the findings of the 2023 Certified EIR, all proposed demolition activities would be required to comply with all applicable federal, State, and local hazardous materials regulation, which includes mandatory provisions for the safe removal, transport, and disposal of asbestos -containing materials (ACMs) and lead paint. South Coast AQMD Rule 1403 (Asbestos Emissions) and Title 17 of the California Code of Regulations (CCR), Division 1, Chapter 8: Accreditation, Certification, and Work Practices for Lead-Based Paint and Lead Hazards applies.

South Coast AQMD Rule 1403 establishes survey requirements, notification, and work practice requirements to prevent asbestos emissions from emanating during building renovation and demolition activities. Assuming that ACMs are present in the existing structure located on -site, then Rule 1403 requires notification of the South Coast AQMD prior to commencing any demolition activities . Rule 1403 also sets forth specific procedures for the removal of asbestos and requires that an on -site representative trained in the requirements of Rule 1403 be present during the stripping, removing, handling, or disturbing of ACM. Mandatory compliance with the provisions of Rule 1403 would ensure that construction-related grading, clearing, and demolition activities do not expose construction workers or nearby sensitive receptors to significant health risks associated with ACMs . Because future development on the Project site would be required to comply with AQMD Rule 1403 during demolition activities, impacts due to asbestos would be less than significant.

Title 17, CCR, Division 1, Chapter 8: Accreditation, Certification and Work Practices for Lead- Based Paint and Lead Hazards, defines and regulates lead -based paint . Any detectable amount of lead is regulated. During the demolition of the existing manufacturing building, there is a potential for exposing construction workers to health hazards associated with lead . The Project would be required to comply with Title 17, CCR, Division 1, Chapter 8, which includes requirements such as employer -provided training, air monitoring, protective clothing, respirators, and handwashing facilities . Mandatory compliance with these requirements would ensure that construction workers and the public are not exposed to significant Lead Based Paint (LBP) health hazards or upset during demolition and/or during transport of demolition waste to an appropriate disposal facility and would ensure that impacts related to LBP remain less than significant . Accordingly, neither ACMs nor lead paint are determined to be a significant hazard on the Project site.

Project Operation

The Revised Project would be occupied with a l ight industrial warehouse use and it is possible that hazardous materials could be used during the future building user’s daily operations. State and federal Community-Right-to-Know laws allow public access to information about the amounts and types of chemicals in use at local businesses. Laws also are in place that requires businesses to plan and prepare for possible chemical emergencies. The City follows the County’s Hazardous Materials Inspection and Enforcement Plan (Orange, 2010b) . To prevent accidents, and ensure proper handling, routine inspections are conducted at businesses within the City that store, use, or handle hazardous materials .

The City concentrates the production of hazardous materials within its industrial area, separated from residential areas, educational uses, and institutional facilities . The City also identifies businesses transporting, manufacturing, using, and storing hazardous chemicals, and requires such businesses to

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exercise caution and to mitigate potential negative effects on surrounding land uses prior to obtaining business licenses. Additionally, any business handling at any one time, greater than 500 pounds of solid, 55 gallons of liquid, or 200 cubic feet of gaseous hazardous material, is required, under Assembly Bill 2185 (AB 2185), to file a Hazardous Materials Business Emergency Plan (HMBEP) . An HMBEP is a written set of procedures and information created to help minimize the effects and extent of a release or threatened release of hazardous material . The HMBEP intends to satisfy federal and State Community Right-To-Know laws and to provide detailed information for use by emergency responders.

If businesses that use or store hazardous materials occupy the Project site, the business owners and operators would be required to comply with all applicable federal, State, and local regulations to ensure proper use, storage, use, emission, and disposal of hazardous substances (as described above) . With mandatory regulatory compliance, the Revised Project is not expected to pose a significant hazard to the public or the environment through the routine transport, use, storage, emission, or disposal of hazardous materials. Impacts would be less than significant with mitigation incorporated. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measure:

4.7-1 The Project Contractor shall adhere to the protocols and performance standards stipulated in the SMP ( Technical Appendix H3 of the Draft EIR ). Contractors working at the site follow all applicable Cal/OSHA regulations for construction safety. A Completion Report shall be prepared at the conclusion of grading activities. The report shall document field monitoring activities and visual observations made during grading/excavations, as well as soil sampling locations and results. The report shall include a description of the location of impacted soil encountered, actions taken to characterize and mitigate impacts, confirmation soil sampling results, and disposition of any excavated soil. In addition, the report shall include a description of encountered subsurface structures and steps to remove and close such structures. The report shall be reviewed and approved by the City of Orange Community Development Director, prior to issuance of building permits.

b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that during Original Project construction and operations, mandatory compliance to federal, State, and local regulations would ensure that the Original Project would not create a significant hazard to the environment due to routine transport, use, disposal, or upset of hazardous materials.

Analysis of the Revised Project :

Similar to the Original Project, d uring the Revised Project construction, there is a possibility of accidental release of hazardous substances such as petroleum-based fuels or hydraulic fluid used for construction equipment. The level of risk associated with the accidental

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release of hazardous substances is not considered significant due to the small volume and low concentration of hazardous materials utilized during construction. The construction contractor would be required to use standard construction controls and safety procedures that would avoid and minimize the potential for accidental release of such that any materials released are appropriately contained and remediated as required by local, State, and federal law.

Construction

Consistent with the findings of the 2023 Certified EIR, the Revised Project would comply with the requirements of applicable laws and regulations governing upsets and accidents including the requirements of the hazardous materials disclosure program, the California Accidental Release Prevention Program, the hazardous mate rials release response plans and inventory program, and California Health and Safety Code Section 25500. Additionally, strict adherence to the City of Orange emergency response plan requirements would be required through the duration of the Project construction phase. These requirements would ensure that all potentially hazardous materials are handled in an appropriate manner and would minimize the potential for upset and accident conditions. Therefore, this impact is considered less than significant.

Operation

Regulatory requirements pertaining to upsets and accidents following during the construction phase would also be implemented during the operational phase. For the operational phase, both the federal government and the State of California require that the Revised Project files a hazardous materials business plan. These requirements would ensure that all potentially hazardous materials are handled in an appropriate manner and would minimize the potential for safety impacts. With mandatory regulatory compliance, the Project would not increase the potential for accident conditions which could result in the release of hazardous materials into the environment . Impacts would be less than significant.

Mitigation Measures: Mitigation measures are not required.

c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school?

Significance Determination: No Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Project site is not located within one-quarter mile of any existing or proposed school. Accordingly, the Original Project would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school . Impacts to schools located more than one - quarter mile of the Project site would be less than significant.

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Analysis of the Revised Project: As discussed previously, the Revised Project’s development footprint is the same as the Original Project’s development footprint analyzed under the 2023 Certified EIR. The closest existing schools to the Project site are California Elementary School and Yorba Middle School located approximately 0.78 miles east of the Project site . Implementation of the Revised Project would not have the potential to emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within 0.25 miles of an existing or proposed school. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

d) Be located on a site which is included on a list of hazardous materials sites complied pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR disclosed that with the consideration of the absence of reported violations, spills, or releases, the Project site is not considered to be a recognized environmental concern ( REC) and would not create a significant hazard to the public or environment and impacts would be less than significant.

Analysis of the Revised Project: The Project site appears on the EnviroStor database sites; however, this listing represents a historic REC at the Site . The status of the Project site is listed as “refer: other agency” and no further action (NFA) was recommended for the site as “remediation of soil was completed by Orange County.” With the consideration of the absence of reported violations , spills, or releases, the Project site is not considered to be a REC. Consistent with the findings of the 2023 Certified EIR, the Revised Project would not create a significant hazard to the public or environment and impacts would be less than significant. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

e) For a project located within 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 result in a safety hazard or excessive noise for people residing or working in the project area?

Significance Determination: No Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Project site is not within an airport land use plan or within 2 miles of a public airport or public use airport . Implementation of the Original Project would not result in a safety hazard or excessive noise for people residing or working within the Project area. No impacts would occur.

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Analysis of the Revised Project: The closest airport to the Project site is the Fullerton Municipal Airport located approximately 8.0 miles northwest . The Project site is not within an airport land use plan or within 2 miles of a public airport or public use airport. Consistent with the findings of the 2023 Certified EIR, implementation of the Revised Project would not result in a safety hazard or excessive noise for people residing or working within the Project area . Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Project site does not contain any emergency facilities nor does it serve as an emergency evacuation route. During construction and long-term operation, adequate emergency vehicle access is required to be provided. Accordingly, implementation of the Original Project would not impair implementation of or physically interfere with an adopted emergency response plan or an emergency evacuation plan.

Analysis of the Revised Project: Consistent with the findings of the 2023 Certified EIR, the Revised Project is not anticipated to affect access to Katella Avenue during construction and would not require road closures or otherwise impact the functionality of this, or other designated evacuation corridors .

Additionally, the Revised Project would not affect emergency access. The Revised Project is required to comply with applicable fire codes established by the Orange County Fire Authority (OCFA) . The Revised Project would be required to go through the City’s development review and permitting process and would be required to incorporate all appliable design and safety standards and regulations in the California Fire Code and the OMC.

Implementation of the Revised Project would not impair the implementation of or physically interfere with the City’s Emergency Operation Plan, the General Plan Public Safety Element, or any other emergency response plan. Impacts would be less than significant. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

g) Expose people or structures, either directly or indirectly to a significant risk of loss, injury or death involving wildland fires?

Significance Determination: No Impact

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2023 Certified EIR Finding: The 2023 Certified EIR concluded that implementation of the Original Project would not expose people or structures to a significant risk involving wildland fires . No impacts would occur.

Analysis of the Revised Project: Consistent with the 2023 Certified EIR, the Project site is not within a very high fire hazard severity zone and within a completely urbanized area that is void of any wildland areas. Implementation of the Revised Project would not expose people or structures to a significant risk involving wildland fires. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

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10. HYDROLOGY AND WATER QUALITY.

Would the project: Was Impact
Analyzed in
the 2023
Certified
EIR?
New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
New
Information
Requiring New
Analysis or
Verification?
Does
2023
Certified
EIR
Address/
Resolve
Impacts?
(a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality?

(b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?

(c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:

(i) result in substantial erosion or siltation on- or off-site; (ii) increase the rate or amount of surface runoff in a manner which would result in flooding in- or off-site;
(iii) c reate 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; or

(iv) impede or redirect flood flows?
(d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
(e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?

This section is primarily based on the 1) Preliminary Water Quality Management Plan For 534 Struck Ave Redevelopment Project WQMP, prepared by Albert A. Webb Associates (Webb) dated September 2024; and 2) Final Drainage Study (Drainage Study), prepared by Webb dated April 2024. The Project- specific Preliminary WQMPs and Drainage Study are included as Appendi ces B.1 and B.2 of this Addendum.

Impact Analysis:

a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Original 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.

Analysis of the Revised Project: As demonstrated in the analysis below, the Revised Project would not violate any water quality standards or waste discharge requirements and, thus, would result in less-than- significant impacts. Implementation of the Project would not result in any new or more severe impacts

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on water quality standards or waste discharge requirements or groundwater quality than what was disclosed in the 2023 Certified EIR.

Construction Impacts

Similar to the Original Project, the Revised Project may result in water quality impacts during short-term construction activities. The grading/excavation required for the Revised P roject 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 detrimental to the environment . As such, short -term water qu ality impacts have the potential to occur during construction of the Revised Project in the absence of any protective or avoidance measures.

Consistent with the findings of the 2023 Certified EIR, the Revised 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 Revised Project would be required to comply with the City’s Stormwater Local Implementation Plan (LIP). Additionally, the Revised Project would be required to comply with Chapter 7.01, Water Quality and Stormwater Discharges, of the OMC. Mandatory compliance with the SWPPP , the City’s LIP, and Chapter 7.01 of the OMC would ensure that the Revised Project does not violate any water quality standards or waste discharge requirements during construction activities. Impacts would be less than significant.

Post Construction-Impacts

The Project Applicant would redevelop the Project site with an approximate 214,956 sf light industrial warehouse building and associated parking 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 grease, toxic organic compounds (TOCs), pathogens (bacteria/virus), and trash and debris (from all vehicular traffic).

Consistent with the findings of the 2023 Certified EIR, w ith implementation of the Drainage Area Management Plan (DAMP) requirements, as required by OMC Chapter 7.01 the Revised 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; common area landscape management; BMP maintenance; spill contingency plant; 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 Revised Project’s WQMP include providing storm drain signage; trash storage areas; efficient irrigation systems and landscape design; and loading docks.

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Additionally, based on the requirements of the NPDES Industrial General Permit, the Revised Project’s mandatory compliance with all applicable regulations would further reduce potential water quality impacts during long-term operation. As disclosed in the 2023 Certified EIR, it should be noted that under existing conditions, flows generated from the site drain to W. Struck Avenue unmitigated and untreated.

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

Based on the foregoing analysis, the Revised 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. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Original Project would not physically impact any of the major groundwater recharge facilities in the Orange County Groundwater Basin. The Original Project would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the Project would impede sustainable groundwat er management of the Basin.

Analysis of the Revised Project: Similar to the Original Project, implementation of the Revised Project would not include the construction of a potable groundwater well and no potable groundwater wells are located on-site. The City of Orange would provide potable water services to the Revised Project. 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).

Groundwater Supply

According to the City’s 2020 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 Revised 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 Revised Project would not have the potential to substantially decrease groundwater supplies. Impacts would be less than significant.

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Groundwater Recharge

Under existing conditions, approximately 92 percent of the Project site contains impervious surfaces that provides little opportunity for infiltration. The Project would create similar impervious surface conditions, decreasing the Project site’s impervious surface coverage to 9 0 percent (Webb, 2024a) .

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 Element, 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 Santiago Creek. Implementation of the Revised Project would not have the potential to interfere with groundwater recharge. Impacts would be less than significant. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Original Project would be required to comply with applicable water quality regulatory requirements to minimize erosion and siltation. Additionally, the Original Project would not result in flooding on- or off-site or impede/redirect flood flows. Lastly, the Original 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.

Analysis of the Revised Project: Under existing conditions, the Project site does not contain a stream or river; therefore, the Revised Project does not have to potential to alter the course of a stream or river.

No impacts would occur in this regard.

On-Site Storm Drain Facilities

The Project site generally drains from east to west where existing ribbon gutters pick up flows and convey them north into W. Struck Avenue. Flows drain to the existing 33” storm drain within W. Struck Avenue and ultimately into the Collins Channel before entering into the Santa Ana River. The downstream storm drain facilities are maintained and owned by the City. The Collins Channel and the Santa Ana River are maintained by Orange County Flood Control. All downstream facilities are fully functioning stabilized drainage facilities and are not susceptible to hydromodification impacts.

Under the Revised Project conditions, as shown in Figure 10, Water Quality Management Plan , the site will be redeveloped to ensure that the onsite flows are directed to storm drain facilities that will convey flows to treatment devices prior to discharging offsite.

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The majority of the Project site would surface flow to ribbon gutters that are proposed along the sides of the drive aisles to direct flows to proposed storm drain inlets. The proposed building would drain east into the proposed drive aisles and ribbon gutters. Some ponding is expected to occur within the parking limits, however, additional storm drain inlets have been proposed along the ribbon gutters to reduce the ponding to acceptable levels. The pr oposed storm drain would convey flows to the Modular Wetland Systems for treatment prior to discharging offsite into W. Struck Avenue and ultimately into the existing storm drain facilities.

The outlet structure has been designed to bypass approximately 2.0 cubic feet per second (cfs) toward the MWS vaults for compliance with water quality requirements. Treated flows are proposed to enter a pump in order to be discharged off the site and onto W. Struck Avenue. The proposed outlet structure receives approximately 25.4 cfs of onsite flows from the proposed Line A and Line B.

• Line A is a 18”-30” storm drain proposed near the northwestern portion of the Project site. The proposed line would collect flows generated by the areas west of the proposed building that are conveyed along the ribbon 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 co llected. Line A confluences with Line B before discharging into the proposed outlet structure. Line A conveys the total site runoff of approximately 25.4 cfs of runoff generated onsite. • Line B is a 24” – 30” storm drain proposed along the eastern and northern portion of the proposed site. Line B conveys approximately 21.6 cfs runoff when it confluences with line A. The proposed line would collect flows draining through the ribbon gutter along the eastern trailer parking stalls and the eastern auto parking areas before discharging into Line A. Proposed laterals along Line B are proposed at various drainage inlets.

Off-Site Storm Drain Facilities

The existing storm drain adjacent to the Project site in W. Struck Avenue is a 33-inch reinforced concrete pipe (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 W.

Struck Avenue and the adjacent building sites, including the existing drainage of the Project site. At this location, a set of catch basins pick up the street flow from W. Struck Avenue and the adjacent building sites, including the existing drainage of the Revised Project.

The existing storm drain lines were sized to accommodate 10 -year storm event flows. It was assumed that the proposed facilities were designed to accept flows from the surrounding parcels in their developed condition. The existing 33” RCP is not sized to accept flows from the Revised Project; therefore, no connection is proposed.

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c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:

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

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Original Project would increase the amount of impervious surface coverage on the Project site from 89 percent to 91 percent. Therefore, the Original Project would not substantially alter the Project site’s drainage pattern in such a way that would result in substantial erosion or siltation on- or off-site. 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.

Analysis of the Revised Project: As discussed above, the Project would decrease the amount of impervious surface coverage on the Project site from 92 percent to 91 percent. As concluded in Geology and Soils Threshold b above, the Revised Project would not substantially alter the Project site’s drainage pattern in such a way that would result in substantial erosion or siltation on - or off-site. The Revised 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 Revised Project’s proposed BMPs are enforced by the WQMP and are highly effective at removing sediment from stormwater runoff flows. Therefore, stormwater runoff leaving the Project site would not carry substantial amounts of sedime nt. Because there are no exposed soils at the Project site’s discharge points, there is no potential for the Revised Project’s stormwater runoff to result in erosion as it leaves the Project site . Impacts would be less than significant. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

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

2023 Certified EIR Finding: The 2023 Certified EIR concluded that implementation of the Original Project would reduce peak flows discharging from the Project site. Table 12, Original Project Peak Flows, presents the Original Project peak flows as compared to existing conditions. As such, the Original Project proposed drainage improvements would not result in on-site or off-site flooding. Impacts would be less than significant.

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Table 12 Original 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: Table 4.8-1 of the 2023 Certified EIR

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

Table 13, Revised Project Peak Flows, presents the existing, Original Project and Revised Project hydrology conditions. The Revised Project p eak flows would increase slightly as compared to the Original Project. However, as concluded in the Revised Project’s drainage study, the proposed drainage improvements would adequately convey flows to the basin and provide flood protection for the 100-year storm event. As such, the Revised Project’s proposed drainage improvements would not result in on-site or off-site flooding. Impacts would be less than significant. Therefore, the Revised Project would not result in the involvement of new significant environmental effects or a substantial increase in the severity of previously identi fied significant effects, other than those considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Table 13 Revised Project Peak Flows
Existing Conditions Original Project
Conditions
Revised Project Conditions
Storm Event Peak Flow
(cfs)
Tc (min) Peak Flow
(cfs)
Tc (min) Peak Flow
(cfs)
Tc (min)
2-Year 24 hour 12.5 12.31 11.9 9.90 13.7 11.46
10-Year 24
hour

23.3 11.50 21.7 9.54 25.4 10.75
100-Year 24
hour

36.5 10.97 33.4 9.34 39.4 10.35
AF = acre-feet
Tc = cubic feet per second
Source: (Webb, 2024b)(Table 4)

Mitigation Measures: Mitigation measures are not required.

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?

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Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that 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.

Analysis of the Revised Project: As discussed above under Hydrology and Water Quality Threshold c.i and c.ii, ae, the proposed drainage improvements would adequately convey flows to the basin and provide flood protection for the 100 -year storm event. The proposed basins would provide adequate water quality treatment and the Revised Project would not impact flood condi tion to upstream or downstream properties. 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. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

iv) Impede or redirect flood flows?

Significance Determination: No Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that 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. The Original Project does not have the potential to impede or redirect flood flows. No impacts would occur.

Analysis of the Revised Project: Consistent with the findings of the 2023 Certified EIR, the Project site is within Zone X (Unshaded), an area of minimal flood hazard (FEMA, 2009). The Revised Project does not have the potential to impede or redirect flood flows. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?

Significance Determination: No Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Project site is not within a 100- year flood hazard zone. The Original Project does not have the potential to release pollutants due to 100-

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year flood inundation. The Original Project does not have the potential to release pollutants due to Project inundation. The Project site is located approximately 13 miles northeast of the Pacific Ocean. Due to site distance, the Original 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.

Analysis of the Revised Project: Consistent with the findings of the 2023 Certified EIR, 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. The Project site is located approximately 13 miles northeast of the Pacific Ocean . Due to site distance, the Revised 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. The nearest enclosed body of water includes the man-made ponds located at the Islands Golf Center approximately 1.1 miles northwest of the Project site . Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?

Significance Determination: No Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that groundwater is anticipated to be located at a depth greater than 40 below ground surface (bgs). The Original Project’s potable water would be supplied by the City, which relies on groundwater and imported water . As identified in the City’s Urban Water Management Plan ( 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 Original Project would not have the potential to conflict with or obstruct implementation of the Coastal Plain of Orange County Basin (Basin 8-1) Alternative and no impacts would occur.

Analysis of the Revised Project: As discussed under Hydrology and Water Quality Threshold a, the Project site is within the Santa Ana River Basin; therefore, 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 an SWPPP and WQMP . Additionally, as discussed previously, implementation 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 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 agencies 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 road 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,

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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 document s the basin conditions; basin management is to be 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.

Mitigation Measures: Mitigation measures are not required.

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11. LAND USE/PLANNING.

Would the project:

Impact Analysis:

a) Physically divide an established community?

Significance Determination: No Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Project site is developed with a manufacturing facility. Existing industrial development borders the Project site to the south and west; the OCTA/SCRRA railroad track borders the Site to the east; and W. Struck Avenue and the public facility uses border the site to the north. The Original Project would not have the potential to physically divide an established community. No impacts would occur.

Analysis of the Revised Project: Consistent with the findings of the 2023 Certified EIR, the Project site is developed with a vacant manufacturing facility. The Project Applicant would redevelop the Project site with another industrial use with associated parking and landscaping improvements. Similar to the Original Project, the Revised Project would not have the potential to physically divide an established community. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

b) Cause a significant environmental impact due to a conflict with any applicable land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?

Significance Determination: No Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that although the proposed building would require a Conditional Use Permit (CUP) for the proposed truck terminal use, the Original Project would not conflict with the Zoning Code. Because the Original Project would be consistent with the underlying General Plan designation for the Project s ite, the Project would not conflict with any applicable goals, objectives, and policies of South Coast AQMD’s AQMP and SCAG’s Connect SoCal, which base their assumptions and analyses upon the full build -out of t he existing General Plans throughout the region. No impacts would occur.

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Analysis of the Revised Project: Consistent with the findings of the 2023 Certified EIR, the Project site is designated for “Light Industrial” land uses by the City of Orange General Plan and “Industrial (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 1 and Table 2, the Revised Project would not conflict with the General Plan. Although the proposed building would require a CUP for the proposed light industrial warehouse use, the Revised Project would not conflict with the Zoning Code . Because the Revised Project would be consistent with the underlying General Plan designation for the Project site, the Project would not conflict with any applicable goals, objectives, and 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 of this Addendum .

Mitigation Measures: Mitigation measures are not required.

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12. MINERAL RESOURCES.

Would the project: Was Impact
Analyzed in
the 2023
Certified
EIR?
New
Circumstance
s Involving
New
Significant
Impacts or
Substantially
More Severe
Impacts?
New
Information
Requiring New
Analysis or
Verification?
Does
2023
Certified
EIR
Address/
Resolve
Impacts?
(a) Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state? (b) Result in the loss of availability of a locally -important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan?

Impact Analysis:

a) Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?

Significance Determination: No Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that no mineral resources are anticipated in the Project area and the implementation of the Original 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.

Analysis of the Revised Project: The Project site is located within a developed, urbanized area of the City and is located approximately 0.87 miles east of the Santa Ana River and 1.9 miles north of the Santiago Creek. Consistent with the findings of the 2023 Certified EIR , no mineral resources are anticipated in the Project area and the implementation of the Revised 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. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

b) 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?

Significance Determination: No Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the site is not permitted for mining use under the Light Industrial land use designation and Industrial zoning classification . Because the Project site is not delineated as containing mineral resources on the City’s General Plan, the implementation of the Original 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.

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Analysis of the Revised Project: As previously discussed, 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; therefore, the Revised Project does not have the potential to contain any aggregate resources . Additionally, the Project site is not permitted for mining use under the Light Industrial land use designation and Industrial zoning classification. Consistent with the findings of the 2023 Certified EIR , implementation of the Revised Project does not have the potential to result in the loss of availability of a locally -important mineral resource recovery site. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

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13. NOISE.

Would the project result in: Was Impact
Analyzed in
the 2023
Certified
EIR?
New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
New
Information
Requiring
New Analysis
or
Verification?
Does
2023
Certified
EIR
Address/
Resolve
Impacts?
(a) Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?

(b) Generation of excessive groundborne vibration or groundborne noise levels?
(c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within 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?

A Noise and Vibration Impact Analysis was prepared for the Revised Project by Urban Crossroads to evaluate the Revised Project-related long-term operational and short -term construction noise impacts .

This report is included as Technical Appendix C to this EIR Addendum and its findings are incorporated into the analysis presented herein.

Impact Analysis:

a) Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Original Project would generate short-term construction and long- term operational noise but would not generate noise levels that exceed significance thresholds. The 2023 Certified EIR concluded that the Original Project’s construction related noise at the off-site receiver locations which ranged from 57.1 A-weighted decibel equivalent continuous sound level (dBA Leq ) to 78.7 dBA Leq would satisfy the 80 dBA Leq significance threshold. The daytime operational hourly noise levels at the off-site receiver locations are expected to range from 40.6 to 52.2 dBA Leq. The nighttime operational hourly noise levels at the off- site receiver locations are expected to range from 40.6 to 52.2 dBA Leq. The Existing without Project exterior noise levels range from 62.6 to 73.0 dBA Community Noise Equivalent Level (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. The O pening Year without Project exterior noise levels range from 63.5 to 73.2 dBA CNEL, without accounting for any noise attenuation features such as noise barriers or topography; and with Project conditions would range from

63.6 to 73.3 dBA CNEL. The Original Project off-site traffic noise level increases range from 0.0 to 3.9 dBA CNEL. 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.

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Analysis of the Revised Project: As with the Original Project, 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.

Construction Noise Impact Analysis

The Revised 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 high 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. However, although periodic and temporary, construction noise has the potential to be substantial compared to existing ambient noise levels. As was the case with the Original Project, the Revised Project’s construction-related activities would be required to comply with the City’s Noise Ordinance (OMC Section 8.24.040).

Consistent with the findings of the 2023 Certified EIR, to evaluate whether the Revised Project would generate potentially significant short -term noise levels at nearest receiver locations, a construction - related daytime noise level threshold of 80 dBA Leq is used as a reasonable threshold to assess the daytime construction noise level impacts. Figure 11, Noise Receiver Locations, presents the receiver locations used in the analysis for construction noise. As shown on Table 14, Revised Project Construction Noise Level Compliance, the Revised Project’s construction-related noise at the off -site receiver locations would satisfy the 80 dBA Leq significance threshold . Impacts would be less than significant. As was the case in the Original Project analysis, t he Revised Project construction -related noise a nalysis represents a worst -case scenario for noise conditions. Since th e Revised Project construction limits are identical to the Original Project construction limits, the worst-case construction equipment noise levels remain the same as the Original Project. Therefore, the Revised Project would not result in the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects, other than those considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

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Table 14 Revised Project 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 80 No
R6 57.1 80 No
Notes:

1. Noise receiver locations are shown on Figure 11, Noise Receiver Locations

2. Highest construction noise level calculations based on distance from the construction noise source activity to nearby receiver locations.

3. Federal Transit Administration, Transit Noise and Vibration Impact Assessment Manual

4. Do the estimated Project construction noise levels exceed the construction noise level threshold? Source: (Urban Crossroads, 2024b)

Operational Noise Impacts – Stationary Noise

To demonstrate compliance with local noise regulations, the Revised Project operational noise levels were evaluated against exterior noise level thresholds based on the City of Orange exterior noise level standards at nearby noise- sensitive receiver locations. As shown i n Table 15, Revised Project Operational Noise Level Compliance, the Revised Project’s anticipated operational noise level w ould satisfy the City’s daytime and nighttime exterior noise level standards . Under the Revised Project, all receiver locations would result in a decrease in operational noise when compared to the Original Project except for Location R4. Impacts would remain less than significant. Therefore, the Revised Project would not result in the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects, other than those considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

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Table 15 Revised Project Operational Noise Level Compliance Receiver
Location1
Original Project
Operational Noise
Levels (dBA Leq)
Revised Project
Operational
Noise Levels (dBA
Leq)2
Noise Level Standards
(dBA Leq)3
Noise Level Standards
Exceeded?4

Daytime

Nighttime

Daytime Nighttime Daytime Nighttime Daytime Nighttime
R1 52.2 52.2 42.1 41.3 n/a n/a No No
R2 46.7 46.7 46.6 46.5 55 50 No No
R3 51.7 51.7 51.2 51.2 n/a n/a No No
R4 47.3 47.3 49.6 49.6 55 50 No No
R5 42.9 42.9 40.7 40.4 55 50 No No
R6 40.6 40.6 40.6 38.4 n/a n/a No No
1 See Figure 11, Noise Receiver Locations.
2 Proposed Project operational noise levels
3 Exterior noise level standards, as shown on Table 4-1 of the Noise and Vibration Analysis (Technical Appendix C). 4 Do the estimated Project operational noise source activities exceed the noise level standards? 5 The City of Orange Municipal Code does not identify any exterior noise level standards for non-residential land uses. "Daytime" = 7:00 a.m. - 10:00 p.m.; "Nighttime" = 10:00 p.m. - 7:00 a.m.

Source: (Urban Crossroads, 2024b)

Off-Site Traffic-Related Noise Impacts

As shown in Table 16, Existing with Revised Project Traffic Noise Level Increases , the Existing with Revised Project conditions would range from 62.8 to 73.1 dBA CNEL and the Revised Project off -site traffic noise level increases range from 0.0 to 4.5 dBA CNEL on the study area roadway segments. A s with the Original Project, the Revised Project traffic noise would not exceed the City’s applicable significance threshold under the Existing with Revised Project traffic conditions.

As shown in Table 17, Opening Year Cumulative with Revised Project Traffic Noise Level Increases, the Opening Year Cumulative with Revised Project conditions would range from 63.6 to 73.3 dBA CNEL and the Revised Project off -site traffic noise level increases range from 0.0 to 3.9 dBA CNEL .

As with the Original Project, the Revised Project traffic noise would not exceed the City’s applicable significance threshold under the Opening Year Cumulative with Revised Project traffic conditions.

Therefore, the Revised Project would not result in the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects, other than those considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

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Table 16 Existing with Revised Project Traffic Noise Level Increases ID Road Segment
CNEL at Receiving
Land Use (dBA)
Incremental Noise
Level Increase
Threshold
No
Project
With
Project
Project
Increment Limit Exceeded?
1 Main St. n/o W. Struck Av. 71.0 71.0 0.0 3.0 No
2 Main St. s/o W. 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 W. 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 W. Struck Av. w/o Main St. 68.0 68.0 0.0 3.0 No
12 W. Struck Av. e/o Main St. 62.7 62.8 0.1 5.0 No
13 W. Struck Av. e/o Batavia Av. 62.6 67.1 4.5 5.0 No
Source:(Urban Crossroads, 2024b)

Table 17 Opening Year Cumulative with Revised Project Traffic Noise Level Increases ID Road Segment
CNEL at Receiving
Land Use (dBA)
Incremental Noise
Level Increase
Threshold
No
Project
With
Project
Project
Increment Limit Exceeded?
1 Main St. n/o W. Struck Av. 71.1 71.1 0.0 3.0 No
2 Main St. s/o W. 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 W. 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 W. Struck Av. w/o Main St. 68.4 68.5 0.1 3.0 No
12 W. Struck Av. e/o Main St. 63.5 63.6 0.1 5.0 No
13 W. Struck Av. e/o Batavia Av. 63.6 67.5 3.9 5.0 No
Source:(Urban Crossroads, 2024b)

Mitigation Measures: Mitigation measures are not required.

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b) Generation of excessive groundborne vibration or groundborne noise levels?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that 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 would fall below the building damage thresholds at all noise sensitive receiver locations.

Under long- term operational 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. The Original Project’s construction and operational activities would not result in excessive groundborne vibration or groundborne noise levels. Impacts are less than significant.

Analysis of the Revised Project:

Construction-Related Vibration Impacts

Similar to the Original Project, construction activities for the Revised Project on the Project site would utilize heavy equipment that has the potential to generate low levels of intermittent, localized ground- borne vibration. The Revised 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 pas ses through residential neighborhoods on streets with bumps or potholes. Repairing the bumps and potholes generally eliminates the problem.

As discussed previously, since the Revised Project construction limits are identical to the Original Project construction limits, the worst -case construction equipment noise levels remain the same as the Original Project. As shown on Table 18, Revised Project Construction Equipment Vibration Levels, at distances ranging from 31 feet to 563 feet from construction activity , construction vibration levels are calculated to range from 0.001 PPV (in/sec) to 0.0064 PPV . Based on the maximum acceptable continuous vibration threshold of 0.3 PPV (in/sec), the Revised Project construction vibration levels would 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 would occur only during the times that heavy construction equipment is operating adjacent to the Project site perimeter. Therefore, the Revised Project-related vibration impacts are considered less than significant during typical construction activities at the P roject site. Therefore, the Revised Project would not result in the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects, other than those considered

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and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Table 18 Revised Project Construction Equipment Vibration Levels Location1
Distance
to
Const.

Activity
(Feet)2
Typical Construction Vibration Levels
PPV (in/sec)3 Thresholds
PPV
(in/sec)4
Thresholds
Exceeded?5 Small
bulldozer Jackhammer Loaded
Trucks
Large
bulldozer
Highest
Vibration
Level
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 are shown on Exhibit 10-A of the Noise and Vibration Analysis (Appendix C). 2 Distance from receiver to Project construction boundary. 3 Based on the Vibration Source Levels of Construction Equipment (Table 10-4 in Appendix C). 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, 2024b)

Operational Vibration Impacts

As with the Original Project, u nder long-term conditions, the Revised 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 Revised Project would not expose persons or generate excessive groundborne vibration or groundborne noise levels, and a less than significant impact would occur. Therefore, the Revised Project would not result in the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects, other than those considered and addressed in the 2023 Certif ied EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

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 project expose people residing or working in the project area to excessive noise levels?

Significance Determination: No Impact

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2023 Certified EIR Finding: The 2023 Certified EIR concluded that i mplementation of the Original Project does not have the potential to expose people residing or working in the Project area to excessive noise levels associated with air travel. No impacts would occur.

Analysis of the Revised Project: 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 Revised Project does not have the potential to expose people residing or working in the Project area to excessive noise levels associated with air travel. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

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14. POPULATION AND HOUSING.

Would the project:

(b) Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?

Impact Analysis:

a) Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Original Project is not anticipated to induce substantial unplanned population growth in the area . Impacts would be less-than- significant.

Analysis of the Revised Project: Similar to the Original Project, the Revised Project does not include any residential uses; therefore, the Revised Project does not have the potential to directly induce substantial unplanned population growth. Redevelopment of the Project site has the potential to generate up to 200 new jobs . The Revised Project’s proposed employees are not likely to relocate to the City, rather, the new jobs associated with the Project would provide employment opportunities for individuals already residing in the City.

The Revised Project involves redevelopment of the Project site with a permitted use within the Light Industrial land use designation and M -2 zoning classification. The Revised 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 serve s the Project site’s existing use. Consistent with the findings of the 2023 Certified EIR, the Project would not induce substantial indirect population growth in the area. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

b) Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?

Significance Determination: No Impact

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2023 Certified EIR Finding: The 2023 Certified EIR concluded that i mplementation of the Original Project would not displace any housing or people and no replacement housing would be required. No impacts would occur.

Analysis of the Revised Project: The conditions of the Project s ite and surrounding area are identical to the conditions that were described in the 2023 Certified EIR. The Project site is currently developed with an approximate 40,000 sf manufacturing facility and does not contain any residential structures .

Implementation of the Revised Project would not displace any housing or people and no replacement housing would be required. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

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15. PUBLIC SERVICES.

Was
Impact
Analyzed
in the 2023
Certified
EIR?
New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
New
Information
Requiring
New Analysis
or
Verification?
Does
2023
Certified
EIR
Address/
Resolve
Impacts?
(a) Would the project result in substantial adverse physical impacts associated with the provision of or need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain a cceptable service ratios, response times or other performance objectives for any of the public services:

i) Fire Protection?
ii) Police Protection?
iii) Schools?
iv) Parks?
v) Other public facilities?

Impact Analysis:

a) Would the project result in substantial adverse physical impacts associated with the provision of or 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?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that t he Original Project is not anticipated to result in the construction of new or physically altered fire facilities . The Original 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.

Analysis of the Revised Project: As disclosed in the 2023 Certified EIR, t he Orange City Fire Department (OCFD) provides fire and emergency response to the City, including the Project site.

As previously discussed, the Project Applicant proposes to demolish the existing on -site structure and redevelop the Project site with an approximate 214,956 sf light industrial warehouse building. Because fire protection services are currently provided to the surrounding area and based on the Project site’s close proximity to an existing fire station, the City’s existing fire protection facilities would adequately serve the Revised Project. Consistent with the findings of the 2023 Certified EIR, the Revised Project is not anticipated to result in the construction of new or physically altered fire facilities . The Revised Project 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. Additionally, the Revised 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.

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The Revised 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. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

ii) Police Protection?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Cert ified EIR concluded that implementation of the Original Project is not anticipated to result in the new or physically altered police protection facilities.

Additionally, the Project plans would be reviewed and approved by the City of Orange Building and Police Departments, which would ensure that adequate safety and crime prevention measures are provided within the Project’s design. Impacts would be less-than-significant.

Analysis of the Revised Project: As disclosed in the 2023 Certified EIR, t he City of Orange Police Department (OPD) provides law enforcement services to the City, including the Project site .

Implementation of the Revised Project is anticipated to result in similar service calls ( typical of an industrial facility) as the Original Project. Additionally, 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. To ensure adequate services are provided and to minimize the demands on police services, security and design measures that employ Defensible Space concepts would be incorporated into the Project. These measures incorporate the concepts of Crime Prevention though Environmental Design (CPTED), which considerations such as placement and orientation of structures, access and visibility of common areas, placement of doors, windows, addressing, and lands caping.

CPTED promotes public safety, physical security and allows citizens the ability to monitor activity in the area. It is based on five concepts to provide non- invasive and permanent measures to prevent and reduce crime: territoriality, natural surveillance, access control, activity support, and maintenance. Police protection impacts would be addressed by the incorporation of the OPD’s requirements to be included in the design of the project, adhering to the requirements contained in the City of Orange Municipal Code Chapter 15.52 Building Security Construction Standards reference Ordinance #6-22. The Revised Project plans would be reviewed and approved by the City of Orange Building and Police Departments.

Consistent with the findings of the 2023 Certified EIR , implementation of the Revised Project is not anticipated to result in the new or physically altered police protection facilities . Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

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iii) Schools?

Significance Determination: No Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that implementation of the Original Project does not have the potential to result in substantial direct growth in the population, nor an increase in student population. No impact would occur.

Analysis of the Revised Project: As disclosed in the 2023 Certified EIR, t he 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 . As discussed previously, implementation of the Revised Project does not have the potential to result in substantial direct growth in the population, nor an increase in student population. The Revised 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. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

iv) Parks?

Significance Determination: No Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Original Project would not introduce new residents to the City necessitating the need for additional parks. No impact would occur.

Analysis of the Revised Project: As disclosed in the 2023 Certified EIR, 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 miles southeast. Consistent with the findings of the 2023 Certified EIR, the Revised Project would not introduce new residents to the City necessitating the need for additional parks.

Mitigation Measures:

v) Other public facilities?

Significance Determination: No Impact

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2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Original Project would not introduce new residents to the City necessitating the need for additional libraries or demand for library services. No impact would occur.

Analysis of the Revised Project: As discussed previously and consistent with the findings of the 2023 Certified EIR, the Revised Project would not introduce new residents to the City necessitating the need for additional libraries or demand for library services. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

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16. RECREATION.

(b) Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment?

Impact Analysis:

a) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?

Significance Determination: No Impact

2023 Certified EIR Finding: 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 2023 Certified EIR concluded that the Original 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.

Analysis of the Revised Project: As with the Original Project, the Revised Project does not propose to construct any residential uses on the Project site. Consistent with the findings of the 2023 Certified EIR, the Revised 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. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

b) Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment?

Significance Determination: No Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Original Project does not include recreational facilities or require the construction or expansion of recreational facilities .

Implementation of the Original Project would not result in any adverse physical effects on the environment due to the construction of recreational facilities. No impact would occur.

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Analysis of the Revised Project: Similar to the Original Project, the Revised 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 . Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

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17. TRANSPORTATION.

Would the project:

Was Impact
Analyzed in
the 2023
Certified
EIR?
New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
New
Information
Requiring New
Analysis or
Verification?
Does
2023
Certified
EIR
Address/
Resolve
Impacts?
(a) Conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities?

(b) Would the project conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b)?
(c) Substantially increase hazards due to a geometric design feature (e. g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?

(d) Result in inadequate emergency access?

A Trip Generation Assessment, Vehicle Miles Traveled Assessment , and Updated Traffic Index Calculations were prepared for the Revised Project by Urban Crossroads to quantify the effects of Project-related traffic . These reports are included as Technical Appendices D through F to this EIR Addendum and their findings are incorporated into the analysis presented herein.

Trip Generation Comparison

The Original Project was approved to redevelop the Project site with a 57,900 square foot truck terminal building (consisting of 52,900 square feet of warehousing space and 5,000 square feet of office use) with 84 dock doors (in a cross-dock configuration). The Original Project was anticipated to generate 396 two- way trips per day, with 26 trips during the AM peak hour and 23 trips during the PM peak hour.

Based on the land use-specific vehicle trip generation rates published by the Institute of Transportation Engineers (ITE; ITE Code 150, Warehousing), the Revised Project would generate 372 two- way trips per day with 35 AM peak hour trips and 39 PM peak hour trips. The Revised Project is anticipated to result in a net reduction in daily trips of 24 two -way trips per day as compared to the Original Project, however, the Revised Project is anticipated to result in a net increase in both AM and PM peak hour trips as compared to the Original Project (9 AM peak hour trips and 16 PM peak hour trips). (Urban Crossroads, 2024c)

Impact Analysis:

a) Conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Original 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.

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Analysis of the Revised Project:

Truck Routes

As with the Original Project, the Revised Project would utilize routes consistent with the City’s truck routes. Additionally, the Revised Project would comply with the Original Project’s cond itions 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 Revised Project would not conflict with an applicable plan, ordinance, or policy addressing the circulation system. Im pacts would be less than significant.

Transit

The OCTA provides bus service for the City (Orange, 2015d). The nearest bus stop to the Project site is the Route 50 Katella-Batavia bus stop operated by OCTA located approximately 0. 3 miles northwest.

The City recognizes that ridership of bus systems would 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. Consistent with the Original Project, the Revised Project does not have the potential to interfere with the City’s goal to provide conve nient and attractive transit amenities and streetscape features to encourage transit use. No impacts would occur.

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 is not located within 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 W. Struck Avenue, except along the Project’s site frontage. Consistent with the existing pedestrian network, the Project Applicant proposes to install a sidewalk along the Project site’s frontage along W. Struck Avenue . Implementation of the Revised Project would not interfere with the City’s pedestrian -oriented streetscape master plan. Additionally, implementation of the Revised Project would not interfere with the City’s Bikeway Master Plan.

Implementation of the Revised Project would not conflict with an applicable plan, ordinance, or policy addressing the circulation system. Impacts would be less than significant. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

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b) Would the project conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b)? (In accordance with CEQA Guidelines Section 15064.3(c), the City of Orange, as the lead agency, will implement the provisions of Section 15064.3 of the CEQA Guidelines, which went into effect statewide beginning July 1, 2020.)

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Traffic Analysis Zone (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.

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

Analysis of the Revised Project: The City of Orange adopted 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 Planning and Research (OPR) in their Technical Advisory on Evaluating Transportation Impacts in CEQA (Urban Crossroads, 2024d).

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 anticipated 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 need s only to meet one of the above screening thresholds to result in a less than significant impact.

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” would 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 Revised Project meets any of the following secondary screening checks, the Revised Project would not meet the TPA Screening threshold:

• Has a FAR of less than 0.75;

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• 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.

The Revised Project’s proposed FAR would be less than 0.75; therefore, the Revised Project would not meet the TPA Screening threshold.

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. ” The Project is consistent with this criterion, since it is consistent with the existing land uses in the area. VMT performance for the TAZ s containing the Revised Project was collected using the Orange County Transportation Analysis Model (OCTAM). The TAZ containing the Revised Project (i.e., OCTAM TAZ #457) has an existing VMT per service population of 24.85 VMT per service population (Technical Appendix E) and the City’s impact threshold is 31.3 VMT per service population. The Revised Project has not been relocated out of OCTAM TAZ #457 and remains located in a TAZ that generates VMT below the City’s VMT impact threshold.

Based on the review of applicable VMT screening thresholds, the Revised Project meets the Low VMT Area screening criteria and would therefore result in a less than significant VMT impact; no additional VMT analysis is required.

Project Type Screening

The City Guidelines provide a list of project types that are presumed to have a less than significant impact absent substantial evidence to the contrary. Among the list of project types, projects that would attract less than 110 trips per day are assumed to cause a less than significant impact. The Revised 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. However, it should be noted that the trip generation results in a net reduction of 24 daily trips as compared to the Original Project.

Conclusion

The Project meets the Low VMT Screening threshold and is anticipated to exhibit a similar level of low VMT. Impacts would be less than significant. Therefore, the Revised Project would not result in any

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new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

c) Substantially increase hazards due to a geometric design feature (e. g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the Original Project would not create or substantially increase safety hazards due to a design feature or incompatible use. Impacts would be less than significant

Analysis of the Revised Project: As shown on Figure 12, Truck Circulation, the Project’s proposed truck driveways, located at the Project site’s northwest and northeast corners, would accommodate the wide turning radius of the heavy trucks . As with the Original Project, the Revised Project driveways would accommodate the wide turning radius of the heavy trucks (WB‐67, 53‐foot trailer) as currently designed. The Revised Project would not increase hazards and as such, impacts would be less than significant. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

d) Result in inadequate emergency access?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that all Original Project driveways would be subject to the City’s site access and circulation requirements identified in OMC Chapter 12, Streets, Sidewalks, and Public Places . 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 Original Project would provide adequate emergency access for fire vehicles via W. Struck Avenue. Impacts would be less than significant.

Analysis of the Revised Project:

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 Revised Project would have three driveways, similar to existing conditions and the Original Project , along W. Struck Avenue. Consistent with the Original Project, a ll Project driveways would be subje ct to the City’s site access and circulation requirements identified in OMC Chapter 12, Streets, Sidewalks, and Public Places . The Revised Project’s internal drive aisles would provide adequate access for emergency vehicles. Moreover, all construction staging would occur

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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 Revised Project would provide adequate emergency access for fire vehicles via W. Struck Avenue . Impacts would be less than significant.

Mitigation Measures: Mitigation measures are not required.

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18. TRIBAL CULTURAL RESOURCES.

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 landsc ape, sacred place, or object with cultural value to a California Native American Tribe, and that is:

(ii) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resources Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American Tribe?

Impact Analysis:

i) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k)?

ii) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1? In applying the criteria set forth in subdi vision (c) of Public Resources Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American Tribe.

Significance Determination: Less than Significant Impact with Mitigation Incorporated

2023 Certified EIR Finding: The 2023 Certified EIR concluded that 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 potentially significant.

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.

Analysis of the Revised Project: The condition of the Project site has not changed from what was analyzed in the 2023 Certified EIR. As indicated in the Cultural Resources section of this Addendum , the Project site is not included on the National Register of Historic Places, California Register of Historical Resources, or a local register of historical resources, nor is it eligible for listing. Accordingly,

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pursuant to subsection (c) of Public Resources Code Section 5024.1, the City of Orange has determined that the Project would not impact historical resources resulting from Project implementation.

Similar to the Original Project, b ecause the Revised 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 t ribal 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. To address the inadvertent discovery of tribal cultural resources, Mitigation Measure MM 4.11-1 from the 2023 Certified EIR has been incorporated into the Revised Project. This mitigation measure requires the presence of a Native American monitor during grading activities and the proper handling, treatment, and disposition of any discovered tribal cultural resources. With implementation of Mitigation Measure 4.11-1, impacts to tribal cultural resources would be less than significant.

The Project is exempt from the requirement to conduct new consultation pursuant to Assembly Bill 52 (AB 52) because AB 52 only requires consultation for projects that require a Negative Declaration, Mitigated Negative Declaration, or Environmental Impact Report. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measure:

MM 4.11-1 Prior to the commencement of any ground disturbing activity 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 the 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 activitie s 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 edu cational, cultural

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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 constitute 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 uni que archaeological resources.

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19. UTILITIES/SERVICE SYSTEMS.

Would the project: Was Impact
Analyzed in
the 2023
Certified
EIR?
New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
New
Information
Requiring New
Analysis or
Verification?
Does
2023
Certified
EIR
Address/
Resolve
Impacts?
(a) Require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunication facilities, the construction or relocation of which could cause significant environmental effects?

(b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years?

(c) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?

(d) Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?

(e) Comply with federal, state, and local management and reduction statutes and regulations related to solid wastes?

Impact Analysis:

a) Require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunication facilities, the construction or relocation of which could cause significant environmental effects?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the City’s existing water infrastructure and treatment facilities are adequate to serve the Project. 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.

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 the 2023 Certified EIR. 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 effect s. 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 networ ks 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.

Because the Project site has been previousl y developed with a manufacturing facility that requires electric power, natural gas, and telecommunication services, implementation of the Project is not anticipated to limit the ability of SCE, SoCalGas, or AT&T to

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provide service to Project . Therefore, the Project would not require or result in the construction or expansion of new facilities, and impacts would be less-than-significant.

Analysis of the Revised Project:

Water and Wastewater Treatment

Implementation of the Revised Project would demolish the existing approximately 40,000 sf manufacturing facility and redevelop the Project site with a single approximately 214,956 sf building.

The Revised Project would include internal wastewater lines that connect to the existing public 8 -inch sewer main along W. Struck Avenue that is operated by the City’s Public Works Department . Because the Project Applicant proposes to redevelop the Project 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 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 Revised Project’s fair share of costs to upgrade the City’s sewer system. Additionally, the Revised 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 Revised Project would result in new water and sewer line connections, these connections would occur on-site and would be part of the Revised Project’s construction phase, which is evaluated throughout this Addendum. 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 Addendum. Impacts would be less than significant.

Stormwater Drainage

Stormwater on-site would emulate the existing drainage pattern and would flow from the south to the north and to the northwest corner . The Revised Project would incorporate ribbon gutters along the proposed trailer parking areas on the south and east sides of the proposed building. Multiple inlets along the western and eastern ribbon gutter are proposed to collect flows and deposit them into the on- site storm drain facilities. All onsite runoff that is captured would be directed towards a proposed manhole located in the northwest corner of the Project site. The outlet structure is designed to divert the minimum water quality flow rate towards the proposed MWS vaults in order to treat for water quality requirements.

Refer to the analysis under Section 10, Hydrology and Water Quality Threshold c.ii, above. 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.

Dry Utilities

Under existing conditions, the Project site is served by SCE for electrical power, SoCal Gas for natural gas, and AT&T for telephone and fiber optics. Connections to the existing utility networks are available

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in the Project area and any off -site improvements would occur within improved rights -of-way, which are inherent to the Revised Project’s construction phase and have been evaluated throughout this Addendum. Where necessary, mitigation measures have been identified to reduce impacts to a level below significance. Consistent with the findings of the 2023 Certified EIR, because the Project site has been previously developed with a manufacturing facility that requires electric power, natural gas, and telecommunication services, implementation of the Revised Project is not anticipated to limit the ability of SCE, SoCalGas, or AT&T to provide service to Project. The Revised Project would not require or result in the construction or expansion of new facilities, and impacts would be less than significant.

Mitigation Measures: Mitigation measures are not required.

b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the water demand associated with the Original Project was considered in the demand anticipated by the 2015 UWMP and analyzed therein.

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 Original Project from existing entitlements/resources and no new or expanded entitlements are needed. Impacts would be less-than-significant.

Analysis of the Revised Project: Because the Project Applicant would redevelop the site with a use permitted under the Light Industrial land use designation, the Revised Project would be consistent with the City’s General Plan and, therefore, the water demand associated with the Revised Project was considered in the demand anticipated by the 2020 UWMP and analyzed therein. As disclosed previously in the 2023 Certified EIR, the City is anticipated to have adequate water supplies to meet all its demands until the year 2045 under a normal year, single dry year, and multiple dry years . Consistent with the findings of the 2023 Certified EIR, the City has sufficient water supplies available to serve the Revised Project from existing entitlements/resources and no new or expanded entitlements are needed . Impacts would be less than significant. Therefore, the Revised Project would not result in any new, increased or substantially differen t impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

c) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?

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Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the wastewater generation associated with the Original 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 Original Project’s project demand in addition to its existing commitments. Impacts would be less-than-significant.

Analysis of the Revised Project: Similar to the Original Project, the Project Applicant would redevelop the Project site with a use that is consistent with the Project site’s underlying land use designation; therefore, the wastewater generation associated with the Revised 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 t o serve the Revised Project’s demand in addition to its existing commitments. Impacts would be less than significant. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

d) Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The Original Project construction phase was calculated to generate approximately 0.31 tons of solid waste per day requiring landfill during its construction phase and 0.23 tons of solid waste per day during operation. The 2023 Certified EIR concluded that Project construction and operation are not anticipated to cause these landfills to exceed their maximum daily permitted solid waste amounts. Impacts would be less-than-significant.

Analysis of the Revised Project: As disclosed in the 2023 Certified EIR, 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.

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 31, 2036; 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, 2024a; CalRecycle, 2024b; CalRecycle, 2024c)

Similar to the Original Project, implementation of the Revised Project would generate an incremental increase in solid waste volumes requiring off-site disposal during short-term construction and long-term

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operational activities. Additionally, the Revised Project would be required to comply with mandatory waste reduction requirements (AB 341, AB 1826, and SB 1383) as described below in Utilities and Service Systems Threshold e.

Construction Impact Analysis

Solid waste requiring disposal would be generated by the construction process, primarily consisting of discarded demolition materials and packaging.

Based on the size of the Revised Project (214,956 sf and 450 sf pump room), existing building (40,000 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 554.23 tons of waste is calculated to be generated during the Project’s construction phase ([ 255,406 sf x 4.34 lbs/sf]/2,000 lbs/ton = 554.23 tons) (EPA, 2009, p. 10) . Materials generated from construction projects must be recycled to meet statuary obligations under various State legislation and California Green Building Codes, which require 65% of all debris to be diverted from the landfill; therefore, the Revised Project would result in approximately 193.98 tons of construction debris that would be send to a landfill . The Revised Project has a construction schedule of 16 months or approximately 487 days and would generate approximately 0.4 tons of solid waste per day requiring landfill during its construction phase (193.98 tons/487 days = 0.4 tons per day).

Although the Revised Project would generate more non-recyclable construction waste compared to the Original Project, landfills have sufficient daily capacity to accept the solid waste. The Revised Project’s estimated total construction solid waste would represent approximately 0.005 percent of the daily tpd at Olinda Alpha Landfill, 0.003 percent at the Frank R. Bowerman Landfill, and 0.01 percent at the Prima Deshecha Landfill. The 3 landfills have sufficient daily capacity to accept solid waste generated by the Revised Project’s construction phase. Impacts would be less than significant.

Operational Impact Analysis

Based on a daily waste generation factor of 1.42 lbs of waste per 100 sf of industrial building per day obtained from CalRecycle, long- term, on-going operation of the Revised Project would generate up to approximately 1.50 tons ([214,956 sf x {1.42 lbs/100sf}]/2,000 lbs/ton= 1.53 tons) of solid waste per day (CalRecycle, 2006). Implementation of the Revised Project would result in an approximately 1.53- ton net increase in solid waste generation . Consistent with the findings of the 2023 Certified EIR, although the implementation of the Revised Project would increase the amount of solid waste generated at the Project site, the Revised Project’s projected solid waste would be well below the Frank R.

Bowerman, Olinda Alpha Landfill and Prima Deshecha Landfill daily disposal volume . Additionally, according to AB 939, at least 50 percent of the Revised Project’s solid waste is required to be diverted from landfills; therefore, the Revised Project would generate approximately 0.77 tons of solid waste per day requiring landfilling (1.53 tons per day x 50% = 0.77 tons per day).

The non-recyclable solid waste generated during the long- term operation of the Revised Project would be disposed at 1 of the 3 landfills identified above. The Revised Project’s estimated solid waste is well below the maximum daily capacities of any of the 3 landfills. The Revised Project is not anticipated to

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cause these landfills to exceed their maximum daily permitted solid waste amounts . Impacts would be less than significant.

Mitigation Measures: Mitigation measures are not required.

e) Comply with federal, state, and local management and reduction statutes and regulations related to solid wastes?

Significance Determination: Less than Significant Impact

2023 Certified EIR Finding: The 2023 Certified EIR conclude d that t he implementation of these mandatory requirements would reduce the amount of solid waste generated by the Original Project and diverted to landfills, which in turn will aid in the extension of the life of affected disposal sites. The Original Project would be required to comply with all applicable solid waste statutes and regulations .

Impacts would be less-than-significant.

Analysis of the Revised Project: As disclosed in the 2023 Certified EIR , in accordance with the California Solid Waste Reuse and Recycling Act of 1991 (Cal Pub Res. Code Section 42911), the Revised Project is required to provide adequate areas for collecting and loading recyclable materials where solid waste is collected. The collection areas are required to be shown on construction drawings and be in place before occupancy permits are issued. AB 1826 Chesbro (Chapter 727, Statutes of 2014) requires businesses to recycle their organic waste depending on the amount of waste they generate per week. Local jurisdictions across the state are required to implement an organic waste recycling program to divert organic waste generated by businesses, including multifamily residential dwellings that consist of five or more units (note, however, that multifamily dwellings are not required to have a food waste diversion program). SB 1383 requires jurisdictions (cities, counties, cities and counties, or special districts that provide solid waste collection services) to purchase recycled -content paper products that are recyclable. Additionally, in compliance with AB 341 (Mandatory Commercial Recycling Program), the future occupant of the Revised 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 soli d waste generated by the Revised Project and diverted to landfills, which in turn would aid in the extension of the life of affected disposal sites. The Revised Project would be required to comply with all applicable solid waste statutes and regulations .

Impacts would be less than significant. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

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20. WILDFIRE.

If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:

Was Impact
Analyzed in
the 2023
Certified
EIR?
New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
New
Information
Requiring
New Analysis
or
Verification?
Does
2023
Certified
EIR
Address/
Resolve
Impacts?
(a) Substantially impair an adopted emergency response plan or emergency evacuation plan?
(b) Due to slope prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?

(c) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?

(d) Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?

Impact Analysis:

If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:

a) Substantially impair an adopted emergency response plan or emergency evacuation plan?

b) Due to slope prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?

c) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?

d) Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?

Significance Determination: No Impact

2023 Certified EIR Finding: The 2023 Certified EIR concluded that t he State Responsibility Area (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 . Additionally, according to CalFire, the Project site is not within a Very High Fire Hazard Severity Zone (VHFHSZ). As such, no impacts related to wildfire would occur.

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Analysis of the Revised Project: The wildfire hazards zones have not changed since the approval of the Original Project. As with the 2023 Certified EIR, and according to CalFire, the Project site is not within a VHFHSZ (CalFire, 2024). As such, no impacts related to wildfire would occur. Therefore, the Revised Project would not result in any new, increased or substantially different impacts, other than those previously considered and addressed in the 2023 Certified EIR. No changes or additions to the 2023 Certified EIR are necessary.

Mitigation Measures: Mitigation measures are not required.

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21. MANDATORY FINDINGS OF SIGNIFICANCE.

Was Impact
Analyzed in
the 2023
Certified
EIR?
New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
New
Information
Requiring New
Analysis or
Verification?
Does
2023
Certified
EIR
Address/
Resolve
Impacts?
(a) Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a p
lant or animal
community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory?

(b) Does the project have impacts that are individually limited, but cumulatively considerable ? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects?)

s(c) Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly?

Impact Analysis:

a) Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self -sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory?

Significance Determination: Less than Significant Impact with Mitigation Incorporated

2023 Certified EIR Finding: The 2023 Certified EIR concluded that , after implementation of mitigation, the Original Project would result in less than significant impacts to wildlife and habitats.

Additionally, the 2023 Certified EIR concluded that, after implementation of mitigation, the Original Project would result in less than significant impacts to archaeological, paleontological, and tribal cultural resources and would not eliminate important examples of major periods of California history or prehistory.

Analysis of the Revised Project: The Revised Project would have the same development impact area as the Original Project and would result in the same construction -related impacts. As indicated throughout the analysis presented herein, the Revised Project would not substantially degrade the quality of the environment, substantially reduce the habitat of fish or wildlife species, cause a fish or wildlife populations to drop below self-sustaining levels, threaten to eliminate a plant or animal community, or reduce the number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of California history or prehistory, to a greater degree than previously disclosed in the 2023 Certified EIR.

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b) Does the project have impacts that are individually limited, but cumulatively considerable ? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects?)

Significance Determination: Less than Significant Impact with Mitigation Incorporated

2023 Certified EIR Finding: The 2023 Certified EIR addressed cumulative impacts for each of the environmental topics evaluated. The Original Project would not result in any significant cumulative impacts.

Analysis of the Revised Project: As described throughout this analysis, the Revised Project would not result in new environmental impacts that were not previously disclosed in the 2023 Certified EIR and would not increase the severity of environmental impacts disclosed in the 2023 Certified EIR. Therefore, there is no potential for the Revised Project to result in cumulatively considerable effects on the environment.

c) Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly?

Significance Determination: Less than Significant Impact with Mitigation Incorporated

2023 Certified EIR Finding: The 2023 Certified EIR concluded that the planning, construction, and operation of the Original Project would not result in environmental effects that would cause substantial adverse effects on human beings, either directly or indirectly, following incorporation of mitigation.

Analysis of the Revised Project: As discussed throughout this Addendum , the Revised Project’s potential impacts were evaluated with respect to 20 environmental topical areas . Mitigation Measures were required to reduce temporary construction-related impacts related to biological resources, cultural resources, paleontological resources, and tribal cultural resources. As discussed, there is a potential for the Project site to contain impacted soil or other subsurface features (pits, sumps, clarifies, or USTs) that may need to be appropriately and expeditiously managed due to additional agency oversight and/or any permitting necessary to properly abandon such features. In order to ensure public and worker safety, an SMP was prepared (Appendix H3 of the 2023 Certified EIR) to provide procedures for efficiently managing potentially impacted soils and/or USTs during site preparation activities . Implementation of Mitigation Measure MM 4.7-1 would ensure compliance with the SMP, which would reduce potential impacts related to routine transport, use, or disposal of contaminated or potentially contaminated soils to less than significant. Therefore, with implementation of standard conditions and mitigation measures, the Revised Project would not result in environmental impacts that would cause substantial adverse effects on human beings, either directly or indirectly, beyond those impacts already disclosed in the 2023 Certified EIR.

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4.0 REFERENCES

California Department of Forestry and Fire Protection (CalFire). 20 24. Fire Hazard Severity Zones in State Responsibility Area . Web. Accessed September 10, 2024. Available: https://calfire - forestry.maps.arcgis.com/apps/webappviewer/index.html?id=988d431a42b242b29d89597ab6 93d008

California Department of Resources Recycling and Recovery (CalRecycle). 2006. Estimated Solid Waste Generation Rates. Web. Accessed September 10, 2024. Available:
https://www2.calrecycle.ca.gov/WasteCharacterization/General/Rates

———. 2024a. Olinda Alpha Landfill. Web. Accessed September 10, 2024. Available:
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/2757?siteID=2093

———. 2024b. Frank R. Bowerman Landfill. Web. Accessed September 10, 2024. Available:
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/2767?siteID=2103

———. 2024c. Pima Deschecha Landfill. Web. Accessed September 10, 2024. Available:
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/2750?siteID=2085

California Department of Transportation (Caltrans). 2019. California State Scenic Highway System Map.

Web. Accessed September 10, 2024. Available:
https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e805 7116f1aacaa

California Department of Water Resources (DWR). 2020. Groundwater Sustainability Plans . Web.

September 10, 2024. Available: https://water.ca.gov/Programs/Groundwater- Management/SGMA-Groundwater-Management/Groundwater-Sustainability-Plans

Environmental Protection Agency (EPA). 2009. Estimating 2003 Building- Related Construction and Demolition Materials Amounts . Web. Accessed September 10, 2024. Available:
https://www.epa.gov/sites/production/files/2017-
09/documents/estimating2003buildingrelatedcanddmaterialsamounts.pdf

Federal Emergency Management Agency (FEMA). 2009. FEMA Flood Map Service Center . Accessed September 10, 2024. Retrieved from https://msc.fema.gov/portal/home

Google Earth. 2024. Google Earth Pro.

City of Orange (Orange). 2010. Program Environmental Impact Report Orange General Plan. Web.

Accessed September 10, 2024 . Available:
https://www.cityoforange.org/home/showpublisheddocument/240/637698173340500000

———. 2010b. General Plan Public Safety Element . Web. Accessed September 10, 2024. Available:
https://www.cityoforange.org/home/showpublisheddocument/214/637698172567530000

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———. 2015a. General Plan Land Use Element . Web. Accessed September 10, 2024. Available:
https://www.cityoforange.org/home/showpublisheddocument/208/637698172555630000

———. 2015b. General Plan Natural Resources Element . Web. Accessed September 10, 2024 .

Available:
https://www.cityoforange.org/home/showpublisheddocument/210/637698172559270000

———. 2015c. General Plan Cultural Resources & Historic Preservation . Web. Accessed September 10, 2024 . Available:
https://www.cityoforange.org/home/showpublisheddocument/196/637698172534300000

———. 2015d. General Plan Circulation and Mobility Element. Web. Accessed September 10, 2024.

Available:
https://www.cityoforange.org/home/showpublisheddocument/192/637698172525970000

———. 2020. Zoning Map . Web. Accessed September 10, 2024. Available:
https://www.cityoforange.org/home/showpublisheddocument/40/637707607413300000

———. 2021. 2020 Urban Water Management Plan. Web. Accessed September 10, 2024. Available:
https://wuedata.water.ca.gov/getfile?filename=/public%2Fuwmp_attachments%2F394869774 5%2FOrange%202020%20UWMP%20FINAL-2021.11.16.pdf

———. 2024. City of Orange Municipal Code. Web. Accessed September 10, 2024. Available:
https://ecode360.com/OR5214

Urban Crossroads, Inc. 2024a. Supplemental Air Quality, Greenhouse Gas, and Health Risk Assessment.

December 10, 2024. Technical Appendix A.

———. 2024b. 534 Struck Avenue Noise and Vibration Analysis City of Orange. December 11, 2024.

Technical Appendix C

———. 2024c. 534 Struck Avenue Trip Generation Assessment. August 27, 2024. Technical Appendix D

———. 2024d. 534 Struck Avenue Vehicle Miles Traveled (VMT) Screening Evaluation. August 27, 2024. Technical Appendix E

———. 2024e. Updated Traffic Index Calculations. December 9, 2024. Technical Appendix F

Albert A. Webb Associates (Webb), 2024a. Preliminary Water Quality Management Plan For 534 Struck Ave Redevelopment Project (WQMP), September 2024. Technical Appendix B.1

———. 2024b. 534 W. Struck Ave Final Drainage Study. April 2024. Technical Appendix B.2

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PREPARERS AND PERSONS CONSULTED

Lead Agency, Agencies, and Organizations

City of Orange (Lead Agency)
300 E. Chapman Avenue
Orange, CA 92866

Russell Bunim, Director of Community Development
Anna Pehoushek, Assistant Community Development Director Monique Schwartz, Senior Planner
Robert Garcia, Senior Planner
Maria Prado Flores, Associate Engineer

Project Applicant and Consultants

Prologis (Project Applicant)
2141 Rosecrans Ave, Suite 1151
El Segundo, CA 90245

Maggie Xu, Director of Project Management

T&B Planning, Inc. (CEQA Consultant)
3200 El Camino Real, Suite 100
Irvine, CA 92602

Nicole Morse, Esq, Principal
Tracy Chu, Project Manager
Justin Nguyen, Environmental Analyst
Cristina Maxey, GIS/Graphics Manager
Rhea Smith, GIS/Graphics Technician

Urban Crossroads, Inc. (Air Quality, Greenhouse Gas, Energy, Health Risk Assessment, Noise , and Traffic Consultant)
260 E. Baker Street, Suite 200
Costa Mesa, CA 92626

Aric Evatt, PTP, President
Charlene So, PE, Associate Principal
Haseeb Qureshi, Associate Principal
Bill Lawson, PE, Principal

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Albert A. Webb Associates (Hydrology and Water Quality Consultant) 3788 McCray Street
Riverside, CA 92506

Joshua S. Lesinski, PE, Senior Engineer

5-1

5.0 MITIGATION MONITORING AND REPORTING PROGRAM

PROJECT NAME: 534 W. STRUCK AVENUE WAREHOUSE PROJECT
PROJECT LOCATION: 534 W. STRUCK AVENUE, ORANGE, CA
PROJECT DESCRIPTION: The Project entails the demolition of the site’s existing 40,000 sf manufacturing facility and associated structures to redevelop the site with an approximately 214,956 sf building with associated parking and improvements.

LEAD AGENCY: CITY OF ORANGE
CONTACT PERSON/TELEPHONE NO.: MONIQUE SCHWARTZ, SENIOR PLANNER (714) 744-7231

APPLICANT: PROLOGIS
CONTACT PERSON/TELEPHONE NO.: MAGGIE XU, DIRECTOR OF PROJECT DEVELOPMENT (310) 338-3273

No.

Mitigation Measure

Time Frame and
Responsible Party
for
Implementation

Time Frame and
Responsible
Party for
Monitoring

Verification of Compliance

Initials

Date

Remarks
Air Quality
The Project would not result in significant adverse impacts related to air quality. No mitigation is required.

Biological Resources
MM

4.2-1
In the event that vegetation and tree removal should
occur between March 15 and September 1, the
Project Applicant shall retain a qualified biologist to conduct a nesting bird survey no more than 3 days
prior to commencement of construction activities.

The biologist conducting the clearance survey shall
document the negative results if no active bird nests
are observed on the Project site or within the vicinity during the clearance survey with a brief letter report, submitted to the City of Orange Community
Development Department prior to construction,
indicating that no impacts to active bird nests would
Prior to construction;
Project
Applicant/Project
Biologist
Prior to the
commencement of
construction
activities and the
issuance of any
permit; City of
Orange Director of
Community
Development

5-2

No.

Mitigation Measure

Time Frame and
Responsible Party
for
Implementation

Time Frame and
Responsible
Party for
Monitoring

Verification of Compliance

Initials

Date

Remarks
occur before construction can proceed. If an active
avian nest is discovered during the pre-construction
clearance survey, construction activities shall stay
outside of a 200-foot buffer around the active nest.

For listed and raptor species, this buffer shall be 500- feet. A biological monitor shall be present to
delineate the boundaries of the buffer area and to
monitor the active nest to ensure that nesting behavior is not adversely affected by the construction activity.

Prior to the commencement of construction activities
and the issuance of any permits, results of the pre-
construction survey and any subsequent monitoring
shall be provided to the City of Orange Community
Development Department.

4.2-2
Prior to approval of a grading permit, a note shall be
placed on grading plans that “no personnel working
within Project limits will “take” or destroy plants,
animals, or active nests (or eggs) of birds that are
protected under the Federal or State Endangered
Species Acts and Migratory Bird Treaty Act
(MBTA).” During pre-construction surveys, a
biologist shall train all field staff on appliable local, state, and federal regulatory requirements,
environmental laws, and regulations associated with
working around biological resources. Verification of
training shall be provided to the Community
Development Director.

Prior to approval of a
grading permit;
Project Biologist
Prior to approval of
a grading permit and
during pre-
construction
surveys; City of
Orange Director of
Community
Development

Cultural Resources
MM

4.3-1
In the event a potentially significant cultural resource is encountered during subsurface earthwork activities,
all construction activities within a 100-foot radius of the find shall cease and workers should avoid altering
the materials until a qualified archaeologist who
During subsurface
earthwork activities;
Project
Applicant/Project
Archaeologist
In the event a
potentially significant
cultural resource is
encountered during
subsurface earthwork

5-3

No.

Mitigation Measure

Time Frame and
Responsible Party
for
Implementation

Time Frame and
Responsible
Party for
Monitoring

Verification of Compliance

Initials

Date

Remarks
meets the Secretary of Interior’s Professional
Qualification Standards for archaeology has
evaluated the resource. The Applicant shall include a
standard inadvertent discovery clause in every
construction contract to inform contractors of this
requirement. Any previously undiscovered resource
found during construction-related activities shall be
recorded on the appropriate Department of Parks and
Recreation (DPR) forms and evaluated for
significance in terms of CEQA criteria by a qualified
archaeologist. Potentially significant cultural
resources consist of but are not limited to stone, bone, glass, ceramics, wood, or shell artifacts, or features
including hearths, structural remains, or historic
dumpsites. If the resource is determined to be
significant under CEQA Guidelines Section 15064.5,
the qualified archaeologist shall prepare and
implement a research design and archeological data
recovery plan that will capture those categories of
data for which the site is significant in accordance
with Section 15064.5 of the State CEQA Guidelines.

The archaeologist shall also perform appropriate
technical analyses, prepare a comprehensive report
complete with methods, results, and
recommendations, and provide for the permanent
curation or repatriation of the recovered resources in
cooperation with the designated most likely
descendant as needed. The report shall be submitted
to the City of Orange, the South-Central Coastal
Information Center, and the State Historic
Preservation Office, if required.

activities; City of
Orange Director of
Community
Development

5-4

No.

Mitigation Measure

Time Frame and
Responsible Party
for
Implementation

Time Frame and
Responsible
Party for
Monitoring

Verification of Compliance

Initials

Date

Remarks
Energy
The Project would not result in significant adverse impacts related to energy. No mitigation is required.

Geology and Soils
MM

4.5-1
Prior to the issuance of a grading permit, the
Applicant shall provide written evidence to the
Community Development Department that the
Applicant has retained a qualified paleontologist to
respond on an as-needed basis to address
unanticipated paleontological discoveries.

If determined to be significant, the fossil shall be
collected and prepared to the point of identification,
identified to the lowest taxonomic level possible,
cataloged, and curated into the permanent collections
of a museum repository. At the conclusion of
curation, a report of findings shall be prepared to
document the results of the monitoring program.

Construction shall not resume within the vicinity until the site paleontologist states in writing that the
proposed construction activities would not
significantly damage paleontological resources.

Prior to the issuance
of a grading permit;
Project
Applicant/Project
Paleontologist
Prior to the issuance
of a grading permit;
City of Orange
Director of
Community
Development

Greenhouse Gas Emissions
The Project would not result in significant adverse impacts related to greenhouse gas emissions. No mitigation is required.

Hazards and Hazardous Materials
MM

4.7-1
The Project Contractor shall adhere to the protocols
and performance standards stipulated in the SMP
During construction;
Project Contractor
Prior to issuance of
building permits;

5-5

No.

Mitigation Measure

Time Frame and
Responsible Party
for
Implementation

Time Frame and
Responsible
Party for
Monitoring

Verification of Compliance

Initials

Date

Remarks
(Technical Appendix H3). Contractors working at the
site follow all applicable Cal/OSHA regulations for
construction safety. A Completion Report shall be
prepared at the conclusion of grading activities. The
report shall document field monitoring activities and
visual observations made during grading/excavations,
as well as soil sampling locations and results. The
report shall include a description of the location of
impacted soil encountered, actions taken to
characterize and mitigate impacts, confirmation soil
sampling results, and disposition of any excavated
soil. In addition, the report shall include a description of encountered subsurface structures and steps to
remove and close such structures. The report shall be
reviewed and approved by the City of Orange
Community Development Director, prior to issuance
of building permits.

City of Orange
Director of
Community
Development

Hydrology and Water Quality
The Project would not result in significant adverse impacts related to hydrology and water quality. No mitigation is required.

Noise
The Project would not result in significant adverse impacts related to noise. No mitigation is required.

Transportation
The Project would not result in significant adverse impacts related to transportation. No mitigation is required.

Tribal Cultural Resources
MM

4.11-1
Prior to the commencement of any ground disturbing
activity 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
Prior to the
commencement of
any ground disturbing
activity; Project
Applicant/Native
Prior to issuance of
any permits
necessary to
commence a ground-
disturbing activity;

5-6

No.

Mitigation Measure

Time Frame and
Responsible Party
for
Implementation

Time Frame and
Responsible
Party for
Monitoring

Verification of Compliance

Initials

Date

Remarks
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
the 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 American Monitor City of Orange
Director of
Community
Development

5-7

No.

Mitigation Measure

Time Frame and
Responsible Party
for
Implementation

Time Frame and
Responsible
Party for
Monitoring

Verification of Compliance

Initials

Date

Remarks
manner the Tribe deems appropriate, for educational,
cultural 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 constitute 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.

5-8
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6-1

6.0 APPENDICES (Provided Electronically)

Appendix A Urban Crossroads, Inc. 2024. 534 Struck Avenue Supplemental Air Quality, Greenhouse Gas, and Health Risk Assessment. December 10, 2024

Appendix B.1 Albert A. Webb Associates (Webb), 2024. Preliminary Water Quality Management Plan For 534 Struck Ave Redevelopment Project (WQMP) , September 2024

Appendix B.2 Albert A. Webb Associates (Webb), 2024. 534 W. Struck Ave Final Drainage Study. April 2024.

Appendix C Urban Crossroads, Inc. 2024. 534 Struck Avenue Noise and Vibration Analysis City of Orange. December 11, 2024.

Appendix D Urban Crossroads, Inc. 2024. 534 Struck Avenue Trip Generation Assessment .

August 27, 2024

Appendix E Urban Crossroads, Inc. 2024. 534 Struck Avenue Vehicle Miles Traveled (VMT) Screening Evaluation. August 27, 2024

Appendix F Urban Crossroads, Inc. 2025. Updated Traffic Index Calculations . January 21, 2025

Orange City CouncilSeptember 9, 2025

Orange City Council
September 9, 2025