Agenda packet — Orange City Council, May 26, 2026 (part 2 of 10)

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168
Agenda Item
Orange City Council
Item #: 3.12. 5/26/2026 File #: 26-0291
TO: Honorable Mayor and Members of the City Council
THRU: Jarad Hildenbrand, City Manager
FROM: Alan Velasco, Fire Chief

1. SUBJECT
Authorize an increase to an existing purchase order for safety gear and equipment supporting Fire Operations and the Emergency Medical Transport Program

2. SUMMARY
Request to authorize an increase of $103,500 to an existing purchase order with LineGear Fire & Rescue Equipment for the total purchase order amount to $218,500.

3. RECOMMENDED ACTION
Approve an increase to a blanket purchase order for a total not-to-exceed amount of $218,500 with LineGear Fire & Rescue Equipment for safety gear and equipment.

4. FISCAL IMPACT
The total expense for the blanket purchase order is $218,500, of which $115,000 has already been encumbered. The additional increase is $103,500 and will be funded through the available California State Office of Emergency Services Strike Team Deployment Administrative Recovery funds and the EMT Transport Fund (225), respectively:
100-3121-54101-253012 Cal OES Admin Recovery Fee $ 80,000 225-3216-54101 Noncapitalize Equipment $ 20,000
225-3216-53102 Uniforms & Clothing $ 3,500
Total: $103,500

5. STRATEGIC PLAN GOALS
Goal 1: Maintain Strong Emergency and Safety Services.

6. DISCUSSION AND BACKGROUND
The Fire Department purchases safety gear and equipment from a select group of vendors, with LineGear Fire & Rescue Equipment (LineGear) serving as one of the primary providers. LineGear supplies the current and approved specifications for uniforms for firefighters, fire prevention, and ambulance operators, as well as wildland firefighting gear including boots, helmets, gloves, brush jackets, pants, and web gear. Through a cooperative purchasing agreement, LineGear offers a wide range of products and brands at competitive pricing.

In anticipation of incoming new ambulance operators, as well as the need to procure additional wildland uniforms and personal protective equipment (PPE) in preparation for wildfire season, an increase to the purchase order with LineGear is necessary to ensure adequate funding for the remainder of Fiscal Year 2025-2026. Additional funding is also required to replace expired web gear, City of Orange Page 1 of 2 Printed on 5/21/2026
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Item #: 3.12. 5/26/2026 File #: 26-0291
remainder of Fiscal Year 2025-2026. Additional funding is also required to replace expired web gear, which is mandatory for all personnel assigned to wildland deployments. The Orange City Fire Department has an ongoing operational need for wildland uniforms and PPE, as the department plays a critical role in statewide wildfire response efforts. In 2024 and 2025, OFD deployed 239 personnel across 44 incidents, totaling 42,736 personnel hours.

Staff respectfully request that the City Council authorize a $103,500 increase to the existing purchase order with LineGear. The Fire Department currently has an open purchase order totaling $115,000.

Approval of the additional $103,500 will increase the total to $218,500, to be funded through the EMT Transport Fund and Administrative Recovery funds received from the California Office of Emergency Services for Strike Team deployments.

7. ATTACHMENTS
· None
City of Orange Page 2 of 2 Printed on 5/21/2026
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Agenda Item
Orange City Council
Item #: 3.12. 5/26/2026 File #: 26-0291
TO: Honorable Mayor and Members of the City Council
THRU: Jarad Hildenbrand, City Manager
FROM: Alan Velasco, Fire Chief

1. SUBJECT
Authorize an increase to an existing purchase order for safety gear and equipment supporting Fire Operations and the Emergency Medical Transport Program

2. SUMMARY
Request to authorize an increase of $103,500 to an existing purchase order with LineGear Fire & Rescue Equipment for the total purchase order amount to $218,500.

3. RECOMMENDED ACTION
Approve an increase to a blanket purchase order for a total not-to-exceed amount of $218,500 with LineGear Fire & Rescue Equipment for safety gear and equipment.

5. STRATEGIC PLAN GOALS
Goal 1: Maintain Strong Emergency and Safety Services.

In anticipation of incoming new ambulance operators, as well as the need to procure additional wildland uniforms and personal protective equipment (PPE) in preparation for wildfire season, an increase to the purchase order with LineGear is necessary to ensure adequate funding for the remainder of Fiscal Year 2025-2026. Additional funding is also required to replace expired web gear, City of Orange Page 1 of 2 Printed on 5/21/2026
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Item #: 3.12. 5/26/2026 File #: 26-0291
remainder of Fiscal Year 2025-2026. Additional funding is also required to replace expired web gear, which is mandatory for all personnel assigned to wildland deployments. The Orange City Fire Department has an ongoing operational need for wildland uniforms and PPE, as the department plays a critical role in statewide wildfire response efforts. In 2024 and 2025, OFD deployed 239 personnel across 44 incidents, totaling 42,736 personnel hours.

7. ATTACHMENTS
· None
City of Orange Page 2 of 2 Printed on 5/21/2026
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Agenda Item
Orange City Council
Item #: 3.13. 5/26/2026 File #: 26-0282
TO: Honorable Mayor and Members of the City Council
FROM: Jarad Hildenbrand, City Manager

1. SUBJECT
Approval of the Santiago Creek Commission’s proposed Santiago Creek Strategic Plan implementation strategy

2. SUMMARY
On February 24, 2026, the Orange City Council adopted the Santiago Creek Strategic Plan, and directed the Santiago Creek Commission to bring back alternatives to help put the Santiago Creek Strategic Plan into action. After considering different options, the City Council directed the Commission to work with Townsend Public Affairs (TPA) and community groups to develop an implementation strategy for the City Council’s consideration. The Santiago Creek Commission has developed the attached implementation strategy for the City Council’s consideration and approval.

3. RECOMMENDED ACTION
Approve the Santiago Creek Commission’s proposed Santiago Creek Strategic Plan implementation strategy.

4. FISCAL IMPACT
None.

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

Goal 5: Improve Infrastructure, Mobility, and Technology.

6. DISCUSSION AND BACKGROUND
At the April 22, 2026, Santiago Creek Commission (Commission) meeting, the Commission discussed different implementation options for the Santiago Creek Strategic Plan (Plan). After discussing the options presented by staff, the Commission voted to create three subcommittees that focus on distinct topics detailed in the Plan. The topics include the following three categories with the correlating Plan project numbers identified under the column “Project Numbers.” Subcommittee Topic Project Numbers
Ecological Preservation and
Restoration
Project Nos. 1.1, 1.4, 1.9, 2.1, 3.10
Historical, Cultural, and Archeological Project Nos. 1.1, 1.4, 1.9, 2.1, 3.10 Recreational Enhancement and Safety Project Nos. 1.2, 1.3, 1.5, 1.8, 1.10, 1.11, 2.2,

2.3, 2.5, 2.6, 2.7, 2.8, 2.9, 2.11, 3.2, 3.3, 3.4,

3.5, 3.7, 3.8, 3.9
City of Orange Page 1 of 2 Printed on 5/21/2026
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Item #: 3.13. 5/26/2026 File #: 26-0282
Subcommittee Topic Project Numbers
Ecological Preservation and
Restoration
Project Nos. 1.1, 1.4, 1.9, 2.1, 3.10
Historical, Cultural, and Archeological Project Nos. 1.1, 1.4, 1.9, 2.1, 3.10 Recreational Enhancement and Safety Project Nos. 1.2, 1.3, 1.5, 1.8, 1.10, 1.11, 2.2,

2.3, 2.5, 2.6, 2.7, 2.8, 2.9, 2.11, 3.2, 3.3, 3.4,

3.5, 3.7, 3.8, 3.9
The Commission proposes that the following individuals be appointed to each subcommittee:

Subcommittee Topic Commissioners
Ecological
Preservation and
Restoration
Vice Chair Galera and Commissioner Knight
Historical, Cultural,
and Archeological
Commissioners Tillou and Baca
Recreational
Enhancement and
Safety
Chair Moeller and Commissioners Hillman and Adams
The subcommittees will act in an advisory capacity and work with staff, Townsend Public Affairs, and community groups in the implementation of the Plan projects as detailed in the above subcommittee assignments. The subcommittees will dissolve in January 2027 with a progress reported issued to the City Council at that time.

7. ATTACHMENTS
· Santiago Creek Strategic Plan Implementation Strategy City of Orange Page 2 of 2 Printed on 5/21/2026
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Agenda Item
Orange City Council
Item #: 3.13. 5/26/2026 File #: 26-0282
TO: Honorable Mayor and Members of the City Council
FROM: Jarad Hildenbrand, City Manager

1. SUBJECT
Approval of the Santiago Creek Commission’s proposed Santiago Creek Strategic Plan implementation strategy

3. RECOMMENDED ACTION
Approve the Santiago Creek Commission’s proposed Santiago Creek Strategic Plan Implementation Strategy.

4. FISCAL IMPACT
None.

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

Goal 5: Improve Infrastructure, Mobility, and Technology.

2.3, 2.5, 2.6, 2.7, 2.8, 2.9, 2.11, 3.2, 3.3, 3.4,

3.5, 3.7, 3.8, 3.9
City of Orange Page 1 of 2 Printed on 5/21/2026
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Item #: 3.13. 5/26/2026 File #: 26-0282
Subcommittee Topic Project Numbers
Ecological Preservation and
Restoration
Project Nos. 1.1, 1.4, 1.9, 2.1, 3.10
Historical, Cultural, and Archeological Project Nos. 1.1, 1.4, 1.9, 2.1, 3.10 Recreational Enhancement and Safety Project Nos. 1.2, 1.3, 1.5, 1.8, 1.10, 1.11, 2.2,

2.3, 2.5, 2.6, 2.7, 2.8, 2.9, 2.11, 3.2, 3.3, 3.4,

3.5, 3.7, 3.8, 3.9
The Commission proposes that the following individuals be appointed to each subcommittee:

7. ATTACHMENTS
· Santiago Creek Strategic Plan Implementation Strategy City of Orange Page 2 of 2 Printed on 5/21/2026
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Santiago Creek Commission
Santiago Creek Strategic Plan
Implementation Strategy
Background and Purpose:

On February 24, 2026, the Orange City Council adopted the Santiago Creek Strategic Plan (Plan) and directed the Santiago Creek Commission to bring back options to help put the Plan into action. After considering different options, the City Council directed the Commission to work with Townsend Public Affairs (TPA) and community groups to develop an implementation strategy for the City Council’s consideration. The purpose of this workplan is to detail the Commission’s recommendation to help put the Plan into action.

Proposed Implementation Strategy:

On April 22, 2026, the Commission voted to create three subcommittees that focus on select topics detailed in the Plan (see Subcommittee Topic column). The topics include the following three categories with the respective project numbers best suited for each category identified under the column “Project Numbers.” Subcommittee
Topic
Project Numbers
Ecological
Preservation and
Restoration
Project Nos. 1.1, 1.4, 1.9, 2.1, 3.10
Historical, Cultural,
and Archeological
Project Nos. 1.1, 1.4, 1.9, 2.1, 3.10
Recreational
Enhancement and
Safety
Project Nos. 1.2, 1.3, 1.5, 1.8, 1.10, 1.11, 2.2, 2.3, 2.5, 2.6,

2.7, 2.8, 2.9, 2.11, 3.2, 3.3, 3.4, 3.5, 3.7, 3.8, 3.9
177
Santiago Creek Commission
Santiago Creek Strategic Plan
Implementation Strategy
The Commission proposes that the following individuals be appointed to each subcommittee:

Subcommittee
Topic
Commissioners
Ecological
Preservation and
Restoration
Vice Chair Galera and Commissioner Knight
Historical, Cultural,
and Archeological
Commissioners Tillou and Baca
Recreational
Enhancement and
Safety
Chair Moeller and Commissioners Hillman and Adams
These subcommittees will act in an advisory capacity and work with staff, Townsend Public Affairs, and community groups in the implementation of the Plan projects. The subcommittees will dissolve in January 2027 with a progress report issued to the City Council at that time.
178
Agenda Item
Orange City Council
Item #: 3.14. 5/26/2026 File #: 26-0115
TO: Honorable Mayor and Members of the City Council
THRU: Jarad Hildenbrand, City Manager
FROM: Pamela Coleman, City Clerk/City Clerk Services Director Nathalie Adourian, City Attorney

1. SUBJECT
Consideration of resolutions pertaining to the November 3, 2026, General Municipal Election

2. SUMMARY
The proposed resolutions initiate the process for conducting the City’s General Municipal Election to be held on November 3, 2026, for the purpose of electing a Mayor and three Councilmembers from District Nos. 1, 4, and 6.

3. RECOMMENDED ACTION

1. Adopt Resolution No. 11669. A Resolution of the City Council of the City of Orange calling and giving notice of a General Municipal Election to be held on Tuesday, November 3, 2026, for the election of certain officers as required by the provisions of the laws of the State of California relating to General Law cities.

2. Adopt Resolution No. 11671. A Resolution of the City Council of the City of Orange adopting regulations for candidates for elective office pertaining to candidates’ statements submitted to the voters at an election to be held on Tuesday, November 3, 2026.

3. Adopt Resolution No. 11673. A Resolution of the City Council of the City of Orange requesting the Board of Supervisors of the County of Orange to consolidate a General Municipal Election to be held on Tuesday, November 3, 2026, with the Statewide General Election to be held on the same date pursuant to Elections Code Section 10403.

4. FISCAL IMPACT
The estimated expense to hold the November 3, 2026, General Municipal Election is $244,356 and will be included in the Fiscal Year 2026-27 General Fund (100) budget.

5. STRATEGIC PLAN GOALS
This action does not correlate to any of the adopted strategic plan goals; however, Elections Code § 12001 requires the governing body of the local agency to adopt a resolution calling the election.

6. DISCUSSION AND BACKGROUND
The General Municipal Election to elect members of the Orange City Council is held in November of even numbered years. The November 3, 2026, General Election, held in conjunction with the Statewide General Election, shall be for the election of a Mayor for the full term of two years; and City of Orange Page 1 of 2 Printed on 5/21/2026
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Item #: 3.14. 5/26/2026 File #: 26-0115
Statewide General Election, shall be for the election of a Mayor for the full term of two years; and three Councilmember seats in Districts 1, 4, and 6, all for a full term of four years.

Prior to June 15, 2026, the City Council must adopt a resolution calling and giving notice of the November 3, 2026, General Municipal Election, request consolidation with the Statewide General Election, and set regulations pertaining to candidate statements.

The candidate filing period for the November 3, 2026, election will open at 7:30 a.m. on Monday, July 13, 2026, and close at 5:00 p.m. on Friday, August 7, 2026. If an incumbent does not file by August 7, 2026, the nomination period is extended to 5:00 p.m. on Wednesday, August 12, 2026, for nonincumbents only.

Resolution No. 11671 establishes regulations for candidates for elective office pertaining to candidate statements submitted to the voters. Only candidates wishing to submit a candidate statement will be charged to cover the cost of printing the statement in the voter information guide. The statement may include the name, age, and occupation of the candidate and a brief description of no more than 200 words of the candidate’s education and qualifications.

Adoption of the attached resolutions are required to initiate the process for conducting the City’s General Municipal Election and consolidate with the Statewide General Election to be held on the same date.

It should be noted that ballot measures may still be placed on the ballot by separate resolution, provided the resolution calling for the measure to be placed on the ballot is adopted by City Council no later than July 14, 2026, and filed with the Orange County Board of Supervisors and the Orange County Registrar of Voters no later than July 17, 2026.

7. ATTACHMENTS
· Resolution No. 11669
· Resolution No. 11671
· Resolution No. 11673
City of Orange Page 2 of 2 Printed on 5/21/2026
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Agenda Item
Orange City Council
Item #: 3.14. 5/26/2026 File #: 26-0115
TO: Honorable Mayor and Members of the City Council
THRU: Jarad Hildenbrand, City Manager
FROM: Pamela Coleman, City Clerk/City Clerk Services Director Nathalie Adourian, City Attorney

1. SUBJECT
Consideration of resolutions pertaining to the November 3, 2026, General Municipal Election

3. RECOMMENDED ACTION

4. FISCAL IMPACT
The estimated expense to hold the November 3, 2026, General Municipal Election is $244,356 and will be included in the Fiscal Year 2026-27 General Fund (100) budget.

6. DISCUSSION AND BACKGROUND
The General Municipal Election to elect members of the Orange City Council is held in November of even numbered years. The November 3, 2026, General Election, held in conjunction with the Statewide General Election, shall be for the election of a Mayor for the full term of two years; and City of Orange Page 1 of 2 Printed on 5/21/2026
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Item #: 3.14. 5/26/2026 File #: 26-0115
Statewide General Election, shall be for the election of a Mayor for the full term of two years; and three Councilmember seats in Districts 1, 4, and 6, all for a full term of four years.

7. ATTACHMENTS
· Resolution No. 11669
· Resolution No. 11671
· Resolution No. 11673
City of Orange Page 2 of 2 Printed on 5/21/2026
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RESOLUTION NO. 11669

A RESOLUTION OF THE CITY COUNCIL OF THE

CITY OF ORANGE CALLING AND GIVING

NOTICE OF A GENERAL MUNICIPAL ELECTION
TO BE HELD ON TUESDAY, NOVEMBER 3, 2026,

FOR THE ELECTION OF CERTAIN OFFICERS AS

REQUIRED BY THE PROVISIONS OF THE LAWS

OF THE STATE OF CALIFORNIA RELATING TO

GENERAL LAW CITIES
WHEREAS, under the provisions of the laws relating to General Law Cities in the State of California, a General Municipal Election shall be held on November 3, 2026, for the election of Municipal Officers.

NOW, THEREFORE, the City Council of the City of Orange does hereby resolve, declare, determine and order as follows:

SECTION l. That pursuant to the requirements of the laws of the State of California relating to General Law Cities, there is called and ordered to be held in the City of Orange, on Tuesday, November 3, 2026, a General Municipal Election for the purpose of electing a Mayor for the full term of two (2) years; one (1) Member of the City Council from District 1 for the full term of four (4) years; one (1) Member of the City Council from District 4 for a full term of four (4) years; and one (1) Member of the City Council from District 6 for the full term of four (4) years.

SECTION 2. That the ballots to be used at the election shall be in form and content as required by law.

SECTION 3. That the City Clerk is authorized, instructed and directed to coordinate with the County of Orange Registrar of Voters to procure and furnish any and all official ballots, notices, printed matter and all supplies, equipment and paraphernalia that may be necessary in order to properly and lawfully conduct the election.

SECTION 4. That the vote center locations and hours of operations, ballot drop box locations and hours of operations, vote-by-mail procedures and timing, the election officers, and all other persons and procedures for the General Municipal Election shall be the same as those utilized by the County of Orange and in compliance with the Elections Code of the State of California. In addition, the vote centers for the election shall be open at seven o’clock a.m. of the day of the election and shall remain open continuously from that time until eight o’clock p.m. of the same day when the vote centers shall be closed, pursuant to Election Code § 10242, except as provided in §§ 14212, 14401 of the Elections Code of the State of California.

SECTION 5. In all particulars not recited in this resolution, the election shall be held and conducted as provided by law for holding municipal elections. 183
2 SECTION 6. Notice of the time and place of holding the election is given and the City Clerk is authorized, instructed and directed to give further or additional notice of the election, in the time, form and manner as required by law.

SECTION 7. In the event of a tie vote (if any two or more persons receive an equal and the highest number of votes for an office) as certified by the County of Orange Registrar of Voters, the City Council, in accordance with Election Code § 15651(a), shall set a date and time and place and summon the candidates who have received the tie votes to appear and will determine the tie by lot.

SECTION 8. The City Clerk shall certify to the passage and adoption of this Resolution and enter it into the book of original Resolutions.

SECTION 9. The City Council authorizes the City Clerk to administer said election and the City shall pay all reasonable and actual election expenses upon presentation of a properly submitted bill.

ADOPTED this ______ day of ___________________________ 2026.

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

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

Nathalie Adourian, City Attorney,
City of Orange
184
3 STATE OF CALIFORNIA )
COUNTY OF ORANGE ) ss.

CITY OF ORANGE )
I, PAMELA COLEMAN, City Clerk of the City of Orange, California, do hereby certify that the foregoing Resolution was duly and regularly adopted by the City Council of the City of Orange at a regular meeting thereof held on the day of , 2026 by the following vote:

AYES: COUNCILMEMBERS:

NOES: COUNCILMEMBERS:

ABSENT: COUNCILMEMBERS:

Pamela Coleman, City Clerk, City of Orange
185
RESOLUTION NO. 11671

A RESOLUTION OF THE CITY COUNCIL OF THE

CITY OF ORANGE ADOPTING REGULATIONS

FOR CANDIDATES FOR ELECTIVE OFFICE
PERTAINING TO CANDIDATES’ STATEMENTS

SUBMITTED TO THE VOTERS AT AN ELECTION
TO BE HELD ON TUESDAY, NOVEMBER 3, 2026
WHEREAS, Section 13307 of the Elections Code of the State of California provides that the governing body of any local agency adopt regulations pertaining to materials prepared by any candidate for a municipal election, including costs of the candidate statement.

NOW, THEREFORE, the City Council of the City of Orange does hereby resolve, declare, determine and order as follows:

SECTION l. GENERAL PROVISIONS. Pursuant to Section 13307 of the Elections Code of the State of California, each candidate for elective office to be voted for at an election to be held in the City of Orange on November 3, 2026, may prepare a candidate’s statement on an appropriate form provided by the City Clerk. The statement may include the name, age, and occupation of the candidate and a brief description of no more than 200 words of the candidate's education and qualifications expressed by the candidate. The statement shall not include party affiliation of the candidate, nor membership or activity in partisan political organizations. The statement shall be filed in typewritten form and electronic format (as specified by the City Clerk) in the office of the City Clerk at the time the candidate's nomination papers are filed. The statement may be withdrawn, but not changed, during the period for filing nomination papers and until 5:00 p.m. of the next working day after the close of the nomination period.

SECTION 2. FOREIGN LANGUAGE POLICY. Pursuant to the Federal Voting Rights Act, candidates’ statements will be translated into all languages required by the County of Orange.

The County will mail separate voter information guides and candidates’ statements in the required languages to only those voters who are on the County voter file as having requested a voter information guide in a particular language. The County will make the voter information guides and candidates’ statements in the required languages available at all vote centers, on the County’s website, and in the Election Official’s office.

SECTION 3. PAYMENT. The candidate shall pay the total cost of printing, handling, translating, and mailing the candidate’s statement filed pursuant to this section, including costs incurred as a result of complying with the Federal Voting Rights Act (as amended). The City Clerk shall require each candidate filing a statement to pay in advance to the local agency their pro rata share, as determined by the County of Orange Registrar of Voters, as a condition of having their statement included in the voter information guide.

SECTION 4. MISCELLANEOUS. The City Clerk shall comply with all recommendations and standards set forth by the California Secretary of State regarding occupational designations and other matters relating to elections. 186
2 SECTION 5. ADDITIONAL MATERIALS. No candidate will be permitted to include additional materials in the voter information guide.

SECTION 6. The City Clerk shall provide each candidate or the candidate's representative a copy of this Resolution at the time nominating petitions are issued.

SECTION 7. All previous Resolutions establishing Council policy on payment for candidates statements are repealed.

SECTION 8. This Resolution shall apply only to the election to be held on November 3, 2026, and shall thereafter be repealed by its own terms.

SECTION 9. The City Clerk shall certify to the passage and adoption of this Resolution and enter it into the book of original Resolutions.

ADOPTED this _____ day of __________________________ 2026.

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

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

Nathalie Adourian, City Attorney,
City of Orange
187
3 STATE OF CALIFORNIA )
COUNTY OF ORANGE ) ss.

AYES: COUNCILMEMBERS:

NOES: COUNCILMEMBERS:

ABSENT: COUNCILMEMBERS:

Pamela Coleman, City Clerk, City of Orange
188
RESOLUTION NO. 11673

A RESOLUTION OF THE CITY COUNCIL OF

THE CITY OF ORANGE REQUESTING THE

BOARD OF SUPERVISORS OF THE COUNTY OF

ORANGE TO CONSOLIDATE A GENERAL

MUNICIPAL ELECTION TO BE HELD ON
TUESDAY, NOVEMBER 3, 2026 WITH THE

STATEWIDE GENERAL ELECTION TO BE

HELD ON THE SAME DATE PURSUANT TO
ELECTIONS CODE SECTION 10403
WHEREAS, the City Council of the City of Orange called a General Municipal Election to be held on November 3, 2026, for the purpose of the election of a Mayor and three (3) Members of the City Council; and
WHEREAS, it is desirable that the General Municipal Election be consolidated with the Statewide General Election to be held on the same date and that within the City, the precincts, polling places (vote centers) and election officers of the two elections be the same, and that the Board of Supervisors of the County of Orange (“County”) canvass the returns of the General Municipal Election, and that the election be held in all respects as if there were only one election.

NOW, THEREFORE, the City Council of the City of Orange does hereby resolve, declare, determine and order as follows:

SECTION 1. Pursuant to the requirements of § 10403 of the Elections Code, the County is hereby requested to consent and agree to the consolidation of a General Municipal Election with the Statewide General Election on Tuesday, November 3, 2026, for the purpose of electing a Mayor for the full term of two (2) years; one (1) Member of the City Council from District 1 for the full term of four (4) years; one (1) Member of the City Council from District 4 for a full term of four (4) years; and one (1) Member of the City Council from District 6 for the full term of four (4) years.

SECTION 2. The County is authorized to canvass the returns of the General Municipal Election. The election shall be held in all respects as if there were only one election, and only one form of ballot shall be used. The election shall be held and conducted in accordance with the provisions of law regulating the statewide election.

SECTION 3. The Board of Supervisors is requested to issue instructions to the County Registrar of Voters to take any and all steps necessary for the holding of the consolidated election.

SECTION 4. The City of Orange recognizes that additional costs will be incurred by the County by reason of this consolidation and agrees to reimburse the County for any such costs.

SECTION 5. The City Clerk is hereby directed to file a certified copy of this Resolution with the Board of Supervisors of the County of Orange and the Registrar of Voters of the County of Orange.
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2 SECTION 6. The City Clerk shall certify to the passage and adoption of this Resolution and enter it into the book of original Resolutions.

ADOPTED this ______ day of ______________________ 2026.

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

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

Nathalie Adourian, City Attorney,
City of Orange

STATE OF CALIFORNIA )
COUNTY OF ORANGE ) ss.

AYES: COUNCILMEMBERS:

NOES: COUNCILMEMBERS:

ABSENT: COUNCILMEMBERS:

Pamela Coleman, City Clerk, City of Orange
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Agenda Item
Orange City Council
Item #: 7.1. 5/26/2026 File #: 26-0310

1. SUBJECT
Appointment to the Audit Advisory Committee

2. SUMMARY
Due to the resignation of Jeff Grampp, an unscheduled vacancy exists on the Audit Advisory Committee. In accordance with Government Code Section 54974, a Notice of Vacancy was posted on February 17, 2026.

3. RECOMMENDED ACTION
Confirm Mayor Slater’s recommendation to appoint Robert Paul to the Audit Advisory Committee for a two-year term ending on June 30, 2028.

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Agenda Item
Orange City Council
Item #: 7.1. 5/26/2026 File #: 26-0310

1. SUBJECT
Appointment to the Audit Advisory Committee

3. RECOMMENDED ACTION
Confirm Mayor Slater’s recommendation to appoint Robert Paul to the Audit Advisory Committee for a two-year term ending on June 30, 2028.

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Agenda Item
Orange City Council
Item #: 9.1. 5/26/2026 File #: 26-0316
TO: Honorable Mayor and Members of the City Council
THRU: Jarad Hildenbrand, City Manager
FROM: Russell Bunim, Community Development Director

1. SUBJECT
Public Hearing to consider an amendment to the City’s Master Fee Schedule establishing an annual fee and fines for the vacant property registration program

2. SUMMARY
The proposed ordinance establishes maintenance and security standards for unoccupied and abandoned properties. The City has elected not to include a registration requirement for unoccupied or abandoned properties as part of the proposed ordinance. The proposed program would establish inspection, monitoring, and enforcement procedures to address neglected properties, recover City enforcement costs, and reduce blight, nuisance conditions, criminal activity, and threats to the public health, safety, and welfare. The ordinance also provides for progressive administrative fines, criminal penalties, and summary abatement authority, when necessary, to achieve and maintain code compliance.

Staff requests a continuance of the item to the June 9, 2026, Regular City Council Meeting.

3. RECOMMENDED ACTION
Continue the Public Hearing to the June 9, 2026, Regular City Council Meeting.

4. ATTACHMENTS
· None
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Agenda Item
Orange City Council
Item #: 9.1. 5/26/2026 File #: 26-0316
TO: Honorable Mayor and Members of the City Council
THRU: Jarad Hildenbrand, City Manager
FROM: Russell Bunim, Community Development Director

1. SUBJECT
Public Hearing to consider an amendment to the City’s Master Fee Schedule establishing an annual fee and fines for the vacant property registration program

Staff requests a continuance of the item to the June 9, 2026, Regular City Council Meeting.

3. RECOMMENDED ACTION
Continue the Public Hearing to the June 9, 2026, Regular City Council Meeting.

4. ATTACHMENTS
· None
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Agenda Item
Orange City Council
Item #: 9.2. 5/26/2026 File #: 26-0252
TO: Honorable Mayor and Members of the City Council
THRU: Jarad Hildenbrand, City Manager
FROM: Russell Bunim, Community Development Director

1. SUBJECT
Public Hearing to consider a proposal to redevelop a commercial property with 71 three-story singlefamily small lot homes at 2375 N. Tustin Street, the Introduction and First Reading of Ordinance No. 06-26 approving Zone Change No. ZC25-0002, and adoption of Mitigated Negative Declaration No.

ENV25-0001 and associated Mitigation Monitoring and Reporting Program

2. SUMMARY
Melia Homes proposes to redevelop an existing 4.23-acre vacant commercial site (former Best Buy) with 71 three-story single-family small lot homes, open space recreation area, guest parking, and related site improvements. To allow for residential development at this location, the proposal includes a request to amend the General Plan land use designation from General Commercial (Max. 1.0 FAR) (GC) to Medium Density Residential,15-24 dwelling units per acre (MDR) and a request to amend the zoning from Limited Business Tustin Redevelopment Project Area (C-TR) to Residential Multiple Family (R-3). A Tentative Tract Map is proposed for the small lot subdivision including establishment of private and common use areas.

3. RECOMMENDED ACTION

1. Conduct and close the Public Hearing.

2. Adopt Resolution No. 11685. A Resolution of the City Council of the City of Orange adopting Mitigated Negative Declaration No. ENV25-0001 and associated Mitigation Monitoring and Reporting Program, and approving General Plan Amendment No. GPA25-0003, Tentative Tract Map No. TTM25-0001, Major Site Plan No. MJSP25-0002, and Administrative Design Review No.

ADR25-0018 for the redevelopment of a vacant commercial site with 71, three-story single-family small lot homes, open space recreation area, guest parking, and related site improvements on a

4.23-acre site located at 2375 N. Tustin Street.

3. Introduce and conduct First Reading of Ordinance No. 06-26. An Ordinance of the City Council of the City of Orange approving Zone Change No. ZC25-0002 to change the zoning classification from Limited Business Tustin Redevelopment Project Area (C-TR) to Residential Multiple Family (R-3) on a 4.23-acre site located at 2375 N. Tustin Street.

4. FISCAL IMPACT
None.

5. STRATEGIC PLAN GOALS
Goal 3: Enhance Economic Development and Achieve Fiscal Sustainability.

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Item #: 9.2. 5/26/2026 File #: 26-0252

6. DISCUSSION AND BACKGROUND
Existing Site
The 4.23-acre site is located on the east side of Tustin Street between Heim and Meats Avenues.

The site is currently developed with a vacant former Best Buy building, surface parking lot, and mature landscaping. There is one signalized driveway access point off Tustin Street.

The site is surrounded by single-story condominiums to the north, single-story condominiums and mobile homes to the south, a vacant site with a billboard sign to the east, and single-story commercial buildings and Tustin Street to the west. More detailed information about surrounding zoning is provided in Attachment 10.

Proposed Project
The applicant proposes to develop the site with 71 three-story single-family small lot homes, open space recreation area, guest parking, and related site improvements. The project includes small lots ranging from 1,515 to 3,376 square feet. There are 36 residences located within the interior cluster that have primary entries off landscaped paseos and walkways, and 35 residences along the northern, southern, and southwestern boundaries that have primary entries off the looped roadway and interior walkways. Each unit is provided with an attached two car garage. The four-bedroom units are provided with one additional unenclosed parking space on the same lot. In addition, there are 23 open guest spaces, for a total of 179 parking spaces provided for the project.

The architectural design of the residential units is contemporary and intended to respond to the eclectic visual character of the area. There are five plan types, all with coordinating architectural styles. All units are three stories. Units within the interior cluster incorporate roof decks. No roof decks are proposed on units along the perimeter boundaries, adjacent to existing single-story condominiums and mobile homes to the north and south. Windows on the second and third story rear elevations along the north, south, and southwest property lines will incorporate clerestory and/or frosted glass to maintain privacy for the adjacent one-story neighbors.

The project provides common open space area with shaded picnic tables, and multipurpose lawn area across from the main entrance to the development. The project also provides private open space in the form of roof decks for units within the interior cluster or 10-foot rear yards for units along the northern, southern, and southwestern boundaries.

Site access is provided by an existing signalized shared two-way entrance driveway on Tustin Street.

There is an emergency vehicle gate that leads to an emergency access easement dedicated to the City of Orange located at the northeast corner of the site and on the adjacent property to the north.

Existing mature landscaping will be protected in place along both sides of the shared entrance driveway. Landscaping is also provided along the private interior roadway and in landscape pockets between units. The landscape palette is a mix of water efficient groundcover, shrubs, and trees that will complement the contemporary architectural style.

Detailed information regarding site design, unit plan types, site access, parking, architecture, and landscaping is provided in the Planning Commission Staff Report (Attachment 10).

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Item #: 9.2. 5/26/2026 File #: 26-0252
General Plan Amendment and Zone Change
The existing 45,676-square-foot building on the site has been vacant for two years with no viable lease or commercial development options despite continuous efforts by the property owner. In order to support redevelopment of the property with the proposed residential project as opposed to the continuance of commercial uses at the site, the applicant has submitted a Fiscal Impact Analysis by Stanley R. Hoffman Associates, Inc. (Attachment 5), which demonstrates a positive economic impact to the City including an annual recurring net contribution to the City’s general fund and one-time development impact fees. The study also indicates that “the project will have a stabilizing effect on the neighborhood through community ties and economic development benefits from new household spending on goods and services captured within the City”.

To allow residential development at this location, the applicant is requesting approval of a General Plan Amendment (GPA) to change the General Plan Land Use Element designation from General Commercial (Max. 1.0 FAR) (GC) to Medium Density Residential (15-24 dwelling units per acre) (MDR), and a Zone Change (ZC) from Limited Business Tustin Redevelopment Project Area (C-TR) to Residential Multiple Family (R-3) to accommodate a small lot subdivision in accordance with the City’s Small Lot Subdivision Ordinance (OMC Section 17.14.270). The project has a density of 16.76 dwelling units per acre which is within the range allowed under the MDR General Plan land use designation and the R-3 zoning.

The MDR General Plan designation and R-3 zoning are consistent with the General Plan and zoning designations to the north and zoning to the south. The land uses allowed under the MDR land use designation and R-3 zoning are compatible with the abutting residential land uses that would remain to the north and south, and commercial land uses that would remain to the west, which accommodates a mix of retail and service commercial uses and professional offices. The land use changes enable the implementation of the Small Lot Subdivision Development Standards, which allows for alternative in-fill housing typologies within multiple-family residential zones. These development standards allow for the development of smaller residential lots on infill development sites which ultimately provides alternative options for single-family home ownership in the City.

The proposed small lot development is also consistent with the intent of the MDR land use designation and R-3 zoning, in that the project provides private and common open space with amenities, a pedestrian-friendly integration along Tustin Street and project interior, is adjacent to public transportation, and is in close proximity to commercial, retail, medical and professional offices, and recreational uses.

The proposal repositions the project site from commercial to residential General Plan and zoning designations, and represents a continuation of the existing multifamily land use designations and development to the north and south between Heim and Meats Avenues. These long-established multifamily developments have MDR and Low Medium Density Residential (LMDR) General Plan designations and are zoned R-3(A). While the Tustin Street corridor is predominately commercial, and the segment between Heim and Meats consists of a mix of commercial uses along the street frontage and residential development behind the commercial development, the presence of residential uses along this portion of Tustin Street is logical given the neighborhood-serving goods and services in the area, interface with residential neighborhoods, and proximity to public transporation.

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Item #: 9.2. 5/26/2026 File #: 26-0252
The proposed land use change for the project and implementation of the Small Lot Subdivision Development Standards will provide additional housing options that contribute to the Medium Density Residential development between Heim and Meats Avenues and supports the City’s Regional Housing Needs Allocation (RHNA) by adding units to the overall housing inventory on a site that had not previously been identified as a Candidate Housing Site in the Housing Element.

Tentative Tract Map
The applicant is requesting approval of a Tentative Tract Map to establish small lots, with common and private space areas on the site. Common areas include private interior roadways and unenclosed parking, open space recreation area, and common landscape areas. Private space areas are provided in rear yards, and on roof decks. The Tentative Tract Map has been reviewed and found in compliance with the Subdivision Map Act and Orange Municipal Code (OMC) Title 16, Subdivisions.

Environmental Review
Initial Study/Mitigated Negative Declaration (MND) No. ENV25-0001 (State Clearinghouse No. 2026020142) was prepared to evaluate the physical environmental impacts of the project, in conformance with the provisions of the California Environmental Quality Act (CEQA) per State CEQA Guidelines Section 15070 and in conformance with local CEQA guidelines. The analysis contained in the MND determined that the project will have less than significant impacts to the environment with the implementation of Project Design Features, Plans, Programs, and Policies, relating to Aesthetics, Air Quality, Cultural Resources, Energy, Geology and Soils, Greenhouse Gas Emissions, Hydrology and Water Quality, Noise, and Tribal Cultural Resources, and Mitigation Measures relating to Biological Resources, Noise, and Tribal Cultural Resources. In addition, a Mitigation Monitoring and Reporting Program has been prepared and is included in the final MND that summarizes the Project Design Features, Plans, Programs, and Policies, Mitigation Measures, and the responsible party for the implementation and monitoring (Attachments 7 and 8).

The MND was circulated for public review for a 20-day period beginning on February 5, 2026 and ending on February 25, 2026. A Notice of Intent (NOI) to Adopt the MND was filed with the Orange County Clerk Recorder, posted at the site, mailed to property owners and tenants within a 300-foot radius of the project site, potentially affected cities, public agencies, utility service providers, and published in the Anaheim Bulletin newspaper on February 5, 2026. The MND was made publicly available at the Community Development Department, City Clerk’s office, and the City’s website.

Public comments on the MND were received from the California Department of Transportation (Caltrans), Pala Band of Mission Indians, and six community members. Caltrans discusses the pattern of land uses that affect both local vehicle miles traveled and number of trips, supports local developments that promote equity, strengthen the economy, protect the environment, and provide a diversity of housing choices accessible to transportation facilities, promotes Complete Streets with high-quality pedestrian, bicycle, and transit facilities, project adjacency to bike lanes, supports inclusion of secure short term bike parking and provides guidance on bicycle parking best practices, discretionary approval required for work within Caltrans right-of-way, and requests coordination with Caltrans for this and future projects. The Pala Band of Mission Indians commented that the project is not within the boundaries of the recognized Pala Indian Reservation and is beyond the boundaries of the Traditional Use Area and requests to receive project notifications. Community members provided general comments related to traffic, parking, privacy, rezoning and reduction of sales tax revenue, City of Orange Page 4 of 7 Printed on 5/21/2026 powered by Legistar™198
Item #: 9.2. 5/26/2026 File #: 26-0252
general comments related to traffic, parking, privacy, rezoning and reduction of sales tax revenue, waste management, construction noise, site demolition impacts, emergency access, property values, need for more restaurant and retail uses, project should include a commercial component, and noted corrections and/or modifications to the IS/MND document. Responses to comments were prepared and forwarded to the respective authors in accordance with the requirements of CEQA, and in advance of the City’s consideration of any determination. Copies of the comment letters and responses to comments to address feedback relevant to environmental impacts received during the public review period were incorporated into the final MND (Attachment 7).

Planning Commission Review
On April 6, 2026, the Planning Commission conducted a public hearing for the project. Five public comments were posted on the City’s website, and four community members spoke at the meeting.

Written public comments from the April 6, 2026 meeting are included as Attachment 12.

Public Comments
One community member spoke in support of the project and stated the benefits of this type of development for the community in terms of affordability, walkability, adjacency to commercial uses, and traffic reduction as opposed to commercial development. Other general community concerns included the project’s lack of conformance with the Small Lot Subdivision Guidelines in that the mass and scale of buildings should respond to the adjacent one-story neighborhoods to the north and south, project should consider building setbacks, line of sight, privacy, and implementation of twostory building heights along north and south property lines, three-story building height will reduce the value of adjacent one-story residential properties, dens on first floor could be converted to bedrooms, inadequate fire access and utilization of easement on adjacent property to the north, missed opportunity to include commercial bank property to the west as part of the project, problematic traffic signal synchronization along Tustin Street, construction traffic impacts, unproductive community meeting with developer, challenge of integrating housing in commercial zones, loss of sales tax revenue, and the need for more time to consider the project.

Planning Commission Discussion
Planning Commission discussion included comments regarding the preservation of privacy for the adjacent neighbors, project incompatibility with the neighborhood context in terms of height, density, and scale, request for modified windows to increase screening of sight line views onto neighboring properties to the north and south, parking on adjacent bank property, fire access on adjacent property, garage storage, conversion of ground floor dens to ADUs, roof top restrictions, improvement of landscaping with more space, laddering effects on landscaping, light synchronization on Tustin Street, designated guest parking, allowable uses under the GC General Plan designation, setback and height requirements of the C-TR zone, excellent architectural product and the enhancement of this portion of Tustin Street with the project.

The Planning Commission ultimately recommended approval of the project to the City Council by a 4- 2 vote, subject to the following added conditions to Resolution No. PC 10-26:

98. Applicant shall work with Staff to modify second and third story north and south facing windows for units along the north and south property lines, similar to other projects with sight line issues, and to provide additional renderings and sight line views from the modified City of Orange Page 5 of 7 Printed on 5/21/2026
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Item #: 9.2. 5/26/2026 File #: 26-0252
line issues, and to provide additional renderings and sight line views from the modified windows onto adjacent properties to the north and south, particularly where there is a sight line view into a window or yard space.

99. Applicant shall provide sight line views from the nearest roof decks onto adjacent communities to the north and south.

Project Changes Subsequent to the Planning Commission Meeting:

The applicant has considered the Planning Commission’s feedback and implemented the recommended conditions by incorporating the following changes to the project plans:

1. Frosted glass added to rear elevation third-story bedroom windows along the north and south property lines for lots 11-20, and 54-59 (Type B duplex units, Plans 2 and 5A), including notes added to Sheets SP, A13, A22.1, A22.4, and A22.5.

2. Reduced window sizes and raised sill heights to eye level (5 feet above floor level), creating clerestory windows on second story rear elevations for all perimeter units along the north, south, and southwest property lines for lots 1-4, 7-20, 54-67 (Type B duplex, Plans 2 and 5A); lots 5 and 68 (detached Plan 5B); and lot 6 (detached Plan 3A), including revisions to Sheets A3, A4, A8, A9, A13, A15, and A17.

3. Corrected clerestory stairwell windows on floor plans and elevations for Type B duplex, and Plans 5B and 3A, including revisions to Sheets A9, A15, and A17.

4. Revised and added Line of Sight Section Details on Sheets A22.1 - A22.5 to clearly illustrate the views at 5-foot eye levels from rear elevation second and third story adjusted windows and roof top decks onto adjacent properties to the north and south.

In addition, Staff has added conditions 47 - 55 to City Council Resolution No. 11685 regarding private open space requirements in rear yards, requirement of rear elevation second story clerestory windows for all perimeter units, requirement of frosted glass on third story bedroom windows for selected units, limitation on four-bedroom units, marking of unenclosed parking spaces, and attached patio cover limitations for units along the perimeter boundaries.

7. ATTACHMENTS
· Attachment 1 Resolution No. 11685
· Attachment 2 Ordinance No. 06-26
· Attachment 3 Vicinity Map
· Attachment 4 Existing Site Photographs
· Attachment 5 Fiscal Impact Analysis, dated December 12, 2025 City of Orange Page 6 of 7 Printed on 5/21/2026
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· Attachment 6 Project Plans, dated April 10, 2026
· Attachment 7 Final Mitigated Negative Declaration No. ENV25-0001 and Mitigation Monitoring and Reporting Program, dated March 2026
· Attachment 8 Mitigated Negative Declaration No. ENV25-0001 Appendices · Attachment 9 Planning Commission Resolution Nos. PC 08-26, PC 09-26, and PC 10- 26, dated April 6, 2026
· Attachment 10 Planning Commission Staff Report, dated April 6, 2026 · Attachment 11 Draft Planning Commission Minutes, dated April 6, 2026 · Attachment 12 Written Public Comments from the April 6, 2026 Planning Commission meeting
· Attachment 13 Applicant’s Summary of Plan Changes
· Attachment 14 Small Lot Subdivision Guidelines
· Attachment 15 Written Communications received after April 6, 2026 Planning Commission meeting
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Agenda Item
Orange City Council
Item #: 9.2. 5/26/2026 File #: 26-0252
TO: Honorable Mayor and Members of the City Council
THRU: Jarad Hildenbrand, City Manager
FROM: Russell Bunim, Community Development Director

ENV25-0001 and associated Mitigation Monitoring and Reporting Program

3. RECOMMENDED ACTION

1. Conduct and close the Public Hearing.

ADR25-0018 for the redevelopment of a vacant commercial site with 71, three-story single-family small lot homes, open space recreation area, guest parking, and related site improvements on a

4.23-acre site located at 2375 N. Tustin Street.

4. FISCAL IMPACT
None.

5. STRATEGIC PLAN GOALS
Goal 3: Enhance Economic Development and Achieve Fiscal Sustainability.

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Item #: 9.2. 5/26/2026 File #: 26-0252

6. DISCUSSION AND BACKGROUND
Existing Site
The 4.23-acre site is located on the east side of Tustin Street between Heim and Meats Avenues.

The site is currently developed with a vacant former Best Buy building, surface parking lot, and mature landscaping. There is one signalized driveway access point off Tustin Street.

Site access is provided by an existing signalized shared two-way entrance driveway on Tustin Street.

There is an emergency vehicle gate that leads to an emergency access easement dedicated to the City of Orange located at the northeast corner of the site and on the adjacent property to the north.

Detailed information regarding site design, unit plan types, site access, parking, architecture, and landscaping is provided in the Planning Commission Staff Report (Attachment 10).

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General Plan Amendment and Zone Change
The existing 45,676-square-foot building on the site has been vacant for two years with no viable lease or commercial development options despite continuous efforts by the property owner. In order to support redevelopment of the property with the proposed residential project as opposed to the continuance of commercial uses at the site, the applicant has submitted a Fiscal Impact Analysis by Stanley R. Hoffman Associates, Inc. (Attachment 5), which demonstrates a positive economic impact to the City including an annual recurring net contribution to the City’s general fund and one-time development impact fees. The study also indicates that “the project will have a stabilizing effect on the neighborhood through community ties and economic development benefits from new household spending on goods and services captured within the City”.

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The proposed land use change for the project and implementation of the Small Lot Subdivision Development Standards will provide additional housing options that contribute to the Medium Density Residential development between Heim and Meats Avenues and supports the City’s Regional Housing Needs Allocation (RHNA) by adding units to the overall housing inventory on a site that had not previously been identified as a Candidate Housing Site in the Housing Element.

Public comments on the MND were received from the California Department of Transportation (Caltrans), Pala Band of Mission Indians, and six community members. Caltrans discusses the pattern of land uses that affect both local vehicle miles traveled and number of trips, supports local developments that promote equity, strengthen the economy, protect the environment, and provide a diversity of housing choices accessible to transportation facilities, promotes Complete Streets with high-quality pedestrian, bicycle, and transit facilities, project adjacency to bike lanes, supports inclusion of secure short term bike parking and provides guidance on bicycle parking best practices, discretionary approval required for work within Caltrans right-of-way, and requests coordination with Caltrans for this and future projects. The Pala Band of Mission Indians commented that the project is not within the boundaries of the recognized Pala Indian Reservation and is beyond the boundaries of the Traditional Use Area and requests to receive project notifications. Community members provided general comments related to traffic, parking, privacy, rezoning and reduction of sales tax revenue, City of Orange Page 4 of 7 Printed on 5/21/2026 powered by Legistar™205
Item #: 9.2. 5/26/2026 File #: 26-0252
general comments related to traffic, parking, privacy, rezoning and reduction of sales tax revenue, waste management, construction noise, site demolition impacts, emergency access, property values, need for more restaurant and retail uses, project should include a commercial component, and noted corrections and/or modifications to the IS/MND document. Responses to comments were prepared and forwarded to the respective authors in accordance with the requirements of CEQA, and in advance of the City’s consideration of any determination. Copies of the comment letters and responses to comments to address feedback relevant to environmental impacts received during the public review period were incorporated into the final MND (Attachment 7).

Written public comments from the April 6, 2026 meeting are included as Attachment 12.

The Planning Commission ultimately recommended approval of the project to the City Council by a 4- 2 vote, subject to the following added conditions to Resolution No. PC 10-26:

98. Applicant shall work with Staff to modify second and third story north and south facing windows for units along the north and south property lines, similar to other projects with sight line issues, and to provide additional renderings and sight line views from the modified City of Orange Page 5 of 7 Printed on 5/21/2026
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Item #: 9.2. 5/26/2026 File #: 26-0252
line issues, and to provide additional renderings and sight line views from the modified windows onto adjacent properties to the north and south, particularly where there is a sight line view into a window or yard space.

99. Applicant shall provide sight line views from the nearest roof decks onto adjacent communities to the north and south.

Project Changes Subsequent to the Planning Commission Meeting:

The applicant has considered the Planning Commission’s feedback and implemented the recommended conditions by incorporating the following changes to the project plans:

3. Corrected clerestory stairwell windows on floor plans and elevations for Type B duplex, and Plans 5B and 3A, including revisions to Sheets A9, A15, and A17.

7. ATTACHMENTS
· Attachment 1 Resolution No. 11685
· Attachment 2 Ordinance No. 06-26
· Attachment 3 Vicinity Map
· Attachment 4 Existing Site Photographs
· Attachment 5 Fiscal Impact Analysis, dated December 12, 2025 City of Orange Page 6 of 7 Printed on 5/21/2026
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· Attachment 6 Project Plans, dated April 10, 2026
· Attachment 7 Final Mitigated Negative Declaration No. ENV25-0001 and Mitigation Monitoring and Reporting Program, dated March 2026
· Attachment 8 Mitigated Negative Declaration No. ENV25-0001 Appendices · Attachment 9 Planning Commission Resolution Nos. PC 08-26, PC 09-26, and PC 10- 26, dated April 6, 2026
· Attachment 10 Planning Commission Staff Report, dated April 6, 2026 · Attachment 11 Draft Planning Commission Minutes, dated April 6, 2026 · Attachment 12 Written Public Comments from the April 6, 2026 Planning Commission meeting
· Attachment 13 Applicant’s Summary of Plan Changes
· Attachment 14 Small Lot Subdivision Guidelines
· Attachment 15 Written Communications received after April 6, 2026 Planning Commission meeting
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RESOLUTION NO. 11685

A RESOLUTION OF THE CITY COUNCIL OF THE CITY

OF ORANGE ADOPTING MITIGATED NEGATIVE
DECLARATION NO. ENV25-0001 AND ASSOCIATED

MITIGATION MONITORING AND REPORTING

PROGRAM, AND APPROVING GENERAL PLAN
AMENDMENT NO. GPA25-0003, TENTATIVE TRACT MAP
NO. TTM25-0001, MAJOR SITE PLAN REVIEW NO.

MJSP25-0002, AND ADMINISTRATIVE DESIGN REVIEW
NO. ADR25-0018, FOR THE REDEVELOPMENT OF A
VACANT COMMERCIAL PROPERTY WITH 71, THREESTORY SINGLE-FAMLY SMALL LOT HOMES, OPEN

SPACE RECREATION AREA, GUEST PARKING, AND
RELATED SITE IMPROVEMENTS ON A 4.23-ACRE SITE
LOCATED AT 2375 N. TUSTIN STREET
APPLICANT: CHAD BROWN, MELIA HOMES
WHEREAS, the City Council has authority per Orange Municipal Code (OMC) Section

17.08.020 to review and take action on Mitigated Negative Declaration No. ENV25-0001, and approve General Plan Amendment No. GPA25-0003, Tentative Tract Map No. TTM25-0001, Major Site Plan Review No. MNSP25-0002 and Administrative Design Review No. ADR25-0018 for the redevelopment of an existing 4.23-acre vacant commercial site with 71, three-story singlefamily small lot homes, open space recreation area, guest parking, and related site improvements, located at 2375 N. Tustin Street; and
WHEREAS, the applications for Mitigated Negative Declaration No. ENV25-0001, General Plan Amendment No. GPA25-0003, Tentative Tract Map No. TTM25-0001, Major Site Plan Review No. MJSP25-0002, and Administrative Design Review No. ADR25-0018 were filed in accordance with the provisions of the OMC; and
WHEREAS, Zone Change No. ZC25-0002 to change the zoning from Limited Business Tustin Redevelopment Project Area (C-TR) to Residential Multiple Family (R-3) was filed concurrently; and
WHEREAS, Mitigated Negative Declaration No. ENV25-0001, General Plan Amendment No. GPA25-0003, Tentative Tract Map No. TTM25-0001, Major Site Plan Review No. MJSP25-0002, and Administrative Design Review No. ADR25-0018 were processed in the time and manner prescribed by state and local law; and
WHEREAS, on January 29, 2026, the City’s interdepartmental Staff Review Committee completed its review of the project and recommended the applications proceed to the Planning Commission subject to conditions; and
Attachment 1
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2 WHEREAS, on April 6, 2026, the Planning Commission reviewed the project at a duly advertised public hearing, considered public comments, and recommended approval with conditions to the City Council; and
WHEREAS, Mitigated Negative Declaration No. ENV25-0001 was prepared in accordance with the requirements of the California Environmental Quality Act and concluded that the project will have less than significant impacts to the environment with the implementation of Project Design Features, Plans, Programs, Policies, and Mitigation Measures; and WHEREAS, a Notice of Intent to Adopt Mitigated Negative Declaration No. ENV25- 0001 was published and circulated for public review and comments for 20 days as required by CEQA, with the comment period beginning February 5, 2026, and ending February 25, 2026; and WHEREAS, the City Council has reviewed and considered the information presented in Mitigated Negative Declaration No. ENV25-0001, including any written comments received during the public review period; and
WHEREAS, on May 26, 2026, the City Council conducted a duly advertised public hearing, at which time interested persons had an opportunity to testify either in support of or in opposition to Mitigated Negative Declaration No. ENV25-0001, General Plan Amendment No.

GPA25-0003, Tentative Tract Map No. TTM25-0001, Major Site Plan Review No. MJSP25-0002, and Administrative Design Review No. ADR25-0018 upon property described in Attachment “A” to this Resolution.

NOW, THEREFORE, BE IT RESOLVED that the City Council amend the City’s General Plan Map to reflect the new MDR land use designation for the site as depicted on the map provided in Attachment “C”, and adopt Mitigated Negative Declaration No. ENV25-0001, and associated Mitigation Monitoring and Reporting Program and approve General Plan Amendment No. GPA25-0003, Tentative Tract Map No. TTM25-0001, Major Site Plan Review No. MJSP25- 0002, and Administrative Design Review No. ADR25-0018 for the redevelopment of an existing

4.23-acre vacant Best Buy commercial site with 71, three-story single-family small lot homes, open space recreation area, guest parking, and related site improvements, located at 2375 N. Tustin Street, based on the following findings:

SECTION 1 – ENVIRONMENTAL REVIEW
Mitigated Negative Declaration No. ENV25-0001 was prepared to evaluate the physical environmental impacts of the project, in conformance with the provisions of the California Environmental Quality Act (CEQA) per State CEQA Guidelines Section 15070 and in conformance with local CEQA guidelines. The City Council finds that the Mitigated Negative Declaration and associated Mitigation Monitoring and Reporting Program contain an adequate assessment of the potential environmental impacts of the proposed project. The City Council finds that the project will have less than significant impacts to the environment with the implementation Project Design Features, Plans, Programs, and Policies, relating to Aesthetics, Air Quality, Cultural Resources, Energy, Geology and Soils, Greenhouse Gas Emissions, Hydrology and Water 210
3 Quality, Noise, and Tribal Cultural Resources, and Mitigation Measures relating to Biological Resources, Noise, and Tribal Cultural Resources included in the Mitigated Negative Declaration.

On February 5, 2026, a Notice of Intent to Adopt Mitigated Negative Declaration No.

ENV25-0001 was filed with the Orange County Clerk Recorder, posted at the site in two locations, mailed to property owners and tenants within a 300-foot radius of the project site, potentially affected cities, public agencies, utility service providers, and published in the Anaheim Bulletin Newspaper on February 5, 2026. The public review period began on February 5, 2026, and ended on February 25, 2026. The Mitigated Negative Declaration was made publicly available at the Community Development Department, City Clerk’s office, and the City’s website.

Public comments on Mitigated Negative Declaration No. ENV25-0001 were received from the California Department of Transportation (Caltrans), Pala Band of Mission Indians, and six community members. Responses to comments addressing feedback relevant to environmental impacts received during the public review period were incorporated into the final Mitigated Negative Declaration. Comments did not change the conclusions of Mitigated Negative Declaration No. ENV25-0001.

SECTION 2 – GENERAL PLAN FINDINGS

1. The project must be consistent with the goals and policies stated within the City’s General Plan.

With adoption of General Plan Amendment No. GPA25-0003, in conjunction with the subject development proposal establishing the Medium Density Residential land use designation for the site, the project is consistent with the goals and policies stated within the City’s General Plan in that the project will enhance and promote quality of life in the community by supporting and enhancing diverse living environments. The project transforms and revitalizes a vacant commercial site with a small lot residential development that provides a space-efficient and economical alternative to traditional options for home ownership in the City. The project provides architecture and landscape design that emphasizes pedestrian orientation and safe and convenient access between uses.

The project brings a residential population into an area where goods and services are offered by local businesses, national retailers, and restaurants. The project supports the goals of the City’s Housing Element by bringing forward housing that increases the inventory of housing and diversifies the housing types available in the community. The creation of infill housing is consistent with Housing Element Policy Action 7 and supports the City’s Regional Housing Needs Allocation pursuit on a site not previously identified as a Candidate Housing Site.

The project also provides housing in proximity to bus service located on both sides of Tustin Street in the vicinity of the project, contributing to the public transportation network.

Finally, providing housing in proximity to employment, services, and transit also supports the Natural Resources Element by establishing more efficient relationships between land uses that encourage public transportation and reduced dependence on traditional auto travel and associated vehicle trips in pursuit of reduced air pollution emissions. 211
4 The requested General Plan Amendment to change the current land use designation for the project site from General Commercial, Max. 1.0 FAR (GC) to Medium Density Residential, 15-24 dwelling units per acre (MDR) is consistent with the land use designation to the north, as presented in Attachment “A” to this Resolution.

The land uses allowed under the MDR land use designation are compatible with the abutting Medium Density Residential (MDR) land use that would remain to the north, and General Commercial, Max 1.0 FAR (GC) land uses to the west, which accommodates a mix of retail and service commercial uses, and professional offices.

The proposed MDR land use designation enables the implementation of the Small Lot Subdivision Development Standards, which allows for the construction of small lot homes that provide a space-efficient and economical alternative to traditional single dwelling unit and multiple dwelling unit development. The project is consistent with the intent of the MDR land use designation, in that the project provides private and common open space with amenities, a pedestrian-friendly integration along the Tustin Street frontage, is adjacent to public transportation, and is in close proximity to commercial, retail, medical and professional office uses. If the proposed project and associated discretionary actions are approved, the project would be consistent with the site’s new General Plan land use designation and would comply with the General Plan policies for MDR designated areas.

Although the project does not involve a Candidate Housing Site identified in the General Plan Housing Element, the transition of the commercial site to 71 dwelling units contributes to the market-rate housing stock of the community and Regional Housing Needs Allocation.

SECTION 3 – TENTATIVE TRACT MAP FINDINGS

1. The proposed division of land complies with all requirements of the Subdivision Map Act and Title 16, Subdivisions, of the Orange Municipal Code, and all other resolutions and ordinances of this City, including, but not limited to, requirements concerning area, improvements and design, floodwater drainage control, appropriate improved public roads, sanitary disposal facilities, water supply availability, public safety facilities and environmental protection.

The subject tentative tract map for the small lot subdivision complies with the requirements of the Subdivision Map Act, OMC Title 16, Subdivisions, and all other resolutions and ordinances of this City, including the Small Lot Subdivision Ordinance (OMC Section 17.14.270). Further, the tract map for the small lot subdivision establishes private and common use areas for the proposed residential development on a vacant paved site that was used as a Best Buy commercial property. Site planning requirements related to area, improvements and design, floodwater drainage control, appropriate improved public roads, sanitary disposal facilities, water supply availability, public safety facilities, and environmental protection have been addressed either via project design components shown on the proposed plans or through conditions of approval. The project, therefore, meets this finding.
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5 SECTION 4 – MAJOR SITE PLAN REVIEW FINDINGS

1. The project design is compatible with surrounding development and neighborhoods (OMC

17.10.060.H.1).

The project site is in an area of the city that contains a mix of multi-family residential uses and commercial development. The proposed project introduces a contemporary residential design that is intended to respond to the eclectic contemporary visual character of the area.

The proposed density and small lot single-family product type is compatible with the multifamily condominium developments to the north and south. The project’s flag lot configuration and location of three-story residential units behind existing commercial development directs the project’s massing away from the Tustin street frontage, therefore maintaining the existing visual appearance of the Tustin Street corridor. Three story units without roof decks are placed on the north and south perimeter boundaries and rear windows on the second and third story elevations will incorporate clerestory and/or frosted glass taking into consideration the privacy of adjacent one-story condominium and mobile home developments to the north and south. There is also existing landscaping/tree on the mobile home property that serves as a visual screen from the second and third story windows of the new units, therefore maintaining the privacy of the mobile homeowner. In addition, the applicant has demonstrated that potential shading/shadowing will not impact the adjacent properties. The landscape design, project lighting, and signage enhance the architectural aesthetics and contribute to the integration of the project with the surrounding development. The project, therefore, meets this finding.

2. The project conforms to City development standards and any applicable special design guidelines or specific plan requirements (OMC 17.10.060.H.2).

The proposed development conforms with the OMC and the City’s Small Lot Subdivision Development Standards and Guidelines. With the proposed Zone Change and General Plan Amendment, the site is removed from the Limited Business Tustin Redevelopment Project Area (C-TR) zoning and therefore is not subject to the Tustin Street Design Standards. The project complies with the Small Lot Subdivision Guidelines in that three-story residential units will be set back significantly from the Tustin Street right-of-way and partially buffered by existing one-story commercial buildings along the street frontage. Residential developments to the north and south are similarly located and buffered by commercial development. This substantial setback directs the project’s three-story massing away from the Tustin Street right-of-way and does not visually affect the existing appearance of the Tustin Street corridor. Three story units without roof decks are placed on the north and south perimeter boundaries and rear windows on the second and third story elevations will incorporate clerestory and/or frosted glass taking into consideration the privacy of adjacent one-story condominium and mobile home developments to the north and south. The architectural design incorporates varied roof forms, arched openings, unique window arrangements, trim and siding, and façade plane changes that help break up the massing and provide visual interest to the building elevations. The building orientations along the project boundary consider the site’s characteristics and the City’s, Small Lot Subdivision Guidelines in that the main entrances are oriented towards the private roadway and 213
6 walkways to create a relationship between the buildings and pedestrians and to establish a strong tie to the internal street frontages. The main entrances of the units within the center cluster are oriented towards the landscaped paseos or walkways. These paseos/walkways connect to the private roadway, open space recreation area, and public right-of-way. The project, therefore, meets this finding.

3. The project provides for safe and adequate vehicular and pedestrian circulation, both onand off-site (OMC 17.10.060.H.3).

This project was reviewed by the City’s interdepartmental Staff Review Committee for vehicle and pedestrian circulation. Both on and off-site circulation were found to be safe and adequate. Vehicle access is provided by an existing signalized shared two-way driveway entrance along Tustin Street. This entry drive connects to a looped private interior roadway and two additional interior roadways off the center cluster that provide vehicle and pedestrian access to the main entrances and garages of the dwelling units.

There is an emergency vehicle access gate that leads to an emergency access easement dedicated to the City of Orange located at the northeast corner of the site and on the adjacent property to the north. Pedestrian access from Tustin Street is provided via an existing paved sidewalk/walkway along the south side of the entrance driveway that connects to a network of interior walkways that lead to unit entries and common open space amenities. The project is also within walking distance to nearby shopping, restaurants, office, and residential uses, as well as adjacent to multiple bus stops located on the east and west sides of Tustin Street in the general vicinity of the project site.

The design of the vehicle and pedestrian network for the site supports the goals and policies of the Circulation & Mobility Element of the General Plan which focus on achieving safe and comprehensive circulation that sustains quality of life in Orange neighborhoods. The project, therefore, meets this finding.

4. City services are available and adequate to serve the project (OMC 17.10.060.H.4).

The project was reviewed by the City’s interdepartmental Staff Review Committee and City services were found to be sufficient to serve the project. The project is an infill development located on a site that is already developed as a commercial use in an area of the City that is essentially built out. As such, City services are already available in the area to serve the site. The project, therefore, meets this finding.

5. The project has been designed to fully mitigate or substantially minimize adverse environmental effects (OMC 17.10.060.H.5).

Mitigated Negative Declaration No. ENV25-0001 analyzes the environmental impacts of the project and requires implementation of Project Design Features, Plans, Programs, and Policies, relating to Aesthetics, Air Quality, Cultural Resources, Energy, Geology and Soils, Greenhouse Gas Emissions, Hydrology and Water Quality, Noise, and Tribal Cultural Resources, and Mitigation Measures relating to Biological Resources, Noise, and 214
7 Tribal Cultural Resources. These mitigation measures reduce the environmental effects of the project to a less than significant level. The project, therefore, meets this finding.

SECTION 5 – ADMINISTRATIVE DESIGN REVIEW FINDINGS

1. The project design upholds community aesthetics through the use of an internally consistent, integrated design theme and is consistent with all adopted specific plans, applicable design standards, and their required findings (OMC 17.10.07.G.3).

With the proposed Zone Change and General Plan Amendment, the site is removed from the Limited Business Tustin Redevelopment Project Area (C-TR) zoning and therefore is not subject to the Tustin Street Design Standards.

The surrounding community is characterized by a mix of land use types and design styles with no specific architectural theme. Adjacent commercial and residential buildings are generally contemporary in style and one story in height. The proposed project will revitalize the neighborhood by replacing an existing vacant Best Buy retail building and surface parking lot with a distinctive, contemporary residential development that integrates with the surrounding development along North Tustin Street between Meats and Heim Avenues. Because of the Project’s flag lot configuration, the three-story residential units will be set back more than 220 feet from the Tustin Street right-of-way and will be partially buffered by existing one-story commercial buildings along the street frontage. Residential developments to the north and south are similarly located and buffered by commercial development. This substantial setback directs the project’s three-story massing away from the Tustin Street right-of-way and does not visually affect the existing appearance of the Tustin Street corridor. Three story units without roof decks are placed on the north and south perimeter boundaries and rear elevation second and third story windows will incorporate clearstory and/or frosted glass taking into consideration the privacy of adjacent one-story condominium and mobile home developments to the north and south. The applicant has also demonstrated that potential shading/shadowing will not impact the adjacent properties. The architectural design incorporates a combination of hip, flat, and shed roof forms, unique window arrangements and details, arched openings, use of trim and siding, and façade plane changes to add visual interest. The proposed landscape design, project lighting, and signage will enhance the architectural aesthetics and will contribute to the integration of the project with the surrounding development. This project presents a unifying theme and results in an internally consistent design that is compatible with the eclectic mix of styles in the surrounding area. Further, in order to accommodate this residential development project, a Zone Change, General Plan Amendment, and implementation of the Small Lot Subdivision Development Standards will allow a space efficient alternative housing type which would create an additional opportunity for homeownership in the City of Orange. The project, therefore, meets this finding.

SECTION 6 – CONDITIONS OF APPROVAL
BE IT FURTHER RESOLVED that the following conditions are imposed:
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8 General:

1. All Project Design Features, Plans, Programs, and Policies, and Mitigation Measures identified in Mitigated Negative Declaration No. ENV25-0001 and in the associated Mitigation Monitoring and Reporting Program, included as Attachments 7 and 8 to the City Council staff report for this project, shall be incorporated as conditions of approval for the project by the final decision-making body and shall be implemented as described in Mitigated Negative Declaration No. ENV25-0001.

2. Mitigated Negative Declaration No. ENV25-0001, General Plan Amendment No GPA25- 0003, Vesting Tentative Tract Map No. TTM25-0001, Major Site Plan Review No.

MJSP25-0002, and Administrative Design Review No. ADR25-0018 shall become void if not vested within two years from the date of approval. Time extensions may be granted pursuant to OMC Section 17.08.060.

3. Within two (2) business days of approval by the final decision-making body for this project, the applicant shall deliver to the Planning Division a cashier’s check payable to the Orange County Clerk in an amount required to fulfill the fee requirements of Fish and Game Code Section 711.4(d)(2) and the County administrative fee, to enable the City to file the Notice of Determination required under Public Resources Code 21152, and Cal Code Regulations 15075. If it is determined that there will be no impact on wildlife resources, the fee shall be as required based on the current fee schedule.

4. Within two (2) business days of final approval by the final decision-making body for this project, the applicant shall submit a deposit to the Planning Division for the Mitigation Monitoring and Reporting Program. Time spent by City staff to complete the project will be charged to the applicant on an hourly basis, in accordance with the city’s fee schedule.

5. These conditions shall be reprinted on the second and third pages of the construction documents when submitted to the Building Division for the plan check process.

6. This project shall conform in substance and be maintained in general conformance with plans and as recommended for approval by the City Council, unless modified by the City Council.

7. Except as otherwise provided herein, this project is approved as a precise plan and shall conform to, and be maintained in accordance with plans and exhibits labeled as Attachment 6 in the City Council staff report for this project. After any application has been approved, if changes are proposed regarding the location or alteration of any use or structure, a changed plan may be submitted to the Community Development Director for approval. If the Community Development Director determines that the proposed change complies with the provisions and the spirit and intent of the approval action, and that the action would have been the same for the changed plan as for the approved plan, the Community Development Director may approve the changed plan without requiring a new public hearing.
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9 8. Subsequent modifications to the approved architecture, color scheme, and landscape plan specifically shall be submitted for review and approval to the Community Development Director.

9. The applicant agrees, as a condition of the City’s approval of Mitigated Negative Declaration No. ENV25-0001, General Plan Amendment No. GP25-0003, Vesting Tentative Tract Map No. TTM25-0001, Major Site Plan Review No. MJSP25-0002, and Administrative Design Review No. ADR25-0018, to indemnify, defend, and hold harmless, at applicant’s expense, the City, its officers, agents, and employees (“City”) from and against any claim, action or proceeding brought against the City, including, but not limited to, any claim, action or proceeding commenced within the time period provided in Government Code Section 66499.37 to attack, review, set aside, void or annul the City’s approval, to challenge the determination made by the City under the California Environmental Quality Act (“CEQA”) or to challenge the reasonableness, legality or validity of any condition attached hereto. City shall promptly notify applicant of any such claim, action or proceeding to which the City receives notice and to cooperate fully with the applicant in the defense thereof. Applicant shall reimburse the City for any and all costs and expenses, including, but not limited to, court costs and attorney’s fees that the City may be required to pay, including any expenses ordered by a court or expenses incurred through the Office of the City Attorney in connection with said claim, action or proceeding. City may, in its sole discretion, participate in the defense of any claim, action or proceeding but such participation shall not relieve applicant of the obligations of this condition. In the event the applicant is required to defend City in connection with such claim, action or proceeding, City shall have the right to approve counsel to so defend the City, approve all significant decisions concerning the manner in which the defense is conducted and approve any all settlements, which approval(s) shall not be unreasonably withheld. The obligations set forth herein remain in full force and effect throughout all stages of litigation including any and all appeals of any lower court judgment rendered in the proceeding. Further, applicant agrees to indemnify, defend and hold harmless the City for all costs and expenses incurred in enforcing this provision.

10. The applicant shall comply with all federal, state, and local laws, including all City regulations. Violation of any of those laws in connection with the use will be cause for revocation of this permit.

11. The project approval includes certain fees and/or other exactions. Pursuant to Government Code Section 66020, these conditions or requirements constitute written notice of the fees and/or exactions. The applicant is hereby notified that the ninety (90) day protest period commencing from the date of approval of the project has begun. If the applicant fails to file a protest regarding these conditions or requirements, the applicant is legally barred from later challenging such exactions per Government Code Section 66020.

12. Prior to building permit issuance, the applicant shall pay all applicable Development Impact Fees in accordance with the current fee schedule at the time of final entitlement approval, including but not limited to: City sewer connection fees, Orange County Sanitation District connection fees, Transportation System Improvement Program (TSIP) 217
10 fees, Fire Facility fees, Police Facility fees, Park Acquisition fees, Library fees, Sanitation District fees, and School District fees, as required.

13. Prior to building permit issuance, the applicant shall pay any outstanding monies due to the City for Planning Division entitlement activities related to this project.

14. Building permits shall be obtained for all future construction work, as required by the City of Orange, Community Development Department’s Building Division. Failure to obtain the required building permits may cause for revocation of the entitlements provided.

15. All signage shall comply with Sign Regulations of the OMC, Chapter 17.36. Project signage shall be subject to Community Development Director approval.

16. Grading operations shall be restricted to Monday through Friday between the hours of 7:30 a.m. and 5:00 p.m., with limited grading as necessary permitted on Saturdays between the hours of 8:00 a.m. and 4:30 p.m. Mechanics may service the equipment up to two hours after each shift.

17. In conjunction with construction, all activity shall be limited to the hours between 7:00 a.m. and 8:00 p.m. Monday through Saturday. No construction activity will be permitted on Sundays and Federal holidays.

18. Prior to certificate of occupancy, the applicant shall contact the Orange Police Crime Prevention Bureau to schedule an on-site appointment to test all lighting to ensure it meets OMC standards. Any new lighting on the premise shall be installed in such a way to direct, control, and screen the lighting to prevent off-site light spillage onto adjoining properties and shall not be a nuisance to any point beyond the exterior boundaries of the property, or cause illumination in residential districts in excess of 0.5 foot-candles.

19. Prior to building permit issuance, the applicant shall demonstrate to the satisfaction of the Community Development Director that all mechanical and air conditioning equipment shall be shielded and screened from view from adjacent streets and properties. The screening shall be integrated architecturally with the building and painted to match the walls of the building.

20. Prior to building permit issuance, all required parking spaces shall be shown on construction documents as doubled striped to City standards at the time of approval.

21. Any graffiti shall be removed within 72 hours from the time the City of Orange Notice of Violation is received by the applicant/property owner.

22. Prior to building permit issuance, the applicant shall identify the precise location of existing walls proposed for demolition. If the location of the existing wall slated for demolition is wholly or partially upon an adjacent property, the applicant shall secure the property owner(s) approval to demolish and replace the wall. The applicant will be responsible for any site repairs to walls damaged through demolition activity. 218
11 23. Prior to building permit issuance, the applicant shall prepare a final landscaping and irrigation plan consistent with the grading plans, site plans, and the conceptual landscaping plan as proposed for the project, for the review and approval of the Community Development Director or designee.

24. Prior to City approval of the landscape plans, the applicant shall review the approved Water Quality Management Plan (WQMP) and ensure the proposed landscape plans are consistent with the project grading plans and show the proposed structural storm water treatment BMPs incorporated into the project.

25. Prior to building permit issuance, all landscaping located within public areas shall be shown on the landscape plans and shall include the installation of root barriers acceptable to the Public Works Department on the sidewalk side of the tree or where conditions warrant the installation of a Deep Root box as directed by the Public Works Director.

26. Prior to building permit issuance, final landscaping plans for the project shall be designed to comply with the City’s Water Efficient Landscape Guidelines as described in Section IX et al of the City of Orange Landscape Standards and Specifications. The project landscape architect shall submit documentation certifying compliance with this requirement (Appendix B of the City of Orange Landscape Standards and Specifications) for review and approval by the Community Development Director or designee in coordination with the Public Works Director or designee.

27. Prior to certificate of occupancy issuance, all landscaping improvements shall be completed according to the approved plans, the City of Orange Water Efficient Landscape Guidelines, and City of Orange Landscape Standards and Specifications. The project landscape architect shall submit documentation certifying compliance with this requirement (Appendix E of the City of Orange Landscape Standards and Specifications) for review and approval by the Community Development Director or designee, in coordination with the Public Works Director or designee.

28. Prior to building permit issuance, City required irrigation and landscape inspection notes, in accordance with the City of Orange Landscape Standards and Specifications, shall be placed on the final landscape plan, to the satisfaction of the Community Development Director or designee in coordination with the Public Works Director or designee.

29. Prior to building permit issuance, the final landscape plan shall be reviewed and approved by the Public Works Director when landscaping is proposed within the public right-of-way and/or the project is constructing Storm Water Quality Best Management Practices (BMPs) in landscaped areas.

30. Prior to building permit issuance, the final landscape plan shall include a note that a fully automated irrigation system will be provided.

31. Prior to building permit issuance, landscape plans shall include landscape area calculations needed for State landscape water use reporting.
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12 32. Prior to building demolition permit issuance, a Tree Removal Permit shall be approved by the Public Works Department in accordance with the City’s Tree Preservation Ordinance.

A plan is required for submittal to the City depicting all of the existing on-site trees, the specifics of each tree, and the number of trees proposed for removal and replacement.

33. Landscape maintenance shall be performed in such a manner as to allow all trees to retain their full canopy height for screening and full canopy breadth for shade at point of maturity, except as required for public safety purposes.

34. Landscaping shall be maintained so as to not interfere with lighting or addressing. All landscape areas shall be maintained in a neat and healthy condition. Should the plant material die, it shall be replaced at the earliest time with similar plant material.

35. Patio covers, pergolas, canopies, umbrellas larger than five feet in diameter, or similar shade structures, unsecured furniture, and overhead patio string lighting, on roof top decks are prohibited. Heat lamps and other outdoor accessory fixtures shall be secured in place and shall not extend above the height of the roof parapet/balcony railing.

36. The CC&R’s of the Homeowner’s Association for the project shall include enforceable restrictions prohibiting patio covers, pergolas, canopies, umbrellas larger than five feet in diameter, or similar shade structures, unsecured furniture, and overhead patio string lighting on roof top decks, and require that heat lamps and other outdoor accessory fixtures be secured in place and to not extend above the height of the roof parapet/balcony railing.

37. Storage of trash bins on private streets and within parking spaces is prohibited. A 20 feet by 20 feet inside clear area in each garage is to be maintained at all times for its intended use as vehicle parking. Guest parking shall remain available for and be used by guests.

Parking in fire access areas is prohibited. The Fire Chief can, at his/her discretion, require further street markings for fire lanes (including red curbing) if signage fails to keep fire lanes clear of vehicles or other obstructions.

38. The CC&R’s of the Homeowner’s Association for the project shall contain enforceable restrictions prohibiting storage of trash bins on the private street and within parking spaces.

CC&R’s shall also require a 20 feet by 20 feet inside clear area in each garage to be maintained at all times for its intended use as vehicle parking. CC&Rs shall contain enforceable restrictions to ensure guest parking remains available for and is used by guests.

The CC&R’s shall contain enforceable restrictions that prohibit parking in fire access areas.

The CC&R’s shall contain a provision that the Fire Chief can, at his/her discretion, require further street markings for fire lanes (including red curbing) if signage fails to keep fire lanes clear of vehicles or other obstructions.

39. Any changes to the CC&R’s at any time after building permit issuance shall require review and written approval by the Community Development Director. 220
13 40. Each unit is to maintain a minimum of 120 cubic feet of storage within the garage and outside of the 20 feet by 20 feet inside clear area, as shown on the submittal floor plans.

41. The CC&R’s shall indicate that each unit is to maintain a minimum of 120 cubic feet of storage within the garage and outside of the 20 feet by 20 feet inside clear area, as shown on the submittal floor plans.

42. Prior to approval of the Final Map, the Final Tract Map shall dedicate to the City and its assigns, and the City shall approve the method and language of the dedication, the right to enter the private streets and driveways for the maintenance of public utilities (if any), emergency access, trash collection, and for any other reasons stated in the dedication mechanism.

43. A Tentative Tract Map shall expire unless recorded within 24 months after tentative map approval (final City Council Resolution date) and prior to the sale or lease of any parcel, unless the tentative map is extended pursuant to Government Code Section 66452.6.

44. Model Homes shall comply with the following standards:
a. Within 90 days after the close of escrow of the last unit within the tract, restore the model homes, and remove the parking lots, signs, all temporary fencing, and the sales office as necessary to comply with the current applicable zoning regulations. b. A maximum of 10 on-site pennants are permitted in connection with the model homes sales use.
c. The applicant shall submit a plan identifying the model homes and parking areas and to reflect exact size, location, and copy of signs associated with the model home sales complex. The sign copy shall be limited to matters relating to the recorded tract within which the signs are located. Such signs shall have a time limit of existence concurrent with the use of the permitted temporary offices within the recorded tract. d. Signage whose purpose is to direct people to the development that is the subject of this permit shall conform to the requirements of the OMC. e. The model home sales office shall be used solely for the first sale of dwelling units approved under this permit.

45. Codes Covenants and Restrictions (CC&R’S) shall be designed and approved by the City for the entire site and address specific responsibilities of the Homeowners Association (HOA). A few specific areas include, but are not limited to:
a. Any aspect that is zoning in nature shall be structured so they cannot be rescinded or modified without City concurrence.
b. Maintenance responsibilities for any private drainage or water quality features. 221
14 c. Maintenance responsibilities for landscape areas, including parkway median roadway areas, arterial roadway landscaping, common slopes or native open space. d. Detailing enforcement options available to the City to ensure that maintenance is continuously undertaken for drainage and water quality, or other zoning aspects. e. Maintenance of any applicable private streets.
f. Maintenance of any applicable private recreation facilities. g. Identification of common open space lots that will be owned or under the control of the HOA and maintenance for open space lots.
h. A method to distribute the cost of required maintenance in an equitable manner among the owners of the dwelling units within the subdivision. i. The CC&R’s shall contain a provision that the Fire Chief can, at his discretion, require further street markings for fire lanes (including red curbing) if signage fails to keep fire lanes clear of vehicles or other obstructions.

46. A final acoustical report shall be prepared and approved by the City of Orange, showing that dwelling units have been sound attenuated for interior and exterior standards.

Evidence prepared by a state certified acoustical consultant shall be submitted to the Building Official describing the acoustical design features of the structures required to satisfy the exterior and interior noise standards and that sound attenuation measures have been incorporated into the design of the project. The applicant shall show all freestanding acoustical barriers on the project’s plot plan illustrating height, location, and construction in a manner meeting the approval of the Building Official.

47. Prior to building permit issuance, properties along the north, south, and southwest property lines shall maintain 10-foot minimum depth private useable open space areas as measured from the first-floor rear elevation building face to the face of the property boundary walls.

48. All windows on the second-floor rear elevations of units on lots 1 - 20 and 54 - 68 facing the north, south, and southwest property lines shall be clerestory with minimum sill heights of 5 feet above floor level.

49. The CC&Rs shall indicate that all windows on the second-floor rear elevations of units on lots 1 - 20 and 54 - 68 facing the north, south, and southwest property lines shall be clerestory with minimum sill heights of 5 feet above floor level.

50. Third story bedroom windows on the rear elevations of units on lots 11 - 20 and 54 - 59 facing the north and south property lines shall contain frosted glass. 222
15 51. The CC&Rs shall indicate that third story bedroom windows on the rear elevations of units on lots 11 - 20 and 54 - 59 facing the north and south property lines shall contain frosted glass.

52. The project shall be limited to 14 four-bedroom units.

53. The third unenclosed parking space on each lot with a four-bedroom unit shall be clearly marked for resident parking assigned to each respective four-bedroom unit.

54. Guest parking spaces shall be clearly marked as guest parking.

55. Any proposed attached patio covers on the rear elevations of units on lots 6-20 and 54-68 shall maintain a minimum five-foot setback from the north and south property lines as measured to the patio cover post. No attached patio covers on the rear elevations of units 1 - 5 are permitted.

Building Division:

56. Prior to building permit issuance, beginning on January 1, 2026, each California City is required by State law to enforce the 2025 Edition of California Building Standards Codes (a.k.a., Title 24 of the California Codes of Regulations). All projects submitted before or on December 22, 2025, are permitted to comply with the 2022 Edition of the California Building Standards Code.

57. Prior to building permit issuance, construction plans shall include and comply with the following:
a. The City of Orange has adopted the 2025 California Code Amendments and Local Ordinance.
b. A space measuring 2 inches in height and 3 inches in width shall be provided at the top right corner of each sheet for the City’s electronic approval stamp. c. The City of Orange is located in Seismic Design Category D. d. The ultimate wind speed is 95 mph; this can be verified with ASCE 7-22, chapter 26, 2025 CBC Table 1609.3(1). Most areas of Orange can be classified as wind exposure category C.
e. Provide a “Green Code Checklist”. The green measures associated with the project shall be clearly specified as to what sheet of plans are shown. f. Plans shall note that a Cal-OSHA permit is required for excavations deeper than 5 feet and for shoring and underpinning. Contractor to provide a copy of the OSHA permit. g. A soil report is required.
223
16 h. Plans shall include a complete plot plan showing: lot dimensions, yard setbacks, street name(s), north arrow, and easement(s).
i. Provide Certificate of Compliance documents.
j. Plans shall include the following regarding roof construction and covering:

1. Details of roof construction assembly.

2. Specification of ICC approval number for tile and weight of special roof coverings.

3. Class “A” roofing is required.
k. Include Energy Conservation –Title 24 energy forms & calculations: Certificate of Compliance Documents.
l. Roof eave projections of dwelling units and accessory buildings with automatic residential fire sprinkler protection are not permitted less than 2 feet to the property line and are required to be 1 hour fire rated on the underside with a fire separation distance between 2 feet and 3 feet [CRC Table R302.1 (2)].
m. Walls of dwelling units and accessory buildings with automatic residential fire sprinkler protection with a fire separation distance less than 3 feet are required to have a full one-hour rating [CRC Table R302.1 (2)].
n. Openings are not permitted less than 3 feet to the property line. In projects without automatic residential fire sprinkler protection, openings are limited to 25 percent the wall area when fire separation distance is greater than 3 feet and less than 5 feet [CRC R302.1 (1)].
o. Provide specifications from the heat pump water heater company for using metal enclosures. Otherwise, provide framing and foundation for the heat pump water heater. p. The cover sheet of the plans shall list all HERS inspection features and special features required. This shall be coordinated with the Energy Report. q. Plans shall include a “Foundation & Finished Floor Certificate” form. This form is located on the City’s website at:
https://www.cityoforange.org/home/showpublisheddocument/3182. r. The Utility Plan shall be fully dimensioned demonstrating the locations for proposed utilities such as sewer, water, gas, and electric.
s. Plans shall note that a pre-construction meeting is required with the City inspector. t. The minimum sewer slope is 2%.
u. A maximum of five water closets are allowed on a 3” drain line (Table 703.2 note #4 CPC).
224
17 v. A new gas line may be required per device requirements. w. A Temporary power pole may be required per site conditions. This will be determined by the City inspector.
x. Construction fencing may be required if construction materials are placed in front of the property, people are living inside the house during construction, or if no existing fencing is located around the property. This will be determined by the City inspector. y. Location of the electric meter may be changed due to Edison’s requirements and clearance.
z. Provide a letter of agreement from the neighbor that workers may work on the neighbor’s side during construction.
aa. For the sewer line, provide the drainage fixture unit (DFU) table and clarify the length and size of pipe on plan.
bb. For the water line, provide the fixture unit count and clarify the length and size of pipe on plan.
cc. Plans shall show that walls/partitions and floor-ceiling assemblies separating dwelling units shall be rated for fire (1-hr) and sound (50 STC). Please provide tested assembly number (UL#) and details on plan.

Fire Department:

58. Plans submitted for building plan review shall comply with the California Fire Code as amended by the City and as frequently amended and in effect at the time of application for building permit.

59. Onsite fire department access will require reciprocal easement recording prior to final map recordation and shall be reviewed by Fire prior to approval. Because new property lines extend into the shared roadways, the onsite easement recording shall include reciprocal access amongst all properties. Recording shall include a Declaration of Restrictions in perpetuity, to include impact and liability being created by the shared obligation of all property owners and future individuals with interest to each property. All maintenance of, including but not limited to, roadways, utility mains, fire lane signage, markings, fire lines, fire hydrants testing and service, and all equipment thereto within the reciprocal easement.

In addition, the required offsite easement, providing the required secondary emergency access shall be recorded prior to rough grading permit issuance. 225
18 Police Department:

60. Security and design measures that employ defensible space concepts shall be utilized in development and construction plans. These measures incorporate the concepts of Crime Prevention through Environmental Design (CPTED), which involves considerations such as placement and orientation of structures, access and visibility of common areas, placement of doors, windows, addressing, and landscaping. CPTED promotes public safety, physical security and allows citizens the ability to monitor activity. 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.

The project shall also comply with the requirements contained in the City of Orange Municipal Code Chapter 15.52, Building Security Construction Standards reference Ordinance #6-22.

Public Works Department, Subdivision Section:

61. Site grading shall conform to the latest California Building Code Section 1804. The ground immediately adjacent to the foundation shall be sloped away from the building at a slope of 5% for pervious surfaces, and 2% for impervious surfaces, at a minimum distance of 10 feet.

62. The contractor shall obtain a grading permit from Public Works Department prior to start of any site demolition, clearing and grubbing, and grading.

63. Any soil imported or exported shall require a Transportation Permit from Public Works Traffic Division prior to start of construction.

64. Upon submittal of grading plan for plan check, the applicant shall submit a deposit to cover plan check and inspection services related to the grading activities

65. The grading plan shall detail all locations where retaining walls will be constructed.

Geometric details of retaining walls shall be shown on the grading plan, including material type, dimensions, backfill, and subdrains. A building permit is also required for retaining walls over 4 feet in height measured from the bottom of the footing to the top of the wall prior to construction. Structural details and design calculations shall be submitted as a separate document and will be reviewed and permitted by City Building Division.

66. Any grading outside of the owner’s property boundary shall require the applicant to either obtain temporary construction easements or permission by adjacent property owners in a form suitable to the Public Works Director prior to rough grading permit issuance.

67. Show all structural BMPs for water quality purposes on the grading plan. Water quality features shown on the grading plan must match the WQMP.

68. The property owner shall maintain in good condition, all on-site driveways where heavyduty trucks would travel throughout construction. 226
19 69. Prior to building foundation construction, a Certificate Letter of Line and Grade shall be submitted to Public Works Construction Inspector demonstrating that the site grading and pad elevation are completed according to the grading plan.

70. Prior to building permit issuance, the applicant shall submit an address number request, including an addressing plan, to the Public Works Department for review and approval.

71. The final map and CC&R’s shall be recorded (model homes excluded) prior to building permit issuance or sale or lease of any parcels.

72. All trash carts shall be labeled to identify the unit/address number and shall be addressed in the CC&R’s.

73. All works within public right-of-way and public utility easements will require Encroachment Permits, including sidewalk and driveway constructions and utility main and lateral constructions.

74. All public infrastructures, including street sections, sidewalk, driveway apron, and utilities shall comply with City of Orange Standard Plans and Specifications.

75. Utilities serving the development, such as electric, cable television, street lighting and communication shall be installed underground, completed and approved by the appropriate utility provider.

76. Sanitary sewer system connecting from the buildings to the public mainline shall be private and maintained by the property owner.

77. The applicant shall remove unused driveway approaches and restore them to full height curb and gutter, including any sidewalk restoration at the driveway apron.

78. Driveway aprons shall conform to Public Works Standard Plan 115 for commercial driveway with ADA accessibility.

79. Repair any cracked, uneven, or damaged public sidewalk, curb and gutter along property frontage.

80. Pavement restorations on streets, under Moratorium or with a Pavement Condition Index of 75 or greater, shall be completed per Standard Plan 125.

81. The applicant shall submit a grading plan in compliance with City standards for review and approval by the Public Works Director prior to grading permit issuance. All grading and improvements on the subject property shall be made in accordance with the Manual of Grading and Standard Plans and Specifications to the satisfaction of the Public Works Director. The applicant may be required to include Phased Erosion and Sediment Control Plans, Site Demolition Plan, and Utility Plan as parts of the grading plan. 227
20 82. A Hydrology Study/Report or Drainage Assessment Letter shall be submitted for review and approval by the Public Works Department. The Hydrology Study/Report shall comply with the Orange County Hydrology Manual and Addenda (OCHM). Design Storm Frequency at a minimum, shall be 10-year storm (25-year in a sump condition), and a 100- year storm event. Proposed improvements shall comply with freeboard requirements per OCHM and County Local Drainage Manuals. Approval is required prior to rough grading permit issuance.

83. The CC&R’s shall be subject to a joint review by the Community Development Director, Public Works Director, and City Attorney. The applicant shall be required to pay for the review of the CC&R’s by the City Attorney, Public Works Director and the Community Development Director at the City’s hourly billing rate.

84. Prior to rough grading permit issuance, the applicant shall submit and have approved an Offsite Emergency Access Easement dedicated to the City. Additionally, a Reciprocal Emergency Access Agreement between the adjacent land owner and the applicant must be recorded and a copy provided to the City.

Public Works Department, Water Division:

85. Prior to encroachment permit issuance, the applicant must prepare and provide product material submittals consistent with the water improvement plans for all proposed public water system facilities to the Water Division per the City of Orange Standard Specifications and Plans For the Construction of Water System for review and approval.

86. Plans submitted during plan check must show that the minimum separation requirements are met and that each of the various designer’s plan sets match. The applicant’s consultant preparing the improvement and utility plans must coordinate their plans with the consultants preparing the landscape, architectural, surface water quality management, fire master and/or fire suppression plans so that all designs are consistent.

87. Plans submitted during plan check must show that the water improvement plans are consistent with the fire suppression plans and or fire master plan. The applicant’s consultant preparing the water improvement plans must coordinate their plans with the consultant preparing the fire suppression plans and/or fire master plan so that their designs concur.

88. Prior to approval of a water improvement plan, the applicant must satisfy all water main connection, plan check, and inspections charges as determined by the Water Division.

89. Prior to building permit issuance for the first phase of work, the applicant will be responsible for obtaining approval of all necessary encroachment permits from affected agencies for all public water construction work.
228
21 90. Prior to building permit issuance, construction documents must show that permanent signs, awning, surface water quality management features or other structures are not built over water mains, laterals, services, meters, or fire hydrants as required by the Water Division.

91. Prior to building permit issuance, the applicant must submit construction documents that show that an eight-foot minimum clearance is provided between City water mains, laterals, services, meters, fire hydrants, signs, or trees or other substantial shrubs and plants as required by the Water Division. The Water Division will review and approve the construction documents.

92. Prior to building permit issuance, the construction documents must show that a six-foot minimum horizontal clearance and a one-foot minimum vertical clearance would be maintained between City water mains, laterals, services, meters, fire hydrants and all other utilities except sewer. The Water Division will review and approve the construction documents.

93. Prior building permit issuance, the construction documents must show that the installation of sewer mains in the vicinity of water mains is done per the Department of Public Works Water Division Standard No. 113 and will be approved by the Water Division.

94. Prior building permit issuance, the Water Division will approve the type and location of landscaping services, fire services, and backflow prevention devices for proposed City services.

95. Prior certificate of occupancy issuance, the applicant will be responsible for the installation of necessary fire hydrants and fire services as approved by the Fire Department and Water Division.

96. Prior to precise grading permit or building permit issuance, the applicant will be responsible for the installation and/or relocation of the proposed or existing public water system facilities to a location and of a design per the improvement plans approved by the Water Division.

97. Prior to precise grading permit issuance, the applicant may be required to enter into an agreement with the City of Orange, and post security in a form and amount acceptable to the City Engineer and/or Water Division to ensure construction of all public and/or private improvements to the satisfaction of the Water Division.

98. Prior to any grading permit or building permit issuance, the applicant must submit improvement plans to the Water Division for review and approval for any new fire hydrants, domestic water services, fire services, landscape services, backflow prevention devices, and any other proposed improvements or relocations affecting the public water system facilities.

Public Works Department, Water Quality Division:

99. Prior to grading permit issuance, the applicant shall demonstrate that coverage has been obtained under the State’s General Permit for Storm water Discharges Associated with 229
22 Construction Activity (Construction General Permit) by providing a copy of the Notice of Intent (NOI) submitted to the State Water Resources Control Board and a copy of the subsequent notification of the issuance of a Waste Discharge Identification (WDID) Number or other proof of filing. A copy of the current SWPPP required by the General Permit shall be kept at the project site and be available for review by City representatives upon request.
100. The project applicant shall maintain all structural, treatment and low impact development BMPs at the frequency specified in the approved WQMP. Upon transfer of ownership or management responsibilities for the project site, the applicant shall notify the City of Orange Public Works Department of the new person(s) or entity responsible for maintenance of the BMPs.
101. Prior to building permit issuance, the applicant shall review the approved Water Quality Management Plan (WQMP) and grading plan to ensure the structure’s downspouts or drainage outlet locations are consistent with those documents. Copies of the building or architectural plans specifically showing the downspouts and drainage outlets shall be submitted to the Public Works Department for review.
102. Prior to certificate of occupancy issuance or final sign-off by the Public Works Department, the applicant shall demonstrate to the satisfaction of Public Works, that the preparer of the WQMP has reviewed the BMP maintenance requirements in Section V of the WQMP with the responsible person and that a copy of the WQMP has been provided to that person. A certification letter from the WQMP preparer may be used to satisfy this condition. 103. Prior to certificate of occupancy issuance, the applicant shall demonstrate the following to the Public Works Department:
a. That all structural and treatment control best management practices (BMPs) described in the Project WQMP have been constructed and installed in conformance with the approved plans and specifications.
b. That the applicant is prepared to implement all non-structural BMPs described in the Project WQMP.
c. That an adequate number of copies of the project’s approved final Project WQMP are available for the future occupiers.
104. Prior to final map recordation, a copy of the project’s CC&Rs shall be provided to the Public Works Department for review and approval that includes requirements for maintenance and funding of the project’s structural and treatment water quality best management practices as approved by the City in the project’s WQMP. 105. Prior to grading permit issuance, the applicant shall submit a Priority Project WQMP for review and approval to the Public Works Department that:
230
23 a. Prioritizes the use of Low Impact Development principles as follows: preserves natural features; minimizes runoff and reduces impervious surfaces; and utilizes infiltration of runoff as the method of pollutant treatment. Infiltration BMPs to be considered include the use of permeable materials such as concrete and concrete pavers, infiltration trenches, infiltration planters, and other infiltration BMPs as applicable.
b. Incorporates the applicable Site Design, Routine Source, Structural Control and Low Impact BMPs as defined in the Model Water Quality Management Plan and Technical Guidance Document.
c. Maintains the hydrologic characteristics of the site by matching time of concentration, runoff, velocity, volume and hydrograph for a 2-year storm event. d. Minimizes the potential increase in downstream erosion and avoids downstream impacts to physical structures, aquatic and riparian habitat. e. Generally describes the long-term operation and maintenance requirements for structural and Treatment Control BMPs.
f. Identifies the entity or employees that will be responsible for long-term operation, maintenance, repair and or replacement of the structural and Treatment Control BMPs and the training that qualifies them to operate and maintain the BMPs. g. Describes the mechanism for funding the long-term operation and maintenance of all structural and Treatment Control BMPs.
h. Includes a copy of the forms to be used in conducting maintenance and inspection activities.
i. Meets recordkeeping requirements (forms to be kept for 5 years). j. Includes a copy of the form to be submitted annually by the project owner to the Public Works Department that certifies that the project’s structural and treatment BMPs are being inspected and maintained in accordance with the project’s WQMP.

ADOPTED this ____ day of ____________________, 2026
Daniel R. Slater, Mayor, City of Orange
231
24 ATTEST:

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

Nathalie Adourian, City Attorney,
City of Orange

STATE OF CALIFORNIA )
COUNTY OF ORANGE ) ss.

AYES: COUNCILMEMBERS:

NOES: COUNCILMEMBERS:

ABSENT: COUNCILMEMBERS:

Pamela Coleman, City Clerk, City of Orange
232
Attachment A
Legal Description
233
Attachment B
Existing General Plan Map
234
Attachment C
Proposed General Plan Map
235
ORDINANCE NO. 06-26

AN ORDINANCE OF THE CITY COUNCIL OF

THE CITY OF ORANGE APPROVING ZONE
CHANGE NO. ZC25-0002 TO CHANGE THE

ZONING CLASSIFICATION FROM LIMITED

BUSINESS TUSTIN REDEVELOPMENT

PROJECT AREA (C-TR) TO RESIDENTIAL
MULTIPLE FAMILY (R-3) ON A 4.23-ACRE
SITE LOCATED AT 2375 N. TUSTIN STREET
ZONE CHANGE NO. ZC25-0002
APPLICANT: CHAD BROWN, MILIA OMES
WHEREAS, the City Council has authority per Orange Municipal Code (“OMC”) Section

17.10.020 and Government Code Section 65850 to adopt ordinances amending the City’s Zoning Ordinance and to approve Zone Changes; and
WHEREAS, the application for Zone Change No. ZC25-0002 was filed by Chad Brown, Melia Homes in accordance with the provisions of the OMC for a proposal to redevelop a vacant commercial site with 71, three-story single-family small lot homes, open space recreation area, guest parking, and related site improvements on a 4.23-acre site located at 2375 N. Tustin Street (“Project”); and
WHEREAS, the application for Zone Change No. ZC25-0002 was processed in the time and manner prescribed by state and local law; and
WHEREAS, applications for Mitigated Negative Declaration No. ENV25-0001, General Plan Amendment No. GPA25-0003, Tentative Tract Map No. TTM25-0001, Major Site Plan Review No. MJSP25-0002, and Administrative Design Review Design Review No. ADR25-0018 were filed concurrently with Zone Change No. ZC25-0002; and WHEREAS, the Planning Commission conducted a duly advertised public hearing on April 6, 2026, considered public comments, and recommended approval of the project by a 4-2 vote to the City Council, including Zone Change No. ZC25-0002; and WHEREAS, the City Council adopted Mitigated Negative Declaration No. ENV25-0001 and associated Mitigation Monitoring and Reporting Program, which was prepared to analyze potential environmental impacts of the Project, including Zone Change No. ZC25-0002 (“Zone Change”); and
WHEREAS, the City Council adopted Resolution No. 11685, adopting Mitigated Negative Declaration No. ENV25-0001, and approving General Plan Amendment No. GPA25- 0003, Tentative Tract Map No. TTM25-0001, Major Site Plan Review No. MJSP25-0002, and Administrative Design Review No. ADR25-0018 for a proposal to redevelop a vacant commercial Attachment 2
236
2 site with 71, three-story single-family small lot homes, open space recreation area, guest parking, and related site improvements on a 4.23-acre site located at 2375 N. Tustin Street (“Project”); and WHEREAS, the City Council conducted a duly advertised public hearing on May 26, 2024, at which time interested persons had an opportunity to testify either in support of or opposition to the project, including Zone Change No. ZC25-0002.

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

SECTION I:

The existing zoning is depicted on the map attached hereto as Exhibit “A” and incorporated herein by reference. Section 17.06.030 of the Orange Municipal Code is amended in order to change the zoning classification by amending the zoning on the site as depicted on the map attached hereto as Exhibit “B” and incorporated herein by reference.

SECTION II:

1. The proposed Zone Change from Limited Business Tustin Redevelopment Project Area (C-TR) to Residential Multiple Family (R-3) makes the project’s zoning consistent with the Medium Density Residential General Plan (MDR) land use designation established by the project’s General Plan Amendment No. GPA25-0003, as required by law (Government Code Section 65860).

2. Table LU-3 in the General Plan Land Use Element indicates that residential zoning districts, including the R-3 and R-4 zones are compatible with the MDR General Plan land use designation established by the project’s General Plan Amendment No. GPA25-0003.

3. The R-3 zoning and implementation of the Small Lot Subdivision Development Standards allows a small lot residential development use and physical development conditions that are generally compatible with the Residential Multiple Family (R-3(A)) zoning to the north and south and Limited Business Tustin Redevelopment Project Area (C-TR) zoning to the west which accommodates a mix of retail and service commercial uses, and professional offices. The zoning supports the pattern of residential development to the north and south of the site on Tustin Street.

4. The proposed Zone Change furthers the goals and Policy Actions of the General Plan Housing Element and the City’s work toward meeting its Regional Housing Needs Allocation by contributing to the market-rate housing inventory in the community.

SECTION III:

The proposed Zone Change described in Section I is related to the public welfare, is consistent with the accompanying Mitigated Negative Declaration No. EMV25-0001, General Plan Amendment No. GPA25-0003, Tentative Tract Map No. TTM25-0001, Major Site Plan Review No. MJSP25-0002, and Administrative Design Review No. ADR25-0018 filed herewith, 237
3 and furthers the objectives and policies of the General Plan as is more specifically set forth in Resolution No. 11685, which is incorporated by reference as though fully set forth herein.

The proposed Zone Change from Limited Business Tustin Redevelopment Project Area (C-TR) to Residential Multiple Family (R-3) would make the proposed zoning classification consistent with the proposed General Plan land use designation. The Project would meet the Small Lot Subdivision Development Standards for the R-3 zone.

SECTION IV:

Mitigated Negative Declaration (MND) No. ENV25-0001 was prepared to evaluate the physical environmental impacts of the zone change and associated development project, in conformance with the provisions of the California Environmental Quality Act (CEQA) per state CEQA guidelines Section 15070 and the local CEQA Guidelines. No land use impacts have been identified in the MND. The MND finds that the project will have less than significant impacts to the environment, with the implementation of Project Design Features, Plans, Programs, and Policies, relating to Aesthetics, Air Quality, Cultural Resources, Energy, Geology and Soils, Greenhouse Gas Emissions, Hydrology and Water Quality, Noise, and Tribal Cultural Resources, and Mitigation Measures relating to Biological Resources, Noise, and Tribal Cultural Resources.

SECTION V:

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

SECTION VI:

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

ADOPTED this day of , 2026.

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

Pamela Coleman, City Clerk, City of Orange
238
4 APPROVED AS TO FORM:

Nathalie Adourian, City Attorney, City of Orange

STATE OF CALIFORNIA )

COUNTY OF ORANGE )

CITY OF ORANGE )
I, PAMELA COLEMAN, City Clerk of the City of Orange, California, do hereby certify that the foregoing Ordinance was introduced at the regular meeting of the City Council held on the ____ day of May, 2026, and thereafter at the regular meeting of said City Council duly held on the ____ day of ________________, 2026 and was duly passed and adopted by the following vote:

AYES: COUNCILMEMBERS:

NOES: COUNCILMEMBERS:

ABSENT: COUNCILMEMBERS:

ABSTAIN: COUNCILMEMBERS:

Pamela Coleman, City Clerk, City of Orange
239

EXHIBIT A
Existing Zoning Map
240

EXHIBIT B
Proposed Zoning Map
241
J:\GisProjects\DRC_PC_Staff_reports\North Tustin Street Residential_2375 N. Tustin 2/3/2026
Source: City of Orange (2026)
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CITY OF ORANGE

NORTH TUSTIN STREET RESIDENTIAL PROJECT

VICINITY MAP
Application Numbers: GPA25-0003,
ZC25-0002, TTM25-0001, MJSP25-0002,
ADR25-0018, and ENV25-0001
Address: 2375 N. Tustin Street
Zoning: C-TR
Attachment 3
242
2375 N. TUSTIN STREET
Site and Surrounding Area Photos (Existing)
Attachment 4
243
244
245
246
247
248
249
250
11661 San Vicente Blvd. Suite 306
Los Angeles, California 90049-5111
310.820.2680-p
www.stanleyrhoffman.com
2375 N Tustin St., Residential Project
Fiscal Impact Analysis
City of Orange
Prepared for:

Melia Homes LLC
9860 Irvine Center Drive
Irvine, CA 92618
Attn: Gavin Reid, Vice President, Land Acquisitions
(949)759-4367
December 12, 2025
SRHA Job #1410
Attachment 5
251
Stanley R. Hoffman Associates, Inc.

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CONTENTS
Tables .................................................................................................................................. ii Figures ................................................................................................................................. iii EXECUTIVE SUMMARY ........................................................................................................... iii CHAPTER 1 INTRODUCTION ....................................................................................................1

1.1 Background ......................................................................................................................1

1.2 Approach..........................................................................................................................2

1.3 Organization of the Report ..............................................................................................3 CHAPTER 2 PROJECT DESCRIPTION..........................................................................................4

2.1 Development Description after Buildout.........................................................................4

2.2 Assessed Valuation and Property Tax ..............................................................................6

2.3 Projected Off-Site Retail Sales and Use Tax .....................................................................8

2.4 Major One-Time Development Impact Fees....................................................................9 CHAPTER 3 FISCAL IMPACTS.................................................................................................. 10

3.1 Proposed Residential General Fund Impacts.................................................................10

3.2 Proposed Residential Other City Funds Impacts............................................................12

3.3 No-Project Scenario: Major Revenues Analysis.............................................................12 CHAPTER 4 CITY OF ORANGE FISCAL ASSUMPTIONS.............................................................. 14

4.1 City General Assumptions..............................................................................................14

4.2 City Revenue Assumptions.............................................................................................16

4.3 City Cost Assumptions....................................................................................................20 APPENDIX A SUPPORTING FISCAL TABLES ............................................................................. 24 APPENDIX B PROJECT REFERENCES ....................................................................................... 31 252
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TABLES
2-1 Development Description after Buildout.............................................................................5 2-2 Assessed Valuation and Property Tax..................................................................................6 2-3 Estimated Existing Assessed Valuation................................................................................7 2-4 Off-Site Taxable Retail Sales Tax..........................................................................................8 2-5 Summary of Estimated One-Time City Development Impact Fees......................................9 3-1 Summary of Projected Fiscal Impacts after Buildout.........................................................10 3-2 General Fund Detailed Projected Recurring Fiscal Impacts...............................................11 3-3 Comparison of Major Revenues: No Project Scenario.......................................................13 4-1 City Population, Housing and Employment Assumptions .................................................15 4-2 Recurring General Fund Revenue Factors.........................................................................17 4-3 General Fund Recurring Cost Factors................................................................................20 4-4 Calculation of City General Government Overhead Rate..................................................21 A-1 Inflow-Outflow Patterns of Workers Employed in the City ...............................................24 A-2 General Fund Recurring Revenues ....................................................................................25 A-3 Current Tax Rate Area (TRA) Allocations...........................................................................27 A-4 Estimated Property Tax In Lieu Vehicle License Fee (VLF) Factor......................................27 A-5 Estimated Average Household Income, Single-Family Ownership, Orange County..........28 A-6 Calculation of Use Tax Factor ............................................................................................28 A-7 Net Costs: Public Works, Comm. Development, and Comm. Services..............................29 A-8 Details of Comparative Revenue Performance Evaluation for Non-Residential Uses.......30

FIGURES
1 Project Location, 2375 N Tustin Street Residential Project................................................iii 2 Comparison of Major Revenue Categories: Residential versus Commercial......................iv 1-1 Project Vicinity, 2375 N Tustin Street Residential Project...................................................2 2-1 Conceptual Site Plan, 2375 N Tustin Street Residential Project..........................................4 253
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EXECUTIVE SUMMARY
This study evaluates the annually recurring fiscal impacts from the proposed Melia Homes forsale single-family residential project on the City of Orange General Fund. The project is being proposed at 2375 N Tustin Street, which is currently occupied by a vacant Best Buy. The study estimates project-generated General Fund revenues, including taxes and fees, compared against General Fund costs for the provision of City services to project residents. • As shown in Figure 1, the project site is sandwiched between residential uses to the north and south, and therefore, ideally suited for a continuation of these same uses. • The current commercial property has been vacant for two years and has not been able to attract viable lessees despite persistent efforts. Limited street-front access on N Tustin Street, combined with a large presence of existing commercial in the vicinity, make the site unattractive for retail uses in an increasingly tough market for brick-and-mortar stores. • The proposed redevelopment to residential use includes 71 single family units comprising 3- and 4-bedroom units in the size range of 2,000-2,100 square feet. The project will have a stabilizing effect on the neighborhood through community ties and economic development benefits from new household spending on goods and services captured within the City.

Figure 1
Project Site Location
2375 N Tustin Street Residential Project, City of Orange 1 Project Location, 2375 N Tustin Street Residential Project Source: Melia Homes, LLC; Stanley R. Hoffman Associates, Inc. 254
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• Overall, it is estimated that the proposed Melia Homes residential project will have a net positive fiscal impact on the City General Fund of $92,600 on an annually recurring basis in constant 2025 dollars, based on $203,400 generated in total gross revenues and $110,800 in City operations and maintenance costs (details in Section 3.1). • The proposed project also generates a total of $2,686,865 in one-time development impact fees, including $1,539,205 for City capital projects, $667,000 in school fees, and $481,000 in County fees.
• The proposed project is compared with a ‘No Project’ scenario that assumes the continued use of the existing vacant building by viable commercial uses identified for the site, including sports and fitness uses, deep discount stores, and seasonal stores. To fully lease out the available 40,000 sf vacant space, a combination of these uses might be necessary. • As shown in Figure 2, evaluated for major revenue categories, the limited viable commercial uses identified for the vacant property generate between $44,300 and $61,100 to City General Fund revenues (details in Section 3.3).
• This is significantly lower compared against around $184,000 for the same major revenue categories, for like-to-like comparison, generated by the proposed residential project. In fact, even after backing out General Fund costs, the net fiscal surplus of the proposed residential project is higher compared against the gross revenues from the commercial uses. • Overall, from the fiscal and economic perspectives, the proposed Melia Homes residential project is a better fit for the specific case of 2375 N Tustin Street site compared to the limited viable tenants for the existing vacant commercial property.

Figure 2
Comparison of Major Revenue Categories: Residential versus Commercial 2375 N Tustin Street Residential Project, City of Orange (in Constant 2025 Dollars)
2 Comparison of Major Revenue Categories: Residential versus Commercial Source: Stanley R. Hoffman Associates, Inc.
$183,587
$44,335
$61,136 $54,903
$0
$20,000
$40,000
$60,000
$80,000
$100,000
$120,000
$140,000
$160,000
$180,000
$200,000
Proposed Residential Gyms Discount Stores Seasonal Stores Major revenue categories included in
this graph are Property Tax, Property
Tax In-lieu of Vehicle License Fee, Onsite and Off-site Sales and Use Tax, and Business License Fees.
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CHAPTER 1

INTRODUCTION
This report presents the fiscal impact analysis for the proposed 2375 N Tustin Street Residential Project. The fiscal impact analysis projects recurring public revenues and costs to the City of Orange General Fund assuming full development of the project. Major one-time development impact fees are also projected for full buildout of the project.

1.1 Background
The proposed project includes 71 single family residential units for-sale on a 4.23-acre site (184,259 square feet) (APN 372- 642- 31) located in the central portion of the City of Orange between the Costa Mesa Freeway (SR 55) and N Tustin Ave, as shown in Figure 1. Regional access to the project is provided by the Costa Mesa Freeway to the west and the SR-91 Freeway to the north of the City.

The project site currently includes a vacant commercial property, formerly occupied by Best Buy, and is zoned as ‘Limited Business Tustin Redevelopment Project Area (C-TR)’, as per an overlay update made by the City Council in 2021, which accommodates commercial development. The existing commercial property has been vacant for two years and has not been able to attract viable lessees despite persistent efforts. This proposed redevelopment project for the site is a new for-sale single family residential development, which will replace the existing vacant commercial, for a total of 71 units, including 3-bedroom units (Plans 1, 2, 4 and 5) and 4-bedroom units (Plan 3).

The focus of the fiscal analysis is the ongoing operations and maintenance costs to the City of Orange as provided through the General Fund. General Fund revenues include property, sales and use taxes and other taxes; franchise fees; fines and forfeitures; licenses and permits; charges for current services; revenues from other agencies; use of money and property; and other miscellaneous revenues. The ongoing range of services that the City of Orange provides includes police and fire protection; planning; public works, including engineering, road maintenance and park maintenance; community services; library services; and general government. Also projected are special fund revenues, including the Gas Tax Fund, which receives revenues primarily from gasoline taxes collected by the Federal and State governments, and Prop 172 Public Safety and Measure M2 Transportation funds, which are 1/2 cent sales tax measures earmarked for public safety and transportation projects, respectively.
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Figure 1-1
Project Vicinity
2375 N Tustin Street Residential Project Fiscal Impact Analysis City of Orange
1-1 Project Vicinity, 2375 N Tustin Street Residential Project Source: Stanley R. Hoffman Associates, Inc.

1.2 Approach
The fiscal analysis and the estimated major one-time development impact fees associated with the 2375 N Tustin Street Residential Project are based on data and assumptions from the following sources:
• City of Orange revenue and cost factors are estimated based on the City of Orange, Fiscal Year 2025-26 Adopted Budget.
• The fiscal methodology is based on previous fiscal analyses prepared by Stanley R. Hoffman Associates, as presented in Chapter 4.
• Project information was obtained from the project developer, Melia Homes LLC. • Cost and revenue factors are projected In Constant 2025 dollars and are not adjusted for possible inflation.N Tustin Street
Costa Mesa Fwy
Vacant
Best Buy
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1.3 Organization of the Report
Chapter 2 presents the detailed project description for the 2375 N Tustin Street Residential Project assuming full buildout. Chapter 3 consists of the detailed fiscal impacts from the project on the City’s General Fund revenues and expenditures, and one-time development fees. Chapter 4 describes the assumptions for the fiscal analysis. Appendix A presents supporting fiscal assumption tables, and a list of project references appears in Appendix B. 258
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CHAPTER 2

PROJECT DESCRIPTION
This chapter presents the detailed development description for the proposed 2375 N Tustin Street Residential Project assuming full buildout of the project.

2.1 Development Description after Buildout
The proposed redevelopment project for the site is a new for-sale single family residential development, which will replace the existing vacant commercial, for a total of 71 units, including 3-bedroom units (Plans 1, 2,4 and 5) and 4-bedroom units (Plan 3), as shown in Figure 2-1.

As shown in Table 2-1, the project includes 10 Plan 1 units of size 2,008 square feet, 16 Plan 2 units of size 2,014 square feet, 13 Plan 4 of size 2,086 square feet, and 18 Plan 5 units of size 2,117 square feet adding up to a total of 57 3-bedroom units, and 14 Plan 3 4-bedroom units of size 2,057 square feet. Total residential population for the proposed project is estimated at 202 persons, which is calculated by applying a ratio of 2.84 persons per household (PPH) for the City of Orange obtained from the California Department of Finance (DOF) for 2025, as shown in Table 2-1.

Figure 2-1
Conceptual Site Plan
2375 N Tustin Street Residential Project Fiscal Impact Analysis City of Orange
2-1 Conceptual Site Plan, 2375 N Tustin Street Residential Project Source: Melia Homes, LLC
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Table 2-1
Development Description after Buildout
2375 N Tustin Street Residential Project Fiscal Impact Analysis City of Orange
(In Constant 2025 dollars)
2-1 Development Description after Buildout
Proposed Project
Residential
Buildout
A. GROSS ACRES 4.23
B. DEVELOPMENT
Residential
Units
Plan 1 - 3 BR (2,008 sf) 10
Plan 2 - 3 BR (2,014 sf) 16
Plan 3 - 4 BR (2,026 sf) 14
Plan 4 - 3 BR (2,086 sf) 13
Plan 5 - 3 BR (2,117 sf) 18
Total Units 71
Estimated Residential Population 1 (@2.84 PPH)
Plan 1 - 3 BR (2,008 sf) 28
Plan 2 - 3 BR (2,014 sf) 45
Plan 3 - 4 BR (2,026 sf) 40
Plan 4 - 3 BR (2,086 sf) 37
Plan 5 - 3 BR (2,117 sf) 51
Total Residential Population 202
Service Population 2 202
Average Price
C. ASSESSED VALUATION per Unit 3 Total Valuation
Plan 1 - 3 BR (2,008 sf) $1,139,000 $11,390,000
Plan 2 - 3 BR (2,014 sf) $1,154,000 $18,464,000
Plan 3 - 4 BR (2,026 sf) $1,154,000 $16,156,000
Plan 4 - 3 BR (2,086 sf) $1,169,000 $15,197,000
Plan 5 - 3 BR (2,117 sf) $1,169,000 $21,042,000
$82,249,000
$22,327,825
$59,921,175
$151,225
D. PROJECTED OFF-SITE SALES AND USE TAX TO CITY 7 $39,052

1. Based on city-wide household size obtained from California Department of Finance, 1/1/2025

2. Defined as 100 percent of the residential population, and 50% employment where applicable.

3. Average unit prices provided by Melia Homes are best estimates, including premiums and upgrades.

4. Project valuation estimated based on unit price provided by Melia Homes LLC.

5. Obtained from the Orange County Assessor parcel information system for the project site.

6. Property tax calculation discussed in Section 2.2.

7. Off-site sales and use tax from project houesehold spending discussed in Section 2.3.

Sources: Stanley R. Hoffman Associates, Inc.

Melia Homes LLC
California Department of Finance (DOF),E-5 City/County Population and Housing Estimates Orange County Assessor, Parcel Information System, ParcelQuest Projected Property Tax ( incl. PTVLF) to City General Fund 6 Total Project Valuation 4
Less Existing Valuation 5
Net New Valuation
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2.2 Assessed Valuation and Property Tax
Assessed Valuation
As shown in Table 2-1 and Table 2-2, total valuation for the Project is estimated at about $82.25 million, based on information provided by the project proponent, Melia Homes, LLC.

As shown in the following Table 2-3 the existing valuation of the project site is $22.33 million.

When this existing value is subtracted from estimated total valuation, net new valuation for the proposed redevelopment is estimated at about $59.92 million. While the total valuation at buildout of $82.25 million projects the basic 1 percent annual property tax related revenues to the General Fund, the net new valuation of $59.92 million is used to calculate the Property Tax In-Lieu of the Motor Vehicle License Fee (PTVLF) generated from the project at buildout.

Table 2-2
Assessed Valuation and Property Tax
2375 N Tustin Street Residential Project Fiscal Impact Analysis City of Orange
(In Constant 2025 dollars)
2-2 Assessed Valuation and Property Tax
Proposed Project
Residential
Category Buildout
A. ASSESSED VALUATION
Total Project Valuation 1 $82,249,000
B. PROJECTED PROPERTY TAX
Annual 1 Percent Property Tax Levy $822,490
(@ 1% of Valuation)
Annual General Fund Property Tax 2 $111,677
(@ 13.6% of 1 Percent Levy)
C. PROJECTED PROPERTY TAX IN LIEU VLF
Net New Annual Valuation for Property Tax In Lieu VLF $59,921,175 Projected Property Tax In Lieu VLF (@ $660 per $1,000,000 assessed valuation) 3 $39,548 D. TOTAL PROJECTED PROPERTY TAXES INCL. PTVLF $151,225

1. Valuation is provided by Melia Homes, LLC.

2. The total City's share of the basic one percent property tax levy is 13.6 percent, as shown in Appendix A.

3. PTVLF factor of $660 per million new valuation is calculated from historical data, as shown in Appendix A.

Sources: Stanley R. Hoffman Associates, Inc.

Melia Homes, LLC
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Table 2-3
Estimated Existing Assessed Valuation
2375 N Tustin Street Residential Project Fiscal Impact Analysis City of Orange
2-3 Estimated Existing Assessed Valuation
Projected Property Tax
The City General Fund will receive property tax at about 13.6 percent of the basic one percent property tax levy on assessed valuation for the Tax Rate Area 008-124, where the project parcel is located. As shown in Panel B of Table 2-2, for the proposed project, annual property tax to the City General Fund is projected at $111,677 at buildout.

Projected Property Tax In lieu of Vehicle License Fees (PTVLF) The City General Fund receives property tax in lieu of VLF (PTVLF) based on the increase in assessed valuation in the City. As shown in Appendix Table A-4, historical trend data indicates that the PTVLF in the City increases at about $660 per million dollars of assessed valuation (AV).

As shown in Panel C of Table 2-2, annual PTVLF after buildout of 2375 N Tustin Street Residential Project is projected at $39,548, based on the estimated net new project valuation of $59.92 million.

Taken together, the City share of the basic 1 percent property tax levy on the overall new valuation for the project and the PYVLF from net new valuation (increment) for the project, results in $151,225 in overall annually recurring property taxes accruing to the City General Fund, as shown in Panel D of Table 2-2.
2025 Assessed Valuation
Land Improvement Personal Real Estate Tax Rate
Parcel Number Value Value Property Exemptions Total 1 Area 372-642-36 2 16,597,293 5,730,532 0 0 $22,327,825 008-124 Total $16,597,293 $5,730,532 $0 $0 $22,327,825

1. The total assessed valuation was calculated by subtracting the total real estate exemptions from the sum of the land value, improvement value, and personal property.

2. The latest assessment data for the parcel site in the Orange County Assessor Parcel information system is listed under the previous parcel number prior to a recent tract map revision with minor changes to internal lot lines.

Sources: Stanley R. Hoffman Associates, Inc.

Orange County, Auditor-Controller/Treasure/Tax Collector, 2025 Roll Values 262
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2.3 Projected Off-Site Retail Sales and Use Tax
The City General Fund will also receive retail sales and use tax generated by the off-site spending activities associated with project households for an estimated total of $32,362, as shown in Table 2-4. The total sales and use tax accruing to the City General Fund are calculated from an estimated total of $2.73 million in taxable sales in off-site spending of project households at a 50 percent capture rate within the City. This generates $27,264 in annual retail sales tax at 1 percent of taxable sales (Bradley-Burns sales tax), which when factored for use tax factor for the City at

18.7 percent of sales tax results in total annual sales and use tax of $32,362 accruing to the City General Fund. Household expenditures are based on an estimated average household income of $240,000 for single-family ownership households in Orange County residing in units constructed since 2020, obtained from the American Community Survey, 2019-2023 5-year estimates, as shown in Appendix Table A-5.

Over and above the Bradley-Burns 1 percent sales and use tax accruing to the City’s General Fund, taxable sales associated with project household spending within the City will also result in revenues accruing to the City’s special funds, including the Prop 172 Public Safety ½ cent sales tax and the Measure M2 ½ cent sales tax, as discussed in Chapter 3.

Table 2-4
Off-Site Taxable Retail Sales Tax
2375 N Tustin Street Residential Project Fiscal Impact Analysis City of Orange
2-4 Off-Site Taxable Retail Sales Tax
Proposed Project
Residential
Category Buildout
Annual Off-Site Residential Retail Taxable Sales
Estimated Average Household Income of Project Households 1 $240,000 Total Project Household Income (71 Units) $17,040,000
Retail Taxable Sales (@ 32% of total household income) 2 $5,452,800 Projected Off-Site Retail Taxable Sales Captured in City at 50% Share $2,726,400 Total Annual On-Site and Off-Site Taxable Sales
Sales Tax (@ 1% of taxable sales) $27,264
Use Tax (@ 18.7% of sales tax) 3 5,098
Projected Residential Sales and Use Tax Captured in Orange $32,362

1. Project average household income estimated from data obtained from the American Community Survey for ownership households residing in 3 and 4 bedroom single-family units built after the year 2020 in Orange County, as shown in Appendix A.

2. Residential taxable purchases are estimated at 32 percent of household income, based on Consumer Expenditure Survey data. The fiscal analysis assumes the City will capture 50 percent of the taxable retail purchases from new households.

3. The calculation of the use tax factor is included in Appendix A.

Sources: Stanley R. Hoffman Associates, Inc.

American Community Survey, 2023 5-yr Estimates, Public Use Microdata Sample (PUMS) Bureau of Labor Statistics, Consumer Expenditure Survey 263
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2.4 Major One-Time Development Impact Fees
Development fees are one-time fees paid by the developer to offset the additional off-site public capital costs of new development, and are estimated based on the City of Orange, Development Fees, Updated July 1, 2025. Processing fees, such as project permits and plan check fees that are charged to offset public processing costs are not estimated in this analysis.

As shown in Table 2-5, the total major one-time fees collected from the Project towards City public capital expenditures, including parks, library, fire, police and transportation facilities are projected at $1.54 million. An additional $666 thousand are collected for school facilities, combining to a total of $2.21 million in City fees. Including $481 thousand charged by the Orange County Sanitation District, total one-time fees from the project are projected at $2.69 million.

These one-time fees are provided here for information only and subject to final evaluations and agreement between the project proponent and the City.

Table 2-5
Summary of Estimated One-Time City Development Impact Fees 2375 N Tustin Street Residential Project Fiscal Impact Analysis City of Orange
(In Constant 2025 dollars)
2-5 Summary of Estimated One-Time City Development Impact Fees

FEE CATEGORIES
Estimated
Amount
City of Orange, One-time Fees
Park Dedication and In Lieu Fees (Quimby) $16,615.69 per DU 71 DUs $1,179,714 Library Facilities DIF $1,370.44 per DU 71 DUs $97,301
Fire Protection Facility Fee $1,467.00 per DU 71 DUs $104,157 Police Facility Fee $727.04 per DU 71 DUs $51,620
Transportation System Improvement Program (TSIP) $1,498.78 per DU 71 DUs $106,413 $1,539,205
School Development Fee $4.57 per SF 145,892 SF $666,726 $2,205,932
County, One-time Fees
Orange County Sanitation District Fee
4 Bedroom Units $7,770.00 per DU 14 DUs $108,780
3 Bedroom Units $6,529.00 per DU 57 DUs $372,153
$480,933
$480,933
$2,686,865
Sources: Stanley R. Hoffman Associates, Inc.

Community Development Department, Building Division, 2025 Total One-Time Fees
Basis
Proposed
Development
City One-Time Fees less School Subtotal
OC Sanitation District Subtotal
County One-Time Fees Total
City Collected One-Time Fees Total
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CHAPTER 3

FISCAL IMPACTS
This chapter presents the fiscal impact analysis details for the 2375 N Tustin Street Residential Project on the City General Fund after buildout for operations and maintenance. Fiscal impacts are shown In Constant 2025 dollars with no adjustment for possible future inflation. The fiscal assumptions for the analysis are presented in Chapter 4.

As shown in summary Table 3-1, a recurring annual surplus of $92,602 is projected to the City General Fund from the proposed residential project at a revenue-to-cost ratio of 1.84. Major onetime fees are estimated at about $2.69 million for the proposed project.

Table 3-1
Summary of Projected Annual Fiscal Impacts after Buildout 2375 N Tustin Street Residential Project Fiscal Impact Analysis City of Orange
(In Constant 2025 dollars)
3-1 Summary of Projected Fiscal Impacts after Buildout

3.1 Proposed Residential General Fund Impacts
Detailed projected annually recurring fiscal impacts to the City General Fund after buildout of the project are included in Table 3-2. Based on projected annually recurring revenues of $203,372 and projected annually recurring costs of $110,770, an annually recurring surplus of $92,602 is projected to the City General Fund after buildout.

Proposed Project
Residential
Category Buildout
A. GENERAL FUND IMPACTS (FUND 100)
Annual Recurring Revenues $203,372
Annual Recurring Costs $110,770
Annual Recurring Surplus $92,602
Revenue/Cost Ratio 1.84
B. PROJECTED SPECIAL FUND REVENUES
Fund 270: Gas Tax $6,135
Fund 120: Proposition 172 - Public Safety - 1/2 Cent Sales Tax $1,013 Fund 263: Measure M2 - Transportation - 1/2 Cent Sales Tax $2,842 C. ESTIMATED MAJOR ONE-TIME FEES $2,686,865
Sources: Stanley R. Hoffman Associates, Inc.
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Table 3-2
Detailed General Fund Annual Recurring Impacts: Proposed Project 2375 N Tustin Street Residential Project Fiscal Impact Analysis City of Orange
(In Constant 2025 dollars)
3-2 General Fund Detailed Projected Recurring Fiscal Impacts Proposed Project
Residential Percent
City of Orange General Fund (Fund 100) Buildout of Buildout Recurring Revenues 1,3
Property tax (General Fund) $111,677 54.9%
Property Transfer Tax 1,357 0.7%
Off-site retail sales and use tax 32,362 15.9%
In lieu property tax (VLF) 39,548 19.4%
Franchise Fees: Gas and Electric 2,093 1.0%
Franchise Fees: Cable 1,424 0.7%
Franchise Fees: Other 174 0.1%
Fines and forfeitures 2,731 1.3%
Recreation and Current Services 5,044 2.5%
Other revenues 287 0.1%
Transfers in 4,052 2.0%
Interest on invested revenues 2,624 1.3%
Total Projected Revenues $203,372 100.0%
Recurring Costs 2,3
Police Protection $47,060 42.5%
Fire Protection $30,836 27.8%
Animal Control Services (County Contract) 2,007 1.8%
Library 5,902 5.3%
Public Works 2,975 2.7%
Community Development 922 0.8%
Citywide Community Services - Rec, Park, Human 10,482 9.5% General Government (Overhead) 5,310 4.8%
Subtotal Recurring Costs $105,495 95.2%
Contingency/reserves (@ 5% of recurring costs) $5,275 4.8% Total Recurring Costs $110,770 100.0%
Annual Net Recurring Surplus $92,602
Revenue/Cost Ratio 1.84
PROJECTED SPECIAL FUND REVENUES 4
Fund 270: Gas Tax - Street Maintenance $6,135
Fund 120: Proposition 172 - Public Safety - 1/2 Cent Sales Tax $1,013 Fund 263: Measure M2 - Transportation - 1/2 Cent Sales Tax $2,842

1. Recurring project-related General Fund revenues are based on revenue projection factors shown in Table 4-2.

2. Recurring project-related General Fund costs are based on expenditure projection factors shown in Table 4-3.

3. Revenue and cost factors are applied to project development quantities shown in Table 2.1.

4. Special fund revenues are not part of the General Fund, and have been projected here based on factors shown in Table 4-2. These funds are earmarked for specific uses.

Source: Stanley R. Hoffman Associates, Inc.
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Proposed Project: Major Recurring City General Fund Revenues and Costs Projected Recurring Revenues. As shown in Table 3-2, the major recurring revenues for the General Fund after buildout of the proposed 2375 N Tustin Street Residential Project are property tax, property tax in lieu of vehicle license fees (PTVLF), and total retail sales and use tax. These three revenues represent about 90 percent of total recurring revenues after project buildout.

Revenue factors are discussed in Table 4-2.

Projected Recurring Costs. As shown in Table 3-2, major City General Fund recurring costs after buildout are Police and Fire services. These two recurring costs represent about 70 percent of all recurring costs after buildout. Other major cost categories include Community Services and Library, which taken together constitute a share of about 15 percent of total General Fund expenditures. Cost factors are reported in Table 4-3.

3.2 Proposed Residential Other City Funds Impacts
Also projected are revenues to certain special funds that are associated directly with project population and project off-site taxable sales. These special fund revenues are over and above the General Fund revenues and are dedicated toward specific earmarked uses as described below.

Gas Tax Revenues (Fund 270). As shown in Table 3-2, projected Gas Tax revenues associated with population growth from the development is estimated at $6,135. These funds are dedicated toward street and roadways maintenance and projects identified by the City.

Proposition 172 (Fund 120) – Public Protection 1/2 Cent Sales Tax. As shown in Table 3-2, projected Prop 172 Public Projection revenues associated with off-site taxable sales growth from project households is estimated at $1,013. These funds are dedicated toward public safety, including police, fire and emergency needs.

Measure M2 (Fund 263) – Transportation 1/2 Cent Sales Tax. As shown in Table 3-2, projected Measure M2 revenues associated with off-site taxable sales growth from project households is estimated at $2,842. M2 funds are earmarked for City transportation-related projects in coordination with the Orange County Transportation Authority (OCTA).

3.3 No-Project Scenario: Major Revenues Analysis
A ‘No Project’ scenario is evaluated for major City revenue categoriesfor purposes of comparison against the proposed residential project, including property tax, PTVLF, sales and use tax, and business license tax. The ‘No project’ scenario assumes continued use of the existing vacant building with potential new tenants for the estimated 40,000 square feet of commercial space.

This comparison is strictly a public revenue analysis and not a comprehensive fiscal impact analysis, which would also include public costs.
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As noted, the building was previously occupied by Best Buy, which failed at this location and is not a viable option any longer, according to the property owner of 2375 N Tustin Street.

Furthermore, it was indicated that interest from alternative tenants for the current property is minimal, despite persistent attempts to identify and recruit, due to its location and lack of streetfront access on N Tustin Street. Tenants likely to occupy this space, with a medium level of confidence include sports and fitness uses, and seasonal or deep discount retail stores (dollar stores). To fully lease out the available vacant space, a combination of these uses might be necessary. Major revenues to the City General Fund generated for each operation (business) is summarized in Table 3-3. Details are provided in Appendix Table A-7. The assumptions made here represent best case scenarios, and likely outcomes might be significantly lower.

As shown in Table 3-3, an evaluation of major City revenue categories indicates that the limited viable commercial uses identified for the vacant property generate between $44,300 and $61,100 to City General Fund revenues.

Thisis significantly lower compared against $184,000 from the proposed Melia Homes residential project for the same revenue categories, shown previously in Table 3-2. In fact, even after backing out General Fund costs, the net fiscal surplus for the proposed project ($92,602) is higher compared against the gross revenues generated by the evaluated ‘No-Project’ commercial uses.

Table 3-3
Comparative Major Revenues from Hypothetical Uses: No Project Scenario 2375 N Tustin Street Residential Project Fiscal Impact Analysis City of Orange
(In Constant 2025 dollars)
3-3 Comparison of Major Revenues: No Project Scenario
Gyms Discount Stores
Seasonal Stores
(Annualized)
Property Reuse Assumption Renovation Minimal Change Minimal Change Floor Size (sf) Assumption 40,000 10,000 10,000
New Total Assesed Valuation $27,127,825 $22,577,825 $22,427,825 Operations
Gross Revenues $3,000,000 $2,500,000 $2,000,000
Taxable Retail Sales $300,000 $2,500,000 $2,000,000
Number of Employees 10 22 17
Major Public Revenues
Property Tax City Share: 13.6% of 1% $36,894 $30,706 $30,502 Property Tax In-Lieu of VLF $3,168 $165 $66
Sales and Use Tax Total $3,558 $29,650 $23,720
Business License Fees $715 $615 $615
TOTAL ESTIMATED MAJOR REVENUES $44,335 $61,136 $54,903
Source: Stanley R. Hoffman Associates, Inc.
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CHAPTER 4

CITY OF ORANGE FISCAL ASSUMPTIONS
This chapter presents the revenue and cost assumptions for the fiscal analysis of the proposed 2375 N Tustin Street Residential Project to Orange. Fiscal impacts are projected for the City’s operating General Fund. All projections are In Constant 2025 dollars with no adjustment for future inflation.

The general City demographic and economic assumptions used for calculating fiscal factors are first presented. The assumptions for projecting recurring revenues are then presented followed by the assumptions for projecting recurring costs. The City’s revenues and costs as presented in the City of Orange, Fiscal Year 2025/26 Adopted Budget and additional budget details provided by City staff are the sources for calculating fiscal factors.

4.1 City General Assumptions
Fiscal impacts that are not based on valuation and taxable sales are generally projected based on a per capita, per employee, or per service population basis at City average rates. Some fiscal impacts are projected based on other factors, such as per developed acre. General fund revenue and cost factors are estimated by dividing the Fiscal Year (FY) 2025/26 Adopted budget categories by the City’s resident population, employment, total service population or developed acre, as appropriate. Table 4-1 provides the City’s general assumptions for this fiscal analysis.

Population
City of Orange’s total population of 139,724 is based on the California Department of Finance (DOF) estimate as of January 1, 2025. The City population estimate is used for developing factors that project certain revenues and costs on a per capita basis.

Employment
The City employment estimate of 128,889 for the year 2025 represents an interpolation of the years 2019 and 2035 forecasts for Orange City from the Southern California Association of Governments (SCAG) Adopted 2024 Regional Transportation Plan Growth Forecast. As shown in Appendix Table A-1 according to the latest Bureau of Census Longitudinal Employer-Household Survey for 2022, about 93 percent of workers employed in the City (or 119,697 of the 2025 jobs) commute from outside the City. A share of 50 percent of this non-resident employment is used for estimating the City’s service population for certain revenues and costs, as explained next. 269
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Table 4-1
City Population, Housing and Employment Assumptions, 2025 2375 N Tustin Street Residential Project Fiscal Impact Analysis City of Orange
4-1 City Population, Housing and Employment Assumptions Assumption Description
2025 Population and Housing 1
132,804 Household Population
6,920 Group Quarters Population
139,724 Total Population
48,301 Total Housing Units
46,745 Occupied Housing Units (Households)

2.84 Persons per Household
2025 Employment 2
128,889 Estimated Total Workers Employed in City
times
93% Estimated Share of Workers from Outside the City 3
equals
119,697 Estimated Workers from Outside the City 3
2025 Service Population
139,724 Total Population
plus
59,849 50% Share of Workers from Outside City 4
equals
199,573 Estimated Total Service Population
City Developed Acres
10,315 Estimated total City developed acres 5

1. Population and housing estimates are from the California Department of Finance (DOF) for January 1, 2025.

2. The total employment estimate is for 2025 based on an interpolation of the 2019 and 2035 estimates from the Southern California Association of Governments (SCAG), RTP Adopted 2024 Growth Forecast.

3. To avoid double-counting of individuals, the 2025 total estimated City employment is factored by 93 percent based on the Census Bureau's LEHD Survey estimates of the share of employed workers who live outside the City.

4. Reflects the reduced impact on City services from workers due to their less than around the clock presence in the City.

5. Estimated developed acres in the City are provided by City GIS staff.

Sources: Stanley R. Hoffman Associates, Inc.

State of California, Department of Finance, E-5 Population and Housing Estimates for Cities, Counties and the State, January 1, 2020-2025, Sacramento, California, May 2025.

Southern California Association of Governments (SCAG), Adopted Regional Transportation Plan (RTP), 2024 U.S. Census Bureau, Longitudinal Employer-Household Dynamics (LEHD) Program, OnTheMap 2022 City of Orange, Community Development Department
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Service Population
Fiscal factors that are impacted by population and employment are estimated by allocating total budgeted revenues or costs to the estimated service population. Service population includes the City’s resident population (139,724) plus 50 percent share of the estimated employment commuting-in to the City (59,849). As shown in Table 4-1, the service population for the City is estimated at 199,573, which is used for certain revenue and cost categories, as discussed in the following sections.

Estimated Total City Developed Acres
Some costs, such as public works and community development, are projected on a per-developed acre basis. As shown in Table 4-1, developed acres within the City are estimated at 10,315 acres, as provided by City Geographic Information System staff.

4.2 City Revenue Assumptions
City General Fund
The General Fund revenue factors for projecting annually recurring revenues in the fiscal analysis are summarized in Table 4-2. These revenue factors are based on the City’s FY 2025/26 budget revenues detailed in Appendix Table A-2 and the City’s population, employment, housing unit, and service population estimates that are presented in Table 4-1.

As shown in Table 4-2, projected General Fund revenues include property tax; property transfer tax; property tax in lieu of vehicle license fees (VLF); sales and use tax; franchise fees; fines and forfeitures; interest on investments; charges for services; other revenue; transfersto the General Fund; and recreation and other fees and charges. Because there is no commercial development being proposed for the new project, revenues generated only by employment/business growth are not projected, such as the business license tax.

Property Tax. Property tax revenues are projected based on the City’s share of the one percent property tax levy on the estimated assessed valuation for the 2375 N Tustin Street Residential Project proposed development. The current allocation rates of the one percent property tax for tax rate area (TRA) 008-124 in which the project is located are presented in Appendix Table A-3.

The City’s total allocation of the one percent property tax levy is 13.6 percent. 271
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Table 4-2
Recurring General Fund Revenue Factors
2375 N Tustin Street Residential Project Fiscal Impact Analysis City of Orange
(In Constant 2025 dollars)
4-2 Recurring General Fund Revenue Factors
Fiscal Year
2025-26
Adopted
Revenue Source Budget Projection Basis 1
GENERAL FUND (Fund 100) 2
Tax Revenue
General Fund Property Tax 3 $39,648,536 Case Study: Project Valuation 13.58% City general share of 1% levy Property Transfer Tax $552,567 Property Turnover and 3.0% Residential turnover rate Valuation Assumptions $0.55 per $1,000 assessed valuation Property Tax In Lieu Vehicle License Fees 3 $19,016,506 Case Study $660 per $1,000,000 assessed valuation Sales and Use Tax 4 $50,113,960 Project HH Off-Site Taxable Exp. 1% of taxable sales Use Tax Factor Use Tax as Percent
of Sales Tax 18.7% of sales tax
Franchise Fees:

Gas and Electric $2,067,500 Service Population = 199,573 $10.36 per service population Cable $968,500 Housing Units = 48,301 $20.05 per unit
Other $171,364 Service Population = 199,573 $0.86 per service population Fines and Forfeitures $2,697,576 Service Population = 199,573 $13.52 per service population Interest on Investments $1,607,697 Percent of Projected Recurring 1.31% of projected General Fund recurring Revenues of $123,012,395 non-interest revenues
Charges for Current Services
Recreation and Other Current Services 5 $3,489,059 Population = 139,724 $24.97 per capita Other Revenue $282,847 Service Population = 199,573 $1.42 per service population Transfers In $4,003,980 Service Population = 199,573 $20.06 per service population General Fund Total (Projected) $124,620,092
SPECIAL FUNDS 6
Gas Tax Fund (Fund 270) $4,243,665 Population = 139,724 $30.37 per capita Proposition 172 - 1/2 Cent Sales Tax (Fund 120) $1,568,381 $31.30 per $1,000 sales and use tax Measure M2 - 1/2 Cent Sales Tax (Fund 263) $4,400,436 $87.81 per $1,000 sales and use tax

1. For fiscal factors that are based on population and employment, an estimated service population factor is applied, which represents the total population plus estimated employment that commutes into the City.

2. Detailed General Fund revenues are included in the Appendix section.

3. Property tax and property tax in lieu of vehicle license fee (PTVLF) based on project-specific valuation assumptions, as discussed in Chapter 2.

4. Sales and use tax based on specific project-based estimations on household income and spending, as discussed in Chapter 2.

5. Recreation and Other current service changes are for background City resident services,and do not include development-related one time fees and charges, as shown Appendix Table A-2.

6. Special fund factors are based on total gross revenue amounts by fund reported in the City budget, and do not net out any fund specific activity costs.

Sources: Stanley R. Hoffman Associates, Inc.

City of Orange, Fiscal Year 2025/26 Adopted Budget
State of California, Department of Finance, E-5 Population and Housing Estimates for Cities, Counties and the State, January 1, 2020-2025, Sacramento, California, May 2025.

Southern California Association of Governments (SCAG), Adopted Regional Transportation Plan (RTP), 2024.

Projection Factor 1
Per $1,000 of Sales and Use Tax
Per $1,000 of Sales and Use Tax
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Property Tax In Lieu Vehicle License Fees (PTVLF). Cities and counties began receiving additional property tax revenue to replace vehicle license fee (PTVLF) revenue that was lowered when the state reduced the vehicle license tax in 2004. This property tax in lieu of VLF is projected to grow with the change in the citywide gross assessed valuation (AV) of taxable property from the prior year. Property tax in lieu of VLF revenue is allocated in addition to other property tax apportionments. Property tax in lieu of VLF in the City is projected to increase at an average of $660 per million dollars of AV (see Appendix Table A-4). This factor is based on the relationship between City AV and the PTVLF received by the City over the last 5 years.

Sales and Use Tax. As part of the total sales tax levied by the State, all cities and counties in the State generally receive a basic one percent (1.0 percent) Bradley-Burns sales tax and have the option to levy additional sales taxes under certain circumstances. In addition to sales tax revenue, the City receives revenues from use tax, which is levied on shipments into the state and on construction materials for new residential and non-residential development not allocated to a situs location. Use tax is allocated by the California Department of Taxation and Fee Administration (CDTFA) to counties and cities based on each jurisdiction's proportion of countywide and statewide direct (point-of-sales) taxable sales.

Use tax revenues to the City of Orange are estimated at an additional 18.7 percent of point-ofsale sales tax, as shown in Appendix Table A-6. Calendar Year 2024 sales tax data obtained from the CDTFA estimates that $9.09 million of the total sales and use tax revenues were made from levies designated as use tax and the remaining $48.57 million of the sales and use tax was pointof-sale sales tax. Therefore, use tax revenues to the City of Orange are estimated at an additional

18.7 percent of point-of-sale sales tax. Sales and use tax are projected for off-site retail spending of project households.

Franchise Fees. The City receives franchise fees from gas and electric; cable and other services.

Gas and Electric Franchise Fees. As shown in Table 4-2, gas and electric franchise fees are projected at $10.36 per service population based on the City budget revenues of $2,067,500 and the City service population estimate of 199,573.

Cable Franchise Fees. Projected at $20.05 per unit based on $968,500 of revenues and 48,301 residential units in the City.

Other Franchise Fees. Projected at $0.86 per unit based on $171,364 of revenues and 199,573 service population in the City. These are shown in the City budget to include waste remediation activities.
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Fines and Forfeitures. Fines and forfeitures are projected at $13.52 per service population, based on total revenues of $2,697,576 and the City service population estimate of 199,573 as shown in Table 4-2. Revenues in this category include vehicle code fines, parking citations, vehicle release fees, citation fees and other general ordinance fines.

Interest on Investments. These revenues are projected at 1.31 percent of projected recurring revenues based on budget interest on investments of $1,607,697 as a share of projected recurring non-interest revenues of $123.01 million
Charges for Current Services. This category includes charges and fees for a variety of background population-based services such as charges for recreation, processing fees etc. which increase based on population growth. These do not include one-time processing fees associated with development activities. These revenues are estimated at $24.97 per capita resident.

Other Revenue. As shown in Table 4-2, these revenues are projected at $1.42 per service population based on contributions, reimbursement and other revenues of $282,847 and the City’s estimated service population of 199,573.

Transfers In. Transfers to the City General Fund from all other funds, excluding General Obligation funds, are projected at $20.06 per service population based on City budget revenues of $4.0 million and the City’s estimated service population estimate of 199,573.

Special Fund Revenues
Special funds are also projected here to identify revenue impacts over and above the General Fund, which however might be earmarked for specific uses. Special fund factors here are based on total gross revenue amounts by fund reported in the City budget, and do not net out any fund specific activity costs.

State Gasoline Tax. State Gasoline tax accrues to the Gas Tax Fund based on population growth.

Gas tax revenue factor of $30.37 per capita is based on $4.24 million for FY 2025/26 and city population of 139,274. These revenues are earmarked for street and roadways projects.

Proposition 172 (Half Cent Sales Tax). These revenues are projected at $31.30 per $1,000 of sales and use tax based on City estimated FY 2025/26 Proposition 172 revenues of $1.57 million and the City’s total sales and use tax estimate of $50.11 million, and are earmarked for public safety needs including police, fire and emergency.

Measure M2 (Half Cent Sales Tax). As shown in Table 4-2, these revenues are projected at $87.81 per $1,000 of sales and use tax City estimated FY 2025/26 Proposition 172 revenues of $1,568,381 and the City’s total sales and use tax estimate of $50.11 million earmarked for transportation projects.
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4.3 City Cost Assumptions
The cost factors that are used in preparing the fiscal analysis for the 2375 N Tustin Street Residential Project are presented in Table 4-3. These factors are based on the adopted expenditures in the City’s FY 2025-26 Adopted Budget and the City’s population, service population and developed acres estimates that are presented in Table 4-1.

General Fund
Projected General Fund expenditures include general government, or overhead functions, and the following non-general government services of police and fire services, library, public works, community development, and community and recreation services. Animal services, while included in the City budget under general government as a contract with Orange County Animal Care, is treated as non-general departmental cost item. Also shown are contingency costs built into the overall cost projections, based on prior studies. In discussion with the City, a marginal rate of 75 percent has been applied across all cost categories, except for General Government, which is projected at a 60 percent marginal rate.

Table 4-3
General Fund Recurring Cost Factors
2375 N Tustin Street Residential Project Fiscal Impact Analysis City of Orange
(In Constant 2025 dollars)
4-3 General Fund Recurring Cost Factors
FY 2025/26 Adopted Budget
Cost Category Total Adjusted
A. GENERAL FUND (Fund 100)
General Government (less Animal Contract) 2 $12,237,400 $7,342,440 5.3% of direct department costs, Police Protection $61,993,891 $61,993,891 Service Population = 199,573 $232.97 per service population Fire Protection $40,621,032 $40,621,032 Service Population = 199,573 $152.66 per service population Animal Control Services (County Contract) $1,850,840 $1,850,840 Population = 139,724 $9.94 per capita Library $5,443,573 $5,443,573 Population = 139,724 $29.22 per capita Public Works 3 $10,423,942 $9,674,486 Developed Acres = 10,315 $703.40 per developed acre Community Development 3 $6,396,669 $2,997,669 Developed Acres = 10,315 $217.95 per developed acre Citywide Community Services - Rec, Park, Human 3 $10,318,531 $9,666,872 Population = 139,724 $51.89 per capita Contingency n/a n/a Case Study 5.0% of total recurring costs

1. For fiscal factors that are based on population and employment, an estimated service population factor is applied, which represents the total population plus 50% share of estimated employment that commutes into the City. General Government Costs are assumed at a 60% marginal rate, while all other costs are assumed at a 75% marginal rate.

2. General government includes contract with the Orange County Animal Care services, which has been netted out for the purposes of General Fund overhead operational costs.

3. Public Works, Community Development and Community Services overall costs have been adjusted to exclude one-time revenues, such license,permits and processing fees associated with development activity, as shown in Appendix A.

Sources: Stanley R. Hoffman Associates, Inc.

Percent of General Fund Costs
Citywide Projection Basis 1 Cost Factor 1
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Table 4-4
Calculation of City General Government Overhead Rate
2375 N Tustin Street Residential Project Fiscal Impact Analysis City of Orange
(In Constant 2025 dollars)
4-4 Calculation of City General Government Overhead Rate Fiscal Year 2025/26 Adopted Budget
General Fund Expenditures Total
General
Government
Non-General
Government
General Government
Non Departmental (less Animal Control County Contract) $497,991 $497,991 City Council 74,196 74,196
City Manager 1,792,043 1,792,043
City Attorney 1,768,050 1,768,050
City Clerk 1,031,892 1,031,892
City Treasurer 94,758 94,758
Finance Department 4,146,107 4,146,107
Human Resources $2,832,364 $2,832,364
Non-General Government
Animal Control County Contract $1,850,840 $1,850,840
Library 5,443,573 5,443,573
Fire 40,621,032 40,621,032
Police $61,993,891 $61,993,891
Public Works:

Public Works Adminitration $1,925,919 $1,925,919
Engineering 1,409,832 1,409,832
Development Services 753,813 753,813
Street Maintenance 1,243,479 1,243,479
Refuse and Sanitation Services 129,085 129,085
Tree Maintenance 916,570 916,570
Facility Maintenance 1,449,132 1,449,132
Transportation Planning 866,132 866,132
Traffic Operations 236,705 236,705
Roadway Maintenance 125,400 125,400
Transportation Services 1,367,875 1,367,875
Public Works Subtotal $10,423,942 $10,423,942
Community Development:

Planning and Development Administration $2,032,867 $2,032,867 Advance Planning 685,753 685,753
Current Planning 938,170 938,170
Building Inspection 641,106 641,106
Code Enforcement 971,943 971,943
Permit Services 1,126,831 1,126,831
Community Development Subtotal $6,396,669 $6,396,669
Community Services:

Community Services Administration $2,004,131 $2,004,131 Leisure Services 2,060,482 2,060,482
Recreation Athletics 552,494 552,494
Environmental Services 5,354,027 5,354,027
Senior Services 347,397 347,397
Community Services Subtotal 10,318,531 10,318,531
Other - Redevelopment and Water Maintenance 319,006 319,006 GRAND TOTAL GENERAL FUND $149,604,884 $12,237,400 $137,367,484 Current General Government Overhead Rate
General Government Expenditures $12,237,400
divided by
Direct General Fund Expenditures $137,367,484
equals
Current General Government Overhead Rate 8.9%
times
Marginal Factor 60.0%
equals
Overhead Rate at 60 Percent Marginal Rate 5.3%
Sources: Stanley R. Hoffman Associates, Inc.

City of Orange, Fiscal Year 2025/26 Adopted Budget
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General Government. General government costs include administration and support of nongeneral government departmental line costs such as police, fire, library, public works etc. These costs are usually viewed as citywide overhead and are projected using an overhead rate applied to departmental line costs.

As shown in Table 4-4, General Government includes Non-Departmental, City Council, City Management, City Attorney, City Clerk, City Finance, City Treasurer, and Human Resources. As mentioned, while Animal Services contract with the OC Animal Care is shown under General Government in the City budget, this is not an overhead function as described above and is therefore netted out for the cost overhead calculation.

As also shown in Table 4-4, FY 2025/26 general government adjusted costs (net Animal Services contract) of $12.24 million represent about 8.9 percent of direct line costs of $137.37 million.

However, overhead costs are not assumed to increase on a one-to-one basis for new development. Based on previous fiscal analyses, general government costs are projected at a marginal rate of 60 percent, or at 5.3 percent of direct costs.

Further, all other General Fund cost factors are discussed below at a 75 percent marginal rate:

Police Protection. As shown in Table 4-3, Police costs are projected based on the citywide cost factor of $232.97 per service population, based on the adopted budget expenditures.

Fire Protection. As shown in Table 4-3, fire costs are projected based on the citywide cost factor of $152.66 per service population, based on the adopted budget expenditures.

Animal Control and Services Contract. These services are projected on city resident population basis at $9.94 per capita, based on the Orange County contract amount and city population, as shown in Table 4-3.

Library. As shown in Table 4-3, library costs are projected on a city resident population basis at a citywide cost factor of $29.22 per capita, based on the adopted budget expenditures Public Works. Public Works includes several divisions including Engineering, Development Services, Transportation Planning and Engineering, Traffic Operation, Street, Tree and Facilities Maintenance, and Public Refuse and Sanitation Services. The cost factor for Public Works has been developed on a per developed acre basis based on net Public Works costs (less one-time fees, permits and revenues) and the amount of developed land in the City of 10,315 acres. Net Public Work cost calculations adjust the total Public Works costs to back out one-time revenues, as shown in Appendix Table A-7, which are specific to one-time ad-hoc development activities in the City and are not annually recurring citywide activities. Net Public Works costs are estimated at $703.40 per developed acre, at a 75 percent marginal rate. 277
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Community Development. Community Development includes several divisions including Planning, Building Safety Inspection, Code Enforcement and Permit Services. The cost factor for Community Development, as shown in Table 4-3. has been developed on a per developed acre basis based on net Community Development costs (less one-time fees, permits and revenues) and the amount of developed land in the City of 10,315 acres. Net Community Development cost calculations adjust the total costs to back out one-time revenues, as shown in Appendix Table A7, which are specific to one-time ad-hoc development activities in the City and are not annually recurring citywide activities. Net Community Development costs are estimated at $217.95 per developed acre, at a 75 percent marginal rate.

Community Services. Community Services includes several divisions including Leisure Services, Recreational and Athletics, Environmental Services (incl. parks and rec facilities maintenance), and Senior Services. The cost factor for Community Services, as shown in Table 4-3, has been developed on a per capita basis based on net Community Services costs (less one-time fees, permits and revenues) and the resident City population of 139,724. Net Community Services cost calculations adjust the total costs to back out one-time revenues, as shown in Appendix Table A7, which are specific to one-time ad-hoc events in the City and are not annually recurring citywide activities. Net Community Services costs are estimated at $51.89 per capita, at a 75 percent marginal rate.

Contingency Costs. City General Fund contingency costs of 5 percent are applied to projected costs to account for budget and economic uncertainties based on experience from prior fiscal studies.
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APPENDIX A

SUPPORTING FISCAL TABLES
Table A-1
Inflow-Outflow Patterns of Workers Employed in the City City of Orange
A-1 Inflow-Outflow Patterns of Workers Employed in the City Category Count 1 Share
Selection Area Labor Market Size (Primary Jobs)
Employed in the Selection Area 105,164 100%
Living in the Selection Area 59,621 97%
Net Job Inflow (+) or Outflow (-) 45,543
In-Area Employment Efficiency (Primary Jobs)
Employed in the Selection Area 105,164 100%
Employed and Living in the Selection Area 7,500 7%
Employed in the Selection Area but Living Outside 97,664 93%

1. Total employment (workers) based on the survey count does not represent the total employment estimated for the City of Orange, and is used to derive inflow-outflow relationships.

Sources: Stanley R. Hoffman Associates, Inc.

U.S. Census Bureau, OnTheMap Application and Longitudinal Employer-Household Dynamics (LEHD) Origin-Destination Employment Statistics, Orange, California, 2022 2022
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Table A-2 (page 1 of 2)
General Fund Recurring Revenues
2375 N Tustin Street Residential Project Fiscal Impact Analysis City of Orange
(In Constant 2025 dollars)
A-2 General Fund Recurring Revenues
Table Continued…
Fiscal Year One-Time Revenues Revenues
2025/26 Development Not Projected Projected
Adopted Processing in Fiscal in Fiscal
Revenue Category Budget Revenue 1 Analysis 2 Analysis
Taxes and Fees
Property Taxes $39,648,536 $0 $0 $39,648,536
Property Transfer Tax 552,567 0 0 552,567
Property Tax In-Lieu of Vehicle License Fees (VLF) 19,016,506 0 0 19,016,506 Sales and Use Tax 50,113,960 0 0 50,113,960
Proposition 172 - Half Cent Sales Tax
Transient Occupancy Tax 6,334,000 0 6,334,000 0
Franchise- ATT Cable 93,400 0 0 93,400
Franchise-Other 171,364 0 0 171,364
Franchise - Southern California Edison 1,329,200 0 0 1,329,200 Franchise - The Gas Company 738,300 0 0 738,300
Franchise - Time Warner Cable 875,100 0 0 875,100
Subtotal Taxes and Fees 118,872,933 0 6,334,000 112,538,933 Licenses and Permits
Business Licenses and Renewal $4,095,000 $0 $4,095,000 $0 Building Permits + SMIP 1,520,000 1,520,000 0 0
Bldg -Electr, Grade, Mech, Plumb & Swr Cnctn Permits 1,038,000 1,038,000 0 0 Plan Check Permits 370,000 370,000 0 0
Annual Fire Permit Fees 200,000 200,000 0 0
Transportation Permits 35,756 35,756 0 0
Encroachment Permits 120,000 120,000 0 0
Parking Permits 7,000 7,000 0 0
Other Licenses and Permits 51,350 0 51,350 0
Subtotal Licenses and Permits $7,437,106 $3,290,756 $4,146,350 $0 Fines and Penalties
Vehicle Code Fines $380,000 $0 $0 $380,000
General Ordinance Fines 2,206,300 0 0 2,206,300
Delinquent Penalty 100,000 0 0 100,000
Library Fines 11,276 0 0 11,276
Subtotal Fines and Forfeitures $2,697,576 $0 $0 $2,697,576 Use of Money & Property
Interest Earnings $1,607,697 $0 $0 $1,607,697
All Rental /Lease Income 1,274,030 0 1,274,030 0
Subtotal Use of Money & Property $2,881,727 $0 $1,274,030 $1,607,697 Charges For Services
Plan Check Fees $485,000 $485,000 $0 $0
Zoning Clearance Fees $90,000 90,000 0 $0
Engineering Fees (Development Services) $246,000 246,000 0 $0 Encorachment Fee Plan Check $250,000 250,000 0 $0
ADU Developmemt Related Services 100,000 100,000 0 0
Application Fees for Waste Management Plan 130,000 130,000 0 0 Hazardous Materials Disclosure 300,000 300,000 0 0
IGT Reimb for Transport Fees 500,000 500,000 0 0
Adult & Youth Sports 158,959 0 0 158,959
Aquatics 54,000 0 0 54,000
Citation Validation 4,000 0 0 4,000
Civil Subpeona 1,400 0 0 1,400
Digital Media Copies 4,000 0 0 4,000
EMT Charges 0 0 0 0
EV Charge Station Revenue 30,000 0 0 30,000
Evidence Digital Media (Redacted) 5,000 0 0 5,000
False Alarms 150,000 0 0 150,000
Filing & Certification Fees 0 0 0 0
Fingerprints/Livescan 1,000 0 0 1,000
Fire Investigations (Restitution) 0 0 0 0
Firearms Inspections 1,500 0 0 1,500
Immigration Clearance Letter 800 0 0 800
Inspection Supplemental 12,500 0 0 12,500
Library Local History Fees 1,000 0 0 1,000
Note: 1 Development-related one-time processing fee revenues are deducted from projected departmental costs for Public Works, Community Development and Community Services.

2. Revenues not impacted by the project and certain revenues, such as fixed payments and grants, are not projected in the fiscal analysis.

Sources: Stanley R. Hoffman Associates, Inc.

City of Orange, Fiscal Year 2025/26 Adopted Budget
280
Stanley R. Hoffman Associates, Inc.

December 12, 2025 26
2375 N Tustin Street Residential Project
Fiscal Impact Analysis
City of Orange
Table A-2 (page 2 of 2)
General Fund Recurring Revenues
2375 N Tustin Street Residential Project Fiscal Impact Analysis City of Orange
(In Constant 2025 dollars)
Fiscal Year One-Time Revenues Revenues
2025/26 Development Not Projected Projected
Adopted Processing in Fiscal in Fiscal
Revenue Category Budget Revenue 1 Analysis 2 Analysis
Charges For Services (continued..)
Lobbyist Registration Fees 0 0 0 0
Lot Line Adj and Certificates 12,000 0 0 12,000
Massage Processing Fee 2,000 0 0 2,000
Medical Supplies Charges 230,000 0 0 230,000
Mills Act Fees 4,000 0 0 4,000
New Processing Fee 175,000 0 0 175,000
Non-Compliance Fee 13,000 0 0 13,000
Non-Deposit Based Application Fees 4,500 0 0 4,500
OMC/CVC Tow Release 130,000 0 0 130,000
OPM/3rd Party Background Checks 1,500 0 0 1,500
Other Charges For Serv-Citation Copies 49,500 0 0 49,500 Other Fire Services 5,000 0 0 5,000
Paramedic commission contra rev FY21 0 0 0 0
Paramedic Direct Fees 2,000,000 0 0 2,000,000
Paramedic Enrollment 275,000 0 0 275,000
Passport Photo Fee 10,000 0 0 10,000
Passport Processing Fee 30,000 0 0 30,000
Private Property Impound Fees 35,000 0 0 35,000
Purge/Notification Letter 1,200 0 0 1,200
Recreation Classes 52,000 0 0 52,000
Report Fees 10,000 0 0 10,000
Reports - Basic 5,000 0 0 5,000
Safety/Hazard Permits 6,500 0 0 6,500
SB9 Applications 4,000 0 0 4,000
Special event application/permit 4,000 0 0 4,000
Summer Playground - Recreation Activity 0 0 0 0
Tow Truck Dirve ID Fee 1,000 0 0 1,000
Tow Truck Driver ID Fee-Renewal 200 0 0 200
Vehicle ID Verification 1,500 0 0 1,500
Vehicle Repossession 3,000 0 0 3,000
Witness Fees 0 0 0 0
Subtotal Charges for Current Services $5,590,059 $2,101,000 $0 $3,489,059 Intergovernmental
County Waste Disposal Agr $400,000 $0 $400,000 $0
Other Grant Revenue 218,000 0 218,000 0
Revenue from Chapman University 542,800 0 542,800 0
State Grant Funds 90,000 0 90,000 0
State Reimb-Mandated Costs 100,000 0 100,000 0
Homeowners Property Tax Relief 60,283 0 60,283 0
Subtotal Intergovernmental $1,411,083 $0 $1,411,083 $0
Other Revenue
CalOES reimbursement-sexual assault exam $18,000 $0 $0 $18,000 Donations 67,416 0 0 67,416
Expense Reimbursements 154,931 0 0 154,931
Library Prepaid Card 14,000 0 0 14,000
Other Miscellaneous Revenue 26,500 0 0 26,500
Reimbursement-DOJ Live Scan Fee 2,000 0 0 2,000
Subtotal Other Revenue $282,847 $0 $0 $282,847
Transfers In
G & A Admin - G.O. Funds $3,794,969 $0 $3,794,969 $0
Transfers From Other Funds-All Funds $4,003,980 0 0 4,003,980 Subtotal Transfers In $7,798,949 $0 $3,794,969 $4,003,980 General Fund Total $146,972,280 $5,391,756 $16,960,432 $124,620,092 Note: 1 Development-related one-time processing fee revenues are deducted from projected departmental costs for Public Works, Community Development and Community Services.

2. Revenues not impacted by the project and certain revenues, such as fixed payments and grants, are not projected in the fiscal analysis.

Sources: Stanley R. Hoffman Associates, Inc.

City of Orange, Fiscal Year 2025/26 Adopted Budget
281
Stanley R. Hoffman Associates, Inc.

December 12, 2025 27
2375 N Tustin Street Residential Project
Fiscal Impact Analysis
City of Orange
Table A-3
Current Tax Rate Area (TRA) Allocations
2375 N Tustin Street Residential Project Fiscal Impact Analysis City of Orange
A-3 Current Tax Rate Area (TRA) Allocations
Table A-4
Property Tax In Lieu Vehicle License Fees (VLF) Estimated Citywide Factor 2375 N Tustin Street Residential Project Fiscal Impact Analysis City of Orange
(In Constant 2025 dollars)
A-4 Estimated Property Tax In Lieu Vehicle License Fee (VLF) Factor Agency TRA
Code Agency ¹ 008-124
001C Orange Co Gen. Fund 0.062615037
710A O C Flood Control District 0.020088732
713A O C Parks Csa 26 0.015527978
001C Educational Revenue Augmentation Fund 0.103866006
058B Educational Revenue Augmentation Fund 0.036014851
703A Educational Revenue Augmentation Fund 0.000743519
708A Educational Revenue Augmentation Fund 0.001900578
710A Educational Revenue Augmentation Fund 0.008252694
713A Educational Revenue Augmentation Fund 0.002970467
744A Educational Revenue Augmentation Fund 0.000928959
916A Educational Revenue Augmentation Fund 0.000272872
703A Orange Co Cemetery Fund-General 0.000505004
058B Orange City 0.135778929
744A Orange Co Vector Control Dist 0.001134350
960A Orange County Water District 0.008236874
961A Orange Co. Water Dist-Water Reserve 0.000123664
708A Orange County Transit Authority 0.002850867
916A Oc Sanitation #2 Gen Fund 0.031998315
420B Orange Unified General Fund 0.470464152
400B Rancho Santiago Comm Coll Gen Fund 0.077567540
600A O C Dept Of Education-Gen Fund 0.018158611
TOTAL 1.000000000
Sources: Stanley R. Hoffman Associates, Inc.

Orange County Auditor-Controller, Property Tax Accounting, Property Tax Allocation, SECTION 99 FACTOR RPT BY TRA, 2024-25.

Property Tax Assessed VLF per
Fiscal Year In-Lieu of VLF 1 Valuation (AV) 2 $1,000,000 AV 3 2021 - 2022 14,932,479 22,844,350,739 $650
2022 - 2023 15,701,602 23,645,989,631 $660
2023 - 2024 16,845,175 24,783,277,745 $680
2024 - 2025 17,271,109 26,631,838,417 $650
2025 - 2026 18,340,648 27,264,292,435 $670
Average $660

1. The property tax in lieu VLF amounts are from the City budget documents cited below.

2. Assessed valuation amounts are from the County Assessor Office assessment rolls, as cited below.

3. Estimated VLF per $1,000,000 AV is rounded to the nearest tens.

Sources: Stanley R. Hoffman Associates, Inc.

City of Orange, Fiscal Year Adopted Budgets, FY 2021 through 2025 Orange County, Office of Assessor, 2021 - 2025 Assessment Rolls, City of Orange 282
Stanley R. Hoffman Associates, Inc.

December 12, 2025 28
2375 N Tustin Street Residential Project
Fiscal Impact Analysis
City of Orange
Table A-5
Estimated Average Household Income
Single Family Ownership Households
Orange County
A-5 Estimated Average Household Income, Single-Family Ownership, Orange County Table A-6
Calculation of Use Tax Factor
2375 N Tustin Street Residential Project Fiscal Impact Analysis City of Orange
A-6 Calculation of Use Tax Factor
Year Unit
Built Avg. HH Inc.1
No. of
Households 1 Avg. HH Inc.1
No. of
Households 1
2020 $214,091 615 $246,360 401 $230,456,204
2021 $231,773 204 $239,776 289 $116,577,009
2022 $387,181 148 $208,108 97 $77,489,300
967 787 $424,522,513
Total Households 1,754
Average Household Inc. $242,031

1. Data from the ACS 5-year estimates, 2019-2023, Public Use Microdata Sample for Orange County obtained from IPUMS USA, University of Minnesota.

Source: Stanley R.Hoffman Associates, Inc.

American Community Survey (ACS), 5-year Estimates, 2019-2023. 3-Bedroom 4-Bedroom Aggregate
Household
Income All Units
City of Orange Annual 2024 Amount
Use Tax 1
County Pool $9,057,746
State Pool 27,406
Total Use Tax $9,085,151
divided by
Point-of-Sale Sales Tax 1 $48,569,029
equals
Use Tax Rate 2 18.7%

1. Annual 2024 data as reported by the CDTFA.

2. The use tax rate is the County Pool plus the State Pool divided by Point-of-Sale Taxable Sales Tax.

Sources: Stanley R. Hoffman Associates, Inc.

California Department of Tax and Fee Administration (CDTFA), 2025 283
Stanley R. Hoffman Associates, Inc.

December 12, 2025 29
2375 N Tustin Street Residential Project
Fiscal Impact Analysis
City of Orange
Table A-7
Net Cost Factors: Public Works, Community Development and Community Services 2375 N Tustin Street Residential Project Fiscal Impact Analysis City of Orange
(In Constant 2025 dollars)
A-7 Net Costs: Public Works, Comm. Development, and Comm. Services Adopted
FY 2025-26
Category Amount
A. PUBLIC WORKS NET COSTS
Total Public Works Costs $10,423,942
minus
Charge for Services 550,000
Licenses and Permits 169,256
Other Revenue (incl. Use of Money and Property) 30,200
Total One-Time Fees $749,456
equals
Net Recurring Public Works Costs $9,674,486
divided by
City Developed Acres 1 10,315
equals
Net Public Works Cost Factor per Developed Acres $937.86 B. COMMUNITY DEVELOPMENT NET COSTS
Total Community Development Costs $6,396,669
minus
Charge for Services 501,500
Licenses and Permits 2,867,500
Fines and Penalties 30,000
Total One-Time Fees $3,399,000
equals
Net Recurring Community Development Costs $2,997,669
divided by
City Developed Acres 1 10,315
equals
Net Community Development Cost Factor per Developed Acres $290.60 C. COMMUNITY SERVICES
Total Community Services Costs $10,318,531.27
Charge for Services $264,959.00
Other Revenue (incl. Use of Money and Property) $386,700.00 Total One-Time Fees $651,659.00
Net Recurring Community Development Costs $9,666,872
divided by
City Population 1 139,724
equals
Net Community Services Cost Factor per Capita $69.19

1. Developed Acres in the City of Orange based on information provided by City GIS staff.

Sources: Stanley R. Hoffman Associates, Inc.

City of Orange, Adopted Budget, Fiscal Year 2025-26.
284
Stanley R. Hoffman Associates, Inc.

December 12, 2025 30
2375 N Tustin Street Residential Project
Fiscal Impact Analysis
City of Orange
Table A-8
Details of Comparative Revenue Performance Evaluation of Non-Residential Uses 2375 N Tustin Street Residential Project Fiscal Impact Analysis City of Orange
(In Constant 2025 dollars)
A-8 Details of Comparative Revenue Performance Evaluation for Non-Residential Uses Gyms Discount Stores
Seasonal Stores
(Annualized)
Property Reuse Assumption Renovation Minimal Change Minimal Change Floor Size (sf) Assumption 40,000 10,000 10,000
Refurb Costs per SF 1 $120 $25 $10
Existing Property Valuation $22,327,825 $22,327,825 $22,327,825 New Improvement Value (Refurb Cost) $4,800,000 $250,000 $100,000 New Total Assesed Valuation $27,127,825 $22,577,825 $22,427,825 Operations 2
Average Gross Revenues $3,000,000 $2,500,000 $2,000,000 Assumed Taxable Sales Share 10% 100% 100%
Average Retail Sales per SF 3 n/a $250 $200
Taxable Retail Sales $300,000 $2,500,000 $2,000,000
Number of Employees 10 22 17
Major Public Revenues
Overall Property Tax (1%) $271,278 $225,778 $224,278
Property Tax City Share: 13.6% of 1% $36,894 $30,706 $30,502 Property Tax In-Lieu of VLF 4 $3,168 $165 $66
Sales and Use Tax
Sales Tax (1% Taxable Sales) $3,000 $25,000 $20,000
Use Tax (18.6% of Sales Tax) $558 $4,650 $3,720
Sales and Use Tax Total $3,558 $29,650 $23,720
Business License Fees 5 $715 $615 $615
TOTAL ESTIMATED MAJOR REVENUES $44,335 $61,136 $54,903

1. Renovation cost estimation obtained from RS Means for Orange County. Gyms are assumed to undertake extensive rennovations, while discount and seasonal stores are assumed to undertake cosmetic rennovations.

2. Average annual revenues per gym franchise obtained from franchise disclosure documents.

Seasonal stores have been annualized based on a 3-month activity period.

3. Based on data presented in the report "California Retail Analytics, 2025" prepared by HdL Companies.

4. PTVLF calculated at $660 per million net new valuation.

5. Based on the City of Orange Business License Fee schedule, calculated by gross revenue brackets.

Source: Stanley R. Hoffman Associates, Inc.

RSMeansOnline - Estimation Software.

HdL Companies.
285
Stanley R. Hoffman Associates, Inc.

December 12, 2025 31
2375 N Tustin Street Residential Project
Fiscal Impact Analysis
City of Orange

APPENDIX B

PROJECT REFERENCES

CITY OF ORANGE
300 E. Chapman Ave.

Orange, CA 92866
City Manager
Jared L. Hildenbrand, City Manager
(714) 744-2222
[email protected]
Community Development Department
Russell W. Bunim, Community Development Director
(714) 744-7220
[email protected]
Jessica Herrera, Housing Manager
(714) 744-7270
[email protected]
Finance Department
Trang Nguyen, Finance Director
(714) 744-2238
Melia Homes, LLC
9860 Irvine Center Drive
Irvine, CA 92618
(949)759-4367
DJ Delzer, CEO
Gavin Reid, Vice President of Land Acquisitions
Chad Brown, Vice President of Planning & Development
Burnam-Ward Properties
860 Newport Center Drive, Suite 100
Newport Beach, CA 92660
(949) 992-2400
Steve Thorpe, Partner
HdL COMPANIES
Taxable Sales Information
hdlcompanies. com
286
5256 S. Mission Road, Ste. 404
Bonsall, CA 92003
www.summarch.com p.760.724.1198

ARCHITECTURE
ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES

MELIA HOMES
9860 Irvine Center Drive
Irvine, CA 92618
(949) 759-4367
APRIL 10, 2026 CS
VICINITY MAP - N.T.S.

COVER SHEET
PROJECT DESCRIPTION:
3 STORY SMALL-LOT DETACHED HOMES
AND DUPLEXES TOTALING 71 UNITS IN 42 BUILDINGSWITH 5 PLAN TYPES ON A 4.235 ACRE SITE.

PROJECT SHEET INDEX

ARCHITECTURE

CS COVER SHEETSL SMALL LOT SUBDIVISION
DEVELOPMENT STDS.

SP SITE PLAN

ES EXISTING SITE PLANEE EXISTING EASEMENTS EXHIBIT

OS OPEN SPACE

HM HOA MAINTENANCE EXHIBIT
A-1 PERSPECTIVESA-2 PLAN 1 FLOOR PLANA-3 PLAN 2 FLOOR PLANA-4 PLAN 3A FLOOR PLANA-5 PLAN 3B FLOOR PLANSA-6 PLAN 3C FLOOR PLANSA-7 PLAN 4 FLOOR PLANSA-8 PLAN 5A FLOOR PLANSA-9 PLAN 5B FLOOR PLANSA-10 PLANS 3A/3B AND 5B ROOF PLANSA-11 DUPLEX TYPE A, B, AND C FLOOR PLANSA-12 DUPLEX TYPE A ELEVATIONSA-13 DUPLEX TYPE B ELEVATIONSA-14 DUPLEX TYPE C ELEVATIONSA-15 PLAN 3A ELEVATIONSA-16 PLAN 3B ELEVATIONSA-17 PLAN 5B ELEVATIONSA-18 SHADE/SHADOW EXHIBITSA-19 EXISTING SHADOW EXHIBITA-20 LADDER PAD EXHIBITA-21 LADDER PAD EXHIBITA-22.1 SECTION A - NORTH EDGE LINE OF SIGHTA-22.2 SECTION B - NORTH EDGE LINE OF SIGHTA-22.3 SECTION C - SOUTH EDGE LINE OF SIGHTA-22-4 SECTION D - SOUTH EDGE LINE OF SIGHTA-22-5 SECTION 3 - SOUTH EDGE LINE OF SIGHT TEL.

DEVELOPERMELIA HOMES9860 IRVINE CENTER DRIVEIRVINE, CA. 92618 (949)417-6264
Contact: CHAD [email protected] ARCHITECTURE5256 SOUTH MISSION RD, # 404BONSALL, CA 92003 760-724-1198
Contact: ERICK VAN [email protected]
TEL.

CIVIL ENGINEER/SURVEYORC&V CONSULTING, INC.6 ORCHARD, SUITE 200LAKE FOREST, CA 92630 949-445-1749
Contact: MARCO [email protected]
TEL.

LANDSCAPE ARCHITECTSTUDIO PAD, INC.23282 MILL CREEK DR, SUITE 200LAGUNA HILLS, CA 92653 949-770-8530
Contact: PETER [email protected]
VESTED OWNER:

BTPROP3, LLC A CALIFORNIA LIMITED LIABILITY COMPANY
LEGAL DESCRIPTION:

THE LAND REFERRED TO HEREIN BELOW IS SITUATED IN THE
CITY OF ORANGE, IN THE COUNTY OF ORANGE, STATE OFCALIFORNIA, AND IS DESCRIBED AS FOLLOWS:

PARCEL 1 AS SHOWN ON EXHIBIT "B" OF LOT LINE
ADJUSTMENT NO. 2025-01 RECORDED MAY 29, 2025 AS
INSTRUMENT NO. 2025000151774 OF OFFICIAL RECORDS OF

SAID COUNTY
PROJECT TEAM:

PROJECT SUMMARYPRODUCT TYPE: 71 UNITS
3 STORY DETACHED/DUPLEXES
A.P.N.: 372-642-31
SITE AREA: 4.235 AC
DENSITY: 16.76 DU/ACEXISTING LAND USE: GENERAL COMMERCIAL (GC)PROPOSED LAND USE: MEDIUM DENSITY RESID. (MDR)EXISTING ZONING: C-TR LIMITED BUSINESS

TUSTIN REDEVELOPMENT PROJECT AREA
PROPOSED ZONING: MULTIPLE-FAMILY RESIDENTIAL
(R-3) W/ APPLICATION OF SMALL LOT SUBDIVISION DEVELOPMENT STANDARDS (OMC 17.14.270) BLDG. STORIES: 3 STORYBLDG HEIGHT: 35' (35' ALLOWED)FRONT SETBACK: 16.6' (15' ALLOWED) SIDE SETBACK: 10.1' (5' ALLOWED)
REAR SETBACK: 10.1' (10' ALLOWED)
PRODUCT SUMMARY (ALL 3 STORY HOMES)
PLAN LIVABLE ROOF GARAGE # OF
# TYPE AREA DECK AREA BD/BA
10 PL 1 2,008 S.F. 300 S.F. 472 S.F. 3BD/DEN/2BA/2PWD 16 PL 2 2,014 S.F. 0 S.F. 446 S.F. 3BD/DEN/2BA/2PWD 1 PL 3A 2,026 S.F. 0 S.F. 477 S.F. 4 BD/3BA/1PWD 13 PL 3B/3C 2,026 S.F. 269 S.F. 477 S.F. 4 BD/3BA/1PWD 13 PL 4 2,086 S.F. 235 S.F. 473 S.F. 3BD/DEN/2BA/2PWD 18 PL 5A/5B 2,117 S.F. 0 S.F. 446 S.F. 3BD/DEN/2BA/2PWD NOTE: ALL PLANS PROVIDE 120 C.F. STORAGE IN OVERHEAD RACK OR SHELVING

BUILDING CODE SUMMARY
OCCUP. TYPE: R3/U (CRC)CONST. TYPE: TYPE VB
FIRE SPRINKLER: NFPA 13D (CRC R313.1)
2022 CALIFORNIA RESIDENTIAL CODE (CRC)2022 CALIFORNIA ELECTRICAL CODE (CEC)2022 CALIFORNIA MECHANICAL CODE (CMC)2022 CALIFORNIA PLUMBING CODE (CPC)2022 CALIFORNIA FIRE CODE (CFC)2022 CALIFORNIA GREEN BLD'G STDS CODE (CGBSC)2022 CALIFORNIA ENERGY EFFICIENCY STDS (CEES) GPA25-0003 - DRC25-0019, ENV25-0001, MJSP25-0002, TTM25-0001, ZC25-0002

PROJECT APPLICATIONS
GPA25-0003 - DRC25-0019
ENV25-0001, MJSP25-0002
TTM25-0001, ZC25-0002

PROJECT SHEET INDEX (CONTINUED)
LANDSCAPEL1 SCHEMATIC LANDSCAPE PLANL2 SCHEMATIC ENLARGEMENT PLANL3 SCHEMATIC WALL AND FENCE PLANL4 SCHEMATIC PLANTING PLANL5A PLANT IMAGES - TREESL5B PLANT IMAGES - SHRUBS AND GROUNDCOVERL6 SCHEMATIC SHRUB AND

GROUNDCOVER AREA PLAN
L7 SCHEMATIC EXISTING TREE PLANL8 SCHEMATIC PERMEABLE AREA PLANL9A SCHEMATIC PHOTOMETRIC LIGHTING PLANL9B SCHEMATIC LIGHTING PLAN (LOW VOLTAGE 12V)L10 SCHEMATIC TRASH CART LAYOUT/HAULER

CIRCULATION PLAN
L11 SCHEMATIC IRRIGATION HYDROZONE PLAN
CIVIL
1 TITLE SHEET
2 PRELIMINARY SITE PLAN
3 PRELIMINARY GRADING PLAN
4 PRELIMINARY UTILITY PLAN
5 PRELMIINARY SECTIONS
Attachment 6
287
5256 S. Mission Road, Ste. 404
Bonsall, CA 92003
www.summarch.com p.760.724.1198

ARCHITECTURE
ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES

MELIA HOMES
9860 Irvine Center Drive
Irvine, CA 92618
(949) 759-4367
APRIL 10, 2026 SL

SMALL LOT
DEVELOPMENT STDS.

OMC SECTION 17.34.130

TYPICAL STRIPING DETAIL FOR ALL OPEN PARKING SPACES
288
POOL
CAR

ONLY STOP STOP STOP
THRU
DRIVE
THRU
DRIVE PL 3A 1 STORY GARAGES 1 STORY GARAGES 1 STORY GARAGES 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY RETAIL 1 STORY RETAIL 1 STORY GARAGES 1 STORY GARAGES 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY RESID.
1 STORY RESID.
1 STORY RESID.
1 STORY RESID.
1 STORY RESID.
55 FREEWAY

TUSTIN STREET
1 STORY

MULTI-FAMILY
1 STORY RETAIL PROPOSED COMMERCIAL 1 STORY RETAIL NOT A PART 5 6
6 6 PL 5B PL 2 PL 4 PL 5A PL 5A PL 2 PL 5A PL 2 PL 5A PL 2 PL 5A PL 2 PL 5A PL 2 PL 5A PL 2 PL 2 PL 5A PL 2 PL 5A PL 2 PL 5A PL 2 PL 5A PL 2 PL 5A PL 2 PL 5A PL 2 PL 5A PL 2 PL 5A PL 2 PL 5A PL 5B PL 3B PL 3B PL 1
PL 1
PL 1
PL 1
PL 1 PL 3B
PL 3B
PL 3B
PL 3B
PL 4
PL 4
PL 4
PL 4
PL 4
PL 3B
PL 3B
PL 3B
PL 3B
PL 3C PL 3C PL 4 PL 4 PL 1 PL 4 PL 1 PL 4 PL 1 PL 4 PL 1 PL 4 PL 1 PL 3C PL 4

29.0 11.5

3.6 9.8

28.9 F.H. F.H. F.H. NEW 6' PRECISION MASONRY WALL W/ ANTI-GRAFFITI PAINT 470.25' 192.60'
140.00' 8.24' 537.45'
170.60' 222.51'275.01'

60.00'
1 1 1
4 1
1 2
2 3
3 4
4 1
2 3
4 7
7 8
9 9 10 9 10 10
7 7
7 7
7 77 10
4 11 12 13 13 13 13 1313 14 15 15 15 15
100.02'

23.0 EXISTING 6' TAN PRECISION MASONRY WALL TO REMAIN 6'-7' HIGH METAL EMERGENCY ACCESS GATES NEW 8' TAN PRECISION MASONRY WALL ROLLING SLIDE GATE FOR BILLBOARD ACCESS EXISTING BILLBOARD EXIST'G 6' TAN PRECISION MASONRY WALL TO REMAIN EXIST'G 8' GREY PRECISION MASONRY WALL TO REMAIN W/ ANTI-GRAFFITI PAINT NOT A PART //
//
//
// // // // // // // //
//
//
// // // // // //
// //
//
//
//
Z
Z
Z
Z
Z
||
|| ||
T
Z
Z
Z
Z
Z
Z
Z
Z

RESIDENTIAL GUEST

PARKING

12.5'
9' 9' 9' 9' 18' 18'

3.5' 18' 10' 1'
8' 3.5' 9'
4'

6.7'

3.7' 7' 9.4'
3' 5.3' 7' 7' 7' 7' 7' 7' 7' 7' 7' 7' 7' 7'
9'
24'
10'
10' 10'
122.6' 30.6' EX. ESMT (TO REMAIN) 18' 8.7'
9' 3' 8' 4.5' 9.2' 4' 4' 2.8' 4'
24' 4.9' 4.9' 4.2' 4.2'
10' 10'
10' 10'
10' 10' 7' 9.4'
7'
7'

10.2'

10.1'

3.1'

10.1'
10'

10.2'

10.4'

10.5'

10.7'
11'

11.2'

11.4'

11.6'

10.5'

10.4'

10.6'

10.7'

10.9'

11.1'

11.3'

11.3'
13'

11.5' 15.2'
3'
3'
3'
3'
3'
3'
3'
3'
3'
3'
3'
3'
3'
3'

2.2'

3.3'
3'
3'
3'
3'
3'
3' 10.1'

10.1'

10.7'

10.6'

10.7'

10.1'

10.7'

10.1'

10.7'

10.1'

10.7'

10.6' 21.5

11.0 12.0 25.0 25.0

25.0 25.0 25.0

1.1' 5.2' 5.2' 5.2' 5.2' 5.2' 5.2' 5.2' 5.2' 5.2' 5.2' 5.2' 5.2' 5.2' 5.3' 5.3' 5.3' 5.3' 5.3' 5.3' 5.3' 8.8' 3.3'

5.3' 10.7'
1' 16.7' 16.6' 16.8' 16.9' 15.1'

11.6'

10.1'

10.7'

10.6'

10.5'
11'
10'

11.8'

13.1'

12.9'

12.7'

12.5'

12.3'
12' 16.6' 15.1' 15.4'
R50.0 R55.0
R55.0
R50.0
R50.0
R55.0
R50.0
R55.0
R17.5 15
*
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* PROJECT SUMMARY PRODUCT TYPE: 71 UNITS 3 STORY DETACHED/DUPLEXES A.P.N.: 372-642-31 SITE AREA: 4.235 AC DENSITY: 16.76 DU/AC EXISTING LAND USE: GENERAL COMMERCIAL (GC) PROPOSED LAND USE: MEDIUM DENSITY RESID. (MDR) EXISTING ZONING: C-TR LIMITED BUSINESS TUSTIN REDEVELOPMENT PROJECT AREA PROPOSED ZONING: MULTIPLE-FAMILY RESIDENTIAL (R-3) W/ APPLICATION OF SMALL LOT SUBDIVISION DEVELOPMENT STANDARDS (OMC 17.14.270) BLDG. STORIES: 3 STORY BLDG HEIGHT: 35' (35' ALLOWED) FRONT SETBACK: 15.1' (15' ALLOWED)
SIDE SETBACK: 10.1' (5' ALLOWED)
REAR SETBACK: 10.1' (10' ALLOWED)
1 2 PROPERTY LINE
3 4
5 6
7 8 C.M.U. WALL -SEE NOTE & WALL PLAN
9 AMENITY AREA -SEE LANDSCAPE PLAN STANDARD PARKING STALL - 9' X 18' 3-STORY DWELLING, TYP. FIRE LANE SITE PLAN KEYNOTES ENHANCED PAVING (SEE LANDSCAPE PLAN) CONCRETE WALKWAY - MIN. 4' WIDE OPEN STALL W/IN PRIVATE LOT (4 BDRM) PARALLEL PARKING STALL - 9' X 24' 10 FIRE LADDER PAD (TYPICAL) 11 ENTRY MONUMENT - SEE LANDSCAPE PLAN 12 PEDESTRIAN PATH OF TRAVEL FROM TUSTIN ST. 13 ELECTRICAL TRANSFORMER OR SWITCH DOUBLE STRIPING AT PARKING STALLS PER CITY STANDARD, SEE DETAIL SHEET SL 1415 SETBACK LINE PRODUCT SUMMARY (ALL 3 STORY HOMES) PLAN LIVABLE ROOF GARAGE # OF # TYPE AREA DECK AREA BD/BA 10 PL 1 2,008 S.F. 300 S.F. 472 S.F. 3BD/DEN/2BA/2PWD 16 PL 2 2,014 S.F. 0 S.F. 446 S.F. 3BD/DEN/2BA/2PWD 1 PL 3A 2,026 S.F. 0 S.F. 477 S.F. 4 BD/3BA/1PWD 13 PL 3B/3C 2,026 S.F. 269 S.F. 477 S.F. 4 BD/3BA/1PWD 13 PL 4 2,086 S.F. 235 S.F. 473 S.F. 3BD/DEN/2BA/2PWD 18 PL 5A/5B 2,117 S.F. 0 S.F. 446 S.F. 3BD/DEN/2BA/2PWD NOTE: ALL PLANS PROVIDE 120 C.F. STORAGE IN OVERHEAD RACK OR SHELVING 2022 CALIFORNIA ENERGY EFFICIENCY STDS (CEES) PARKING SUMMARY REQUIRED: 3BD = 2.0 ST/U X 57 114 STALLS 4BD = 3.0 ST/U X 14 42 STALLS 71 U X 0.25 ST/U GUEST 18 STALLS 174 STALLS PROVIDED: GARAGES (2 CAR) 142 STALLS ON-LOT 14 STALLS GUEST 23 STALLS 179 STALLS USPS PARKING 1 STALL OPEN SPACE SUMMARY (SEE SHT. OS FOR LOCATIONS) REQUIRED OPEN SPACE PER UNIT = 150 S.F. PRIVATE YARD AREA 10,360 S.F. PROVIDED (UNITS 1-20, 54-68) (240 S.F. MIN., 10'X24') ROOF DECK AREA 9,552 S.F. PROVIDED (UNITS 21-53, 69-71) 235 S.F. MIN., 13'3" X 18'8" TOTAL PRIVATE OPEN SPACE 19,912 S.F. (280 S.F./UNIT) COMMON OPEN SPACE 6,031 S.F. (85 S.F./UNIT)
(20' MIN. DIMENSION) CODE SUMMARY 2022 CALIFORNIA RESIDENTIAL CODE (CRC) 2022 CALIFORNIA ELECTRICAL CODE (CEC) 2022 CALIFORNIA MECHANICAL CODE (CMC) 2022 CALIFORNIA PLUMBING CODE (CPC)2022 CALIFORNIA FIRE CODE (CFC)2022 CALIFORNIA GREEN BLD'G STDS CODE (CGBSC)2022 CALIFORNIA ENERGY EFFICIENCY STDS (CEES) BUILDING SUMMARY OCCUP. TYPE: R3/U (CRC) CONST. TYPE: TYPE VB FIRE SPRINKLER: NFPA 13D (CRC R313.1) ADDITIONAL NOTES/LEGEND: REFER TO CIVIL PLANS FOR UTILITY IMPROVEMENTS (SEWER/WATER/STORM DRAIN/FIRE LINE) SEE FLOOR PLAN SHEETS A2 & A5-A7 FOR AC CONDENSERS LOCATED ON ROOF DECKS AND SCREENED FROM VIEW BY SOLID PARAPET WALLS AT PLANS 1, 3B, 3C AND 4 (LOTS 21-53 AND 69-71) LOT NUMBER PLAN TYPE FIRE LADDER PAD ADA PATH AC CONDENSER SETBACK DIMENSION FROM BUILDING FACE OR CANTILEVER TO PROPERTY LINE FROSTED GLASS AT 3RD FLOOR BEDROOM WINDOWS AT LOTS 11-20 AND 54-59 10.1' NORTH SITE PLAN 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Dr. Irvine, CA 92618 (949) 759-4367 VESTING TTM 19392 0 30 60 90 APRIL 10, 2026 SP *
289

38.9 52.4

43.3 NORTH EXISTING SITE PLAN 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Dr. Irvine, CA 92618 (949) 759-4367 VESTING TTM 19392 0 30 60 90 APRIL 10, 2026 ES 290
NORTH EXISTING EASEMENT EXHIBIT 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Dr. Irvine, CA 92618 (949) 759-4367 VESTING TTM 19392 0 40 80 120 APRIL 10, 2026 EE 291

STOP STOP STOP
THRU
DRIVE
THRU
DRIVE PRIVATE REAR YARDS 10' CLEAR FROM FACE OF WALL, TYPICAL //
//
//
// // // // // // // //
// // // // // // // // // //
//
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|| || || T Z Z Z Z Z Z Z Z PRIVATE REAR YARDS 10' CLEAR FROM FACE OF WALL, TYPICAL REQUIRED OPEN SPACE PER UNIT = 150 S.F. PRIVATE YARD AREA 10,360 S.F. PROVIDED (UNITS 1-20, 54-68) (240 S.F. MIN., 10'X24') ROOF DECK AREA 9,552 S.F. PROVIDED (UNITS 21-53, 69-71) 235 S.F. MIN., 13'3" X 18'8" TOTAL PRIVATE OPEN SPACE 19,912 S.F. (280 S.F./UNIT) COMMON OPEN SPACE 6,031 S.F. (85 S.F./UNIT)
(20' MIN. DIMENSION) NORTH OPEN SPACE 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Dr. Irvine, CA 92618 (949) 759-4367 VESTING TTM 19392 0 30 60 90 APRIL 10, 2026 OS OPEN SPACE SUMMARY 292

STOP STOP STOP
THRU
DRIVE
THRU
DRIVE
//
//
//
// // // // // // // //
// // // // // // // // // //
//
// // Z Z Z Z Z
|| || || T Z Z Z Z Z Z Z Z NORTH HOA MAINTENANCE EXHIBIT 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Dr. Irvine, CA 92618 (949) 759-4367 VESTING TTM 19392 0 30 60 90 APRIL 10, 2026 HM HOA MAINTENANCE AREAS PRIVATE DRIVES/PARKING/IMPROVEMENTS 61,425 S.F. OTHER LANDSCAPE/HARDSCAPE AREAS 51,464 S.F. 293

PERSPECTIVES
5256 S. Mission Road, Ste. 404
Bonsall, CA 92003
www.summarch.com p.760.724.1198

ARCHITECTURE
ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES

MELIA HOMES
9860 Irvine Center Drive
Irvine, CA 92618
(949) 759-4367
APRIL 10, 2026 A1
FRONT ENTRY PERSPECTIVE (PLANS 2 AND 5A) PASEO PERSPECTIVE AT UNIT 32 TOWARD SOUTHEAST

PERSPECTIVE FROM TUSTIN STREET TOWARD EAST
PERSPECTIVE OF MAIN RECREATION AREA VIEWED FROM PROJECT ENTRY PERSPECTIVE OF COMMON WALKWAY AT UNITS 30/31 TOWARD NORTH PERSPECTIVE OF RECREATION AREA TOWARD SOUTHEAST

PERSPECTIVE OF PROJECT ENTRY
PERSPECTIVE OF PLANS 5A/3B LOOKING NORTHEAST (LOT 67/71 ) PERSPECTIVE OF TYPICAL INTERIOR PASEO 294
REC TR PLAN 1 3BED/2BA+2PWD 1ST FL - 361 2ND FL - 863 3RD FL - 784 TOTAL LIVABLE - 2,008 S.F. ROOF DECK 300 S.F. GARAGE - 472 S.F. 1ST FLR 2ND FLR 2 CAR GARAGE 20' X 20' CLR. ORG WH 3RD FLR KITCHEN LIVING DINING PAN PWD ROOF DECK 300 S.F. 20'-1" W/D BDRM 2 BDRM 1 BA 1 CL BA 2 FAU DEN BDRM 3 LIN ROOF DECK 20'-112" 36'-0" 12'-7" 10'-5" 1'-8"
1'-8"
9'-312" 3'-712" 5'-312" 4'-4" 9'-2" 4'-312" 12'-7" 10'-5" 17'-412" 5'-712" 12'-912" 10'-212" 1'-8" 10'-4" 2'-712" 5'-1112" 13'-012" 4'-0" 19'-012" 3'-11" 19'-9" 18'-5" 12'-7" 10'-5" 12'-912" 10'-212"
16'-9" 19'-3"
6"
6"
6" 23'-0"
20'-612" 15'-512"
9'-0" 12'-3" 15'-3"
38'-2" 4"
120 CU.FT. STORAGE

SHELVES
38'-2" 18" X 25" 18" X 25" 18" X 25" PWD 42" HIGH SOLID PARAPET WALL AT AC CONDENSER 3'-0"9'-0" 23'-0" 12'-7" 10'-5" 5'-9"
1'-8" ENTRY PAN PLAN 1 (DUPLEX) 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Drive Irvine, CA 92618 (949) 759-4367 0 4 8 12 APRIL 10, 2026 A2 295
20'-1" REC TR PLAN 2 3BED/2BA+2PWD 1ST FL - 392 2ND FL - 839 3RD FL - 783 TOTAL LIVABLE - 2,014 S.F. GARAGE - 446 S.F. 1ST FLR 2ND FLR ORG WH 3RD FLR FAU 120 CU.FT. STORAGE
RACK ABOVE 3'-1112" 20'-8"
20'-612" 4'-2" 2'-10" 7'-1112" 12'-1012" 5'-012" 6'-812" 5'-6" 5'-412" 25'-1"
9'-112" 5'-7" 3'-312" 3'-10" 13'-712" 14'-9" 5'-11" 3'-1112" 5'-6" 5'-412" 25'-1" 15'-512" 9'-2" 3'-1112" 15'-012" 5'-712" 4'-512" 11'-312" 2'-712" 17'-112" 15'-512" 9'-2" 5'-6" 5'-412" 5'-312" 3'-1012" 3'-4" 12'-7" 2 CAR GARAGE 20' X 20' CLR. 20'-1" DEN PWD KITCHEN DINING LIVING PWD BDRM 2 BDRM 1 BA 1 CL BA 2 BDRM 3 LIN LAUN PAN 18" X 25" 18" X 25" 18" X 25" 24'-712" ENTRY PLAN 2 (DUPLEX) 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Drive Irvine, CA 92618 (949) 759-4367 0 4 8 12 APRIL 10, 2026 A3 296
BDRM 2 BDRM 1 BA 2 BA 1 STOR BDRM 3 KITCHEN LIVING BA 3 BDRM 4 ENTRY PWD 2 CAR GARAGE 20' X 20' CLR. WH DINING 3RD FLR 2ND FLR 1ST FLR 20'-2" 20'-2" PLAN 3A 4 BED/3BA/1PWD 1ST FL - 358 2ND FL - 864 3RD FL - 804 TOTAL LIVABLE - 2,026 S.F. GARAGE - 477 S.F. REC ORG TRASH W/D FAU CL 39'-6"
20'-7" 16'-11" 23'-0" 9'-3" 13'-9" 22'-6" 3'-612" 16'-1" 2'-1012" 2'-0" 1'-612" 39'-6"
2'-0" 7'-512" 30'-012" 23'-0" 9'-3" 13'-9"
17'-612" 20'-612" 1'-5" 11'-312 11'-2 " 12 11'-3 " 12 11'-2 " 12" 2'-0" 10'-712" 2'-6" 11'-7" 12'-912" 23'-0" 9'-3" 13'-9" 8'-10" 8'-8" 11'-112" 9'-5" 1'-512" 1'-2"
120 CU. FT. STORAGE SHELVES
4'-3" 10'-11" 18" X 25" 18" X 25" 18" X 25" PAN
5'-5" 15'-5" 2'-0" PLAN 3A (DETACHED - LOT 6 ONLY) 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Drive Irvine, CA 92618 (949) 759-4367 0 4 8 12 APRIL 10, 2026 A4 297
3RD FLRBDRM 2 BDRM 1 BA 2 BA 1 BDRM 3 FAU CL 11'-312 11'-2 " 12" 23'-0" 9'-3" 13'-9" 2'-0" 10'-712" 2'-6" 11'-7" 12'-912"
11'-412" 7'-9" 15'-0" 3'-1112" 1'-512" BA 3 BDRM 4 ENTRY 2 CAR GARAGE 20' X 20' CLR. WH 1ST FLR 20'-2" 20'-2" PLAN 3B 4 BED/3BA/1PWD 1ST FL - 358 2ND FL - 864 3RD FL - 804 TOTAL LIVABLE - 2,026 S.F. ROOF DECK 269 S.F. GARAGE - 477 S.F. REC ORG TRASH 39'-6"
20'-8" 16'-10" 23'-0" 9'-3" 13'-9" 22'-6" 3'-612" 16'-1" 2'-1012" 2'-0" 5'-5" 5'-9" 15'-6" 1'-512" 1'-2"
120 CU. FT. STORAGE SHELVES KITCHEN LIVING PWD DINING 2ND FLR W/D 39'-6"
2'-0" 7'-512" 30'-012" 23'-0" 9'-3" 13'-9"
17'-612" 20'-612" 1'-5" 11'-312 11'-2 " 12" ROOF DECK 269 S.F. ROOF DECK 18'-1112" 19'-112" 1'-512"
2'-0" 16'-1112" 15'-112" 5'-5" 9'-3" 13'-9" 11'-312 11'-2 " 12" 18" X 25" 18" X 25" 18" X 25" PAN LIN 9'-5" 18'-712" 2'-0" 42" HIGH SOLID PARAPET WALL AT AC CONDENSER 4'-1" PLAN 3B (DETACHED) 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Drive Irvine, CA 92618 (949) 759-4367 0 4 8 12 APRIL 10, 2026 A5 298
BA 3 BDRM 4 ENTRY 2 CAR GARAGE 20' X 20' CLR. WH 1ST FLR - 3C 20'-2" 20'-2" REC ORG TRASH
39'-6"
20'-7" 16'-11" 23'-0" 9'-3" 13'-9" 22'-6" 3'-612" 16'-1" 2'-1012" 2'-0" 1'-612" 1'-2"
120 CU. FT. STORAGE SHELVES
15'-6" 5'-4" 4'-3" 10'-11" 3RD FLR - 3C BDRM 2 BDRM 1 BA 2 BA 1 BDRM 3 FAU CL 11'-312 11'-2 " 12" 23'-0" 9'-3" 13'-9" 2'-0" 10'-712" 2'-6" 11'-7" 12'-912"
11'-1" 7'-9" 15'-0" 3'-1112" 1'-512" KITCHEN LIVING PWD DINING 2ND FLR - 3C W/D 39'-6"
2'-0" 7'-512" 30'-012" 23'-0" 9'-3" 13'-9"
17'-612" 20'-612" 1'-5" 11'-312 11'-2 " 12" ROOF DECK 269 S.F. ROOF DECK - 3C 18'-1112" 19'-112" 1'-512"
2'-0" 16'-1112" 15'-112" 5'-5" 9'-3" 13'-9" 11'-312 11'-2 " 12" 18" X 25" 18" X 25" 18" X 25" PLAN 3C 4 BED/3BA/1PWD 1ST FL - 358 2ND FL - 864 3RD FL - 804 TOTAL LIVABLE - 2,026 S.F. ROOF DECK 269 S.F. GARAGE - 477 S.F. PAN LIN 18'-712" 2'-0" 42" HIGH SOLID PARAPET WALL AT AC CONDENSER 4'-1" PLAN 3C (DUPLEX - LOTS 21/50/53 ONLY) 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Drive Irvine, CA 92618 (949) 759-4367 0 4 8 12 APRIL 10, 2026 A6 299
3RD FLR BDRM 2 BDRM 1BA 1 FAU BDRM 3 LIN ROOF DECK 235 S.F. BA 2 CL ROOF DECK 4'-1" 18'-8" 13'-3" 9'-3" 13'-9"
19'-412" 16'-8" 2'-0" 12'-512 10'-6 " 12 12'-5 " 12 10'-6 " 12" 18'-812" 8'-3" 14'-9"
1'-512" 4'-012" 13'-112" 5'-8" 2'-312" 10'-11" 2'-0"
10'-912" 15'-8" 6'-5" 5'-312" 24'-9" W/D KITCHEN LIVING PWD PAN DINING2ND FLR12'-512 10'-6 " 12" 39'-6"
1'-5" 12'-11" 4'-312" 3'-512" 11'-5" 7'-512" 8'-3" 14'-9" 1ST FLR DEN 2 CAR GARAGE 20' X 20' CLR. WH 20'-3" REC ORG TRASH 39'-6"
2'-0" 19'-3" 1'-7" 4'-11" 1'-6" 10'-3" 23'-0" 23'-0" 8'-3" 14'-9" 20'-1"
120 CU. FT. STORAGE SHELVES PLAN 4 3BED/2BA+2PWD 1ST FL - 378 2ND FL - 875 3RD FL - 833 TOTAL LIVABLE - 2,086 S.F. ROOF DECK - 235 S.F. GARAGE - 473 S.F. 18" X 25" 18" X 25" 18" X 25" PWD 42" HIGH SOLID PARAPET WALL AT AC CONDENSER 8'-9" 3'-0"
2'-0" ENTRY PLAN 4 (DUPLEX) 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Drive Irvine, CA 92618 (949) 759-4367 0 4 8 12 APRIL 10, 2026 A7 300
20'-1" 3RD FLR W/D KITCHEN LIVING PWDPAN DINING 2ND FLR 14'-1012 5'-9 " 12" 26'-0"
1'-812" 11'-1" 3'-6" 5'-7" 9'-612" 5'-9" 17'-012" 7'-7" PLAN 5A 3BED/2BA+2PWD 1ST FL - 391 2ND FL - 888 3RD FL - 838 TOTAL LIVABLE - 2,117 S.F. GARAGE - 446 S.F. BDRM 2 BDRM 1 BA 1CL BA 2 FAUBDRM 3 37'-2 LIN 12" 17'-012" 7'-7" 12'-512 8'-2 " 12" 1'-1112" 10'-4" 2'-712" 7'-11" 14'-7" 1'-812" REC TR 2 CAR GARAGE 20' X 20' CLR. ORG WH 18" X 25" 18" X 25" 18" X 25" 120 CU.FT. STORAGE
RACK ABOVE 1ST FLR DEN 3'-1112" 20'-8" 3'-1112"
6'-212" 5'-0" 24'-912"
20'-612" 3'-612" 3'-312" 8'-112" 7'-7" 17'-012"
13'-512
10'-10 " 12" 2'-312" 5'-8" 7'-10" 12'-6"
20'-1" PWD
1'-812" ENTRY PLAN 5A (DUPLEX) 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Drive Irvine, CA 92618 (949) 759-4367 0 4 8 12 APRIL 10, 2026 A8 301
2 CAR GARAGE 20' X 20' CLR. KITCHEN LIVING DINING PAN BDRM 2 BDRM 1 BA 1 CL BA 2 BDRM 3 18" X 25" 18" X 25" 18" X 25" DEN PWD W/D 20'-1" 3RD FLR 2ND FLR 26'-0"
1'-812" 11'-1" 3'-6" 5'-7" 9'-612" 5'-9" 17'-012" 7'-7" PLAN 5B 3 BED/2.5BA+2PWD 1ST FL - 391 2ND FL - 888 3RD FL - 838 TOTAL LIVABLE - 2,117 S.F. GARAGE - 446 S.F. FAU 37'-212" 17'-012" 7'-7" 10'-512" 10'-212" 1'-1112" 10'-4" 2'-712" 7'-11" 14'-7" 1'-812" REC TR ORG WH 120 CU.FT. STORAGE
RACK ABOVE 1ST FLR 3'-1112" 20'-8" 3'-1112"
6'-212" 5'-0" 24'-912"
20'-612" 3'-612" 3'-312" 8'-112" 7'-7" 17'-012"
13'-2"
10'-1012" 2'-312" 5'-8" 7'-10" 12'-6"
20'-1" COATS
1'-1112" PWD
1'-812" ENTRY PLAN 5B (DETACHED LOTS 5/68 ONLY) 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Drive Irvine, CA 92618 (949) 759-4367 0 4 8 12 APRIL 10, 2026 A9 302
HIP 3:12 SOLAR TYP. 3:12 ROOF DECK
3:12 3:12 RIDGE SOLAR 3:12 TYP.
3:12 3:12
3:12 ROOF PLAN 3B ROOF PLAN - 3A
3:12 SOLAR TYP.
3:12
3:12 3:12 3:12 3:12 ROOF PLAN 5B DETACHED ROOF PLANS 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Drive Irvine, CA 92618 (949) 759-4367 0 4 8 12 APRIL 10, 2026 A10 303
PLAN 4 PLAN 1 PLAN 4 PLAN 1 PLAN 4 PLAN 1 2ND FLR - BLDG TYPE A 1ST FLR - BLDG TYPE A 3RD FLR - BLDG TYPE A 3:12 3:12
RIDGE SOLAR TYP. SOLAR TYP. 3:12
3:12 ROOF DECK ROOF DECKROOF PLAN - BLDG TYPE A PLAN 3C PLAN 4 3RD FLR - BLDG TYPE C 2ND FLR - BLDG TYPE C 1ST FLR - BLDG TYPE C HIP 3:12 3:12
RIDGE SOLAR TYP. SOLAR TYP. 3:12
3:12 ROOF DECK ROOF DECK HIP ROOF PLAN - BLDG TYPE C PLAN 3C PLAN 4 PLAN 3C PLAN 4 2ND FLR - BLDG TYPE B 1ST FLR - BLDG TYPE B 3RD FLR - BLDG TYPE B PLAN 2 PLAN 5A PLAN 2 PLAN 5A PLAN 2 PLAN 5A ROOF PLAN - BLDG TYPE B 3:12 3:12 RIDGE VALLEY 3:12 RIDGE 3:12 SOLAR TYP. SOLAR TYP. CRICKET 1:12
1:12 3:12 3:12 3:12
3:12
3:12 3:12 REFER TO SHEETS A2-A9 FOR UNIT FLOOR PLAN DIMENSIONS 2 CAR GARAGE 20' X 20' CLR.DEN PWD PWD PWD PWD PWD 2 CAR GARAGE 20' X 20' CLR. 2 CAR GARAGE 20' X 20' CLR. 2 CAR GARAGE 20' X 20' CLR. 2 CAR GARAGE 20' X 20' CLR. 2 CAR GARAGE 20' X 20' CLR. BA 3 BDRM 4 ENTRY DEN DEN DEN DENENTRY ENTRY ENTRY ENTRY ENTRY KITCHEN KITCHEN KITCHEN KITCHEN KITCHEN KITCHEN LAUN LAUN LAUN LAUN LAUN LAUN PWD PWD PWD PWD PWD PWD DINING DINING DINING DINING DINING DINING LIVING LIVING LIVING LIVING LIVING LIVING BDRM 2 BDRM 1BA 1 CL BA 2 BDRM 2 BDRM 3 BDRM 1 BA 1 BDRM 3 BA 2 CL BDRM 2 BDRM 1 BA 1CL BA 2 BDRM 3 BDRM 2 BDRM 1 BA 1 CL BA 2 BDRM 3 BDRM 2 BDRM 1BA 1 BDRM 3 BA 2 CL BDRM 2 BDRM 1 BA 2 BA 1 BDRM 3 CL DUPLEX TYPE A, B & C 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Drive Irvine, CA 92618 (949) 759-4367 APRIL 10, 2026 0 8 16 24 A11 304
PLAN 4 PLAN 1
35'-0" BLD'G. HT.
9'-1" 9'-1" 8'-6" 4 7 8 6 12 9 12 2 1 3 6 9 PLAN 4 13 PLAN 1 PLAN 4 11 9 PLAN 1 13 MATERIAL SCHEDULE 1. ROOF - ASPHALT SHINGLES 2. FASCIA - 2X RESAWN WOOD 3. 16/20 SAND FINISH STUCCO 4. HARDIE LAP SIDING - 6" EXPOSURE 5. DECORATIVE METAL RAILING 6. VINYL WINDOW W/ WHITE FRAME AND STUCCO TRIM 7. STUCCO CONTROL REGLET 8. EXTERIOR LIGHT FIXTURE 9. DECORATIVE METAL AWNING 10. DECORATIVE STUCCO EYEBROW 11. SECTIONAL GARAGE DOOR 12. COVERED ENTRY OR PORCH 13. WALL VINE ESPALIER DUPLEX TYPE A 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Drive Irvine, CA 92618 (949) 759-4367 APRIL 10, 2026 0 4 8 12 16 A12 PLAN 4 SIDE ELEVATION PASEO ELEVATION PLAN 1 SIDE ELEVATION DRIVE AISLE ELEVATION 305
PLAN 5A PLAN 2
35'-0" BLD'G. HT.
9'-1" 9'-1" 8'-6" 12 7 8 6 9 11 4 2 12 1 6 3 PLAN 5A PLAN 2 PLAN 5A 5'-0"
MIN.
5'-0"
MIN.
5'-0"
MIN.
5'-0"
MIN.
5'-0"
MIN.
5'-0"
MIN.
5'-0"
MIN. FROSTED GLASS AT 3RD FLOOR BEDROOM WINDOWS AT LOTS 11-20 AND 54-59 W/ 5' MIN. TO GLASS AT 2ND FLOOR WINDOWS * * * * * PLAN 2 MATERIAL SCHEDULE 1. ROOF - ASPHALT SHINGLES 2. FASCIA - 2X RESAWN WOOD 3. 16/20 SAND FINISH STUCCO 4. HARDIE LAP SIDING - 6" EXPOSURE 5. DECORATIVE METAL RAILING 6. VINYL WINDOW W/ WHITE FRAME AND STUCCO TRIM 7. STUCCO CONTROL REGLET 8. EXTERIOR LIGHT FIXTURE 9. DECORATIVE METAL AWNING 10. DECORATIVE STUCCO EYEBROW 11. SECTIONAL GARAGE DOOR 12. COVERED ENTRY OR PORCH 13. WALL VINE ESPALIER DUPLEX TYPE B 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Drive Irvine, CA 92618 (949) 759-4367 APRIL 10, 2026 A13 REAR - PRIVATE YARD ELEVATION PLAN 5A SIDE ELEVATION FRONT - DRIVE AISLE ELEVATION PLAN 2 SIDE ELEVATION 0 4 8 12 16 306
PLAN 3C
35'-0" BLD'G. HT.
9'-1" 9'-1" 8'-6" 4 7 10 6 1 6 7 9 2 8 3 6 5 PLAN 4 PLAN 4 PLAN 3C MATERIAL SCHEDULE 1. ROOF - ASPHALT SHINGLES 2. FASCIA - 2X RESAWN WOOD 3. 16/20 SAND FINISH STUCCO 4. HARDIE LAP SIDING - 6" EXPOSURE 5. DECORATIVE METAL RAILING 6. VINYL WINDOW W/ WHITE FRAME AND STUCCO TRIM 7. STUCCO CONTROL REGLET 8. EXTERIOR LIGHT FIXTURE 9. DECORATIVE METAL AWNING 10. DECORATIVE STUCCO EYEBROW 11. SECTIONAL GARAGE DOOR 12. COVERED ENTRY OR PORCH 13. WALL VINE ESPALIER PLAN 3C PLAN 4 11 9 DUPLEX TYPE C 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Drive Irvine, CA 92618 (949) 759-4367 APRIL 10, 2026 A14 PLAN 2C SIDE - ENTRY ELEVATION PASEO ELEVATION PLAN 3C SIDE - ENTRY ELEVATION DRIVE AISLE ELEVATION 0 4 8 12 16 307
35'-0" BLD'G. HT.
9'-1" 9'-1" 8'-6" 1 3 4 2 6 7
5'-0"
MIN. 9 MATERIAL SCHEDULE 1. ROOF - ASPHALT SHINGLES 2. FASCIA - 2X RESAWN WOOD 3. 16/20 SAND FINISH STUCCO 4. HARDIE LAP SIDING - 6" EXPOSURE 5. DECORATIVE METAL RAILING 6. VINYL WINDOW W/ WHITE FRAME AND STUCCO TRIM 7. STUCCO CONTROL REGLET 8. EXTERIOR LIGHT FIXTURE 9. DECORATIVE METAL AWNING 10. DECORATIVE STUCCO EYEBROW 11. SECTIONAL GARAGE DOOR 12. COVERED ENTRY OR PORCH 13. WALL VINE ESPALIER PL 3A ELEVATIONS 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Drive Irvine, CA 92618 (949) 759-4367 APRIL 10, 2026 A15 ENTRY ELEVATION PRIVATE YARD ELEVATION SIDE ELEVATION DRIVE AISLE ELEVATION 0 4 8 12 16 308
35'-0" BLD'G. HT.
9'-1" 9'-1" 8'-6" 7 1 2 9 8 3 6 5 9 MATERIAL SCHEDULE 1. ROOF - ASPHALT SHINGLES 2. FASCIA - 2X RESAWN WOOD 3. 16/20 SAND FINISH STUCCO 4. HARDIE LAP SIDING - 6" EXPOSURE 5. DECORATIVE METAL RAILING 6. VINYL WINDOW W/ WHITE FRAME AND STUCCO TRIM 7. STUCCO CONTROL REGLET 8. EXTERIOR LIGHT FIXTURE 9. DECORATIVE METAL AWNING 10. DECORATIVE STUCCO EYEBROW 11. SECTIONAL GARAGE DOOR 12. COVERED ENTRY OR PORCH 13. WALL VINE ESPALIER PL 3B ELEVATIONS 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Drive Irvine, CA 92618 (949) 759-4367 APRIL 10, 2026 A16 SIDE ELEVATION PASEO ELEVATION ENTRY ELEVATION DRIVE AISLE ELEVATION 0 4 8 12 16 309
35'-0" BLD'G. HT.
9'-1" 9'-1" 8'-6" 12 8 11 3 9 2 1 4
5'-0"
MIN.
5'-0"
MIN.
5'-0"
MIN.
5'-0"
MIN. MATERIAL SCHEDULE 1. ROOF - ASPHALT SHINGLES 2. FASCIA - 2X RESAWN WOOD 3. 16/20 SAND FINISH STUCCO 4. HARDIE LAP SIDING - 6" EXPOSURE 5. DECORATIVE METAL RAILING 6. VINYL WINDOW W/ WHITE FRAME AND STUCCO TRIM 7. STUCCO CONTROL REGLET 8. EXTERIOR LIGHT FIXTURE 9. DECORATIVE METAL AWNING 10. DECORATIVE STUCCO EYEBROW 11. SECTIONAL GARAGE DOOR 12. COVERED ENTRY OR PORCH 13. WALL VINE ESPALIER PL 5B ELEVATIONS 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Drive Irvine, CA 92618 (949) 759-4367 APRIL 10, 2026 A17 LEFT SIDE ELEVATION FRONT - DRIVE AISLE ELEVATION RIGHT SIDE ELEVATION PRIVATE YARD - REAR ELEVATION 0 4 8 12 16 310
SHADE/SHADOW EXHIBITS 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Drive Irvine, CA 92618 (949) 759-4367 APRIL 10, 2026 0 4 8 12 16 A18 3 PM - DEC 21 NOON - DEC 21 9 AM - DEC 21 3 PM - JUN 21 NOON - JUN 21 9 AM - JUN 21 311
EXISTING RETAIL EXISTING RETAIL EXISTING RETAIL EXISTING RETAIL EXISTING RETAIL EXISTING RETAIL EXISTING SHADOW EXHIBITS 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Drive Irvine, CA 92618 (949) 759-4367 APRIL 10, 2026 0 4 8 12 16 A19 3 PM - DEC 21 NOON - DEC 21 9 AM - DEC 21 3 PM - JUN 21 NOON - JUN 21 9 AM - JUN 21 312
35'-0" GARAGE DEN KITCHEN LIVING BDRM BATH CLOS. BDRM DINING ROOF DECK 35'-0" GARAGE DEN LIVING KITCHEN CLOS. HALL BDRM DINING 24'-312" PLAN 1 PLAN 4
3'-0" 6'-2"
6'-0" 2'-0"
2'-0"
30'-0"
24'-312"
3'-0"
24'-312"
3'-0" 6'-2"
30'-0" EAVE HT. EAVE HT. BLDG. HT. BLDG. HT. 2'-0" 2'-0" BEDROOM BEDROOM BEDROOM BEDROOM BEDROOM BEDROOM PLAN 2 PLAN 5A 6'-0" 2'-0"
2'-0" BEDROOM BEDROOM BEDROOM BEDROOM BEDROOM BEDROOM DUPLEX A DUPLEX B 24'-312"
3'-0" 6'-2" 2'-0" PLAN 1 PLAN 2 PLAN 3A
6'-0" 2'-0"
2'-0" BEDROOM BEDROOM BEDROOM DETACHED
35'-0" GARAGE BDRM LIVING KITCHEN BDRM BATH CL BDRM DINING 24'-312"
3'-0" 6'-2"
30'-0" EAVE HT. BLDG. HT. 2'-0" PLAN 3A 2'-0" 6'-2" 2'-0" 6'-2" 24'-312" LADDER PAD SECTIONS 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Drive Irvine, CA 92618 (949) 759-4367 APRIL 10, 2026 0 4 8 12 16 A20 313
GARAGE BDRM LIVING KITCHEN BDRM BATH CL BDRM DINING ROOF DECK PLAN 3B PLAN 3C PLAN 4 6'-0" 2'-0"
2'-0"
6'-0" 2'-0"
2'-0"
24'-312"
3'-0" 6'-2"
30'-0" EAVE HT. 2'-0" BEDROOM BEDROOM BEDROOM BEDROOM BEDROOM BEDROOM BEDROOM BEDROOM BEDROOM DUPLEX C DETACHED DETACHEDPLAN 5B GARAGE DEN LIVING KITCHEN BDRM BATH BDRM DINING 24'-312"
3'-0" 8'-2"
30'-0"
3'-0" EAVE HT. 2'-0" PLAN 3B & 3C PLAN 5A & 5BCL GARAGE BDRM LIVING KITCHEN BDRM BATH CLOS. BDRM DINING ROOF DECK 24'-312"
3'-0" 6'-2"
30'-0" EAVE HT. 2'-0" PLAN 4 CL
35'-0" BLDG. HT. 2'-0" 6'-2"
24'-312"
35'-0" BLDG. HT. 2'-0" 6'-2"
24'-312"
35'-0" BLDG. HT. 2'-0" 6'-2"
24'-312" BEDROOM BEDROOM BEDROOM LADDER PAD SECTIONS 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Drive Irvine, CA 92618 (949) 759-4367 APRIL 10, 2026 0 4 8 12 16 A21 314
GARAGE DEN KITCHEN LIVING BDRM BATH CLOS. BDRM DINING LOT 59 DRIVE AISLE OPEN PARKING/ TRASH ENCLOSURE MULTI-FAMILY DWELLING PRIVATE YARD 63'-6" PRIVATE YARD GARAGE BLDG. BEYOND 5'-0" 5'-0" FROSTED GLASS AT 3RD FLOOR BEDROOM WINDOWS AT LOTS 54-59 5' MIN. TO GLASS AT 2ND FLOOR WINDOWS TREES BETWEEN LOTS - REFER TO LANDSCAPE PLANS * * STOP //// 1 STORY GARAGE 1 STORY GARAGE 1 STORY GARAGE TRASH ENCL. 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY GARAGE 1 STORY GARAGE 1 STORY MOBILE HOME 1 STORY MOBILE HOME 1 STORY MOBILE HOME 1 STORY MOBILE HOME 1 STORY MOBILE HOME DRIVE AISLE

DRIVE AISLE
DRIVE AISLE 1 STORY MULTI-FAMILY NO WINDOWS NO WINDOWS PRIVATE YARDS PRIVATE YARDS PRIVATE YARDS PRIVATE YARDS PARK 72 CONDOMINIUMS DRIVE AISLE DRIVE AISLE DRIVE AISLE DRIVE AISLE COCO PALMS CONDOMINIUMS ORANGE MOBILE HOME PARK VIEWS OF ADJACENT MULTI-FAMILY DWELLING NORTH OF LOT 59 LINE OF SIGHT - NORTH SIDE SECTION A - PARK 72 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Drive Irvine, CA 92618 (949) 759-4367 APRIL 10, 2026 0 6 12 18 A22.1 SECTION A KEY PLAN (NO SCALE) A 315
STOP //// 1 STORY GARAGE 1 STORY GARAGE 1 STORY GARAGE TRASH ENCL. 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY GARAGE 1 STORY GARAGE 1 STORY MOBILE HOME 1 STORY MOBILE HOME 1 STORY MOBILE HOME 1 STORY MOBILE HOME 1 STORY MOBILE HOME DRIVE AISLE

DRIVE AISLE
DRIVE AISLE 1 STORY MULTI-FAMILY NO WINDOWS NO WINDOWS PRIVATE YARDS PRIVATE YARDS PRIVATE YARDS PRIVATE YARDS PARK 72 CONDOMINIUMS DRIVE AISLE DRIVE AISLE DRIVE AISLE DRIVE AISLE COCO PALMS CONDOMINIUMS ORANGE MOBILE HOME PARK PRIVATE DRIVE AISLE GARAGE BUILDING YARD 35'-0" PRIVATE MULTI-FAMILY DWELLING YARD GARAGE DEN KITCHEN LIVING BDRM BATH CLOS. BDRM DINING 5'-0" 5'-0" LOT 64 5' MIN. TO GLASS AT 2ND FLOOR WINDOWS TREES BETWEEN LOTS - REFER TO LANDSCAPE PLANS * VIEWS OF ADJACENT GARAGES NORTH OF LOT 64 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Drive Irvine, CA 92618 (949) 759-4367 APRIL 10, 2026 0 6 12 18 A22.2 KEY PLAN (NO SCALE) SECTION B B LINE OF SIGHT - NORTH SIDE SECTION B - PARK 72 316
STOP //// 1 STORY GARAGE 1 STORY GARAGE 1 STORY GARAGE TRASH ENCL. 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY GARAGE 1 STORY GARAGE 1 STORY MOBILE HOME 1 STORY MOBILE HOME 1 STORY MOBILE HOME 1 STORY MOBILE HOME 1 STORY MOBILE HOME DRIVE AISLE

DRIVE AISLE
DRIVE AISLE 1 STORY MULTI-FAMILY NO WINDOWS NO WINDOWS PRIVATE YARDS PRIVATE YARDS PRIVATE YARDS PRIVATE YARDS PARK 72 CONDOMINIUMS DRIVE AISLE DRIVE AISLE DRIVE AISLE DRIVE AISLE COCO PALMS CONDOMINIUMS ORANGE MOBILE HOME PARK GARAGE BUILDING DRIVE AISLE PRIVATE YARD 43'-9" MULTI-FAMILY DWELLING PRIVATE YARD GARAGE DEN LIVING KITCHEN BDRM CLOS. BATH BDRM DINING 5'-0" 5'-0" LOT 9 TREES BETWEEN LOTS - REFER TO LANDSCAPE PLANS 5' MIN. TO GLASS AT 2ND FLOOR WINDOWS * VIEWS OF ADJACENT GARAGES SOUTH OF LOT 9 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Drive Irvine, CA 92618 (949) 759-4367 APRIL 10, 2026 0 6 12 18 A22.3 KEY PLAN (NO SCALE) SECTION C C LINE OF SIGHT - SOUTH SIDE SECTION C - COCO PALMS 317
GARAGE DEN LIVING KITCHEN BDRM CLOS. BATH BDRM DINING MULTI-FAMILY DWELLING OPEN PARKING DRIVE AISLE LOT 12 PRIVATE YARD 61'-10" 5'-0" 5'-0" ROOF DECK BDRM BDRM LIVING GARAGE DEN BATH LAUN PWDR FROSTED GLASS AT 3RD FLOOR BEDROOM WINDOWS AT LOTS 11-20 5' MIN. TO GLASS AT 2ND FLOOR WINDOWS DRIVE AISLE LOT 27 TREES BETWEEN LOTS - REFER TO LANDSCAPE PLANS * * 5'-0" STOP //// 1 STORY GARAGE 1 STORY GARAGE 1 STORY GARAGE TRASH ENCL. 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY GARAGE 1 STORY GARAGE 1 STORY MOBILE HOME 1 STORY MOBILE HOME 1 STORY MOBILE HOME 1 STORY MOBILE HOME 1 STORY MOBILE HOME DRIVE AISLE

DRIVE AISLE
DRIVE AISLE 1 STORY MULTI-FAMILY NO WINDOWS NO WINDOWS PRIVATE YARDS PRIVATE YARDS PRIVATE YARDS PRIVATE YARDS PARK 72 CONDOMINIUMS DRIVE AISLE DRIVE AISLE DRIVE AISLE DRIVE AISLE COCO PALMS CONDOMINIUMS ORANGE MOBILE HOME PARK VIEWS OF ADJACENT MULTI-FAMILY DWELLINGS SOUTH OF LOT 12 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Drive Irvine, CA 92618 (949) 759-4367 APRIL 10, 2026 0 6 12 18 A22.4 SECTION D KEY PLAN (NO SCALE) D LINE OF SIGHT - SOUTH SIDE SECTION D - COCO PALMS 318
GARAGE DEN LIVING KITCHEN BDRM CLOS. BATH BDRM DINING DETACHED MOBILE HOME PRIVATE LOT 20 YARD PRIVATE YARD 21'-0" 5'-0" 5'-0" FROSTED GLASS AT 3RD FLOOR BEDROOM WINDOWS AT LOTS 11-20 TREES BETWEEN LOTS - REFER TO LANDSCAPE PLANS 5' MIN. TO GLASS AT 2ND FLOOR WINDOWS * * STOP //// 1 STORY GARAGE 1 STORY GARAGE 1 STORY GARAGE TRASH ENCL. 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY MULTI-FAMILY 1 STORY GARAGE 1 STORY GARAGE 1 STORY MOBILE HOME 1 STORY MOBILE HOME 1 STORY MOBILE HOME 1 STORY MOBILE HOME 1 STORY MOBILE HOME DRIVE AISLE

DRIVE AISLE
DRIVE AISLE 1 STORY MULTI-FAMILY NO WINDOWS NO WINDOWS PRIVATE YARDS PRIVATE YARDS PRIVATE YARDS PRIVATE YARDS PARK 72 CONDOMINIUMS DRIVE AISLE DRIVE AISLE DRIVE AISLE DRIVE AISLE COCO PALMS CONDOMINIUMS ORANGE MOBILE HOME PARK VIEW OF MOBILE HOMES SOUTH OF LOT 20 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE 2375 N. TUSTIN ST. - DETACHED/DUPLEX HOMES MELIA HOMES 9860 Irvine Center Drive Irvine, CA 92618 (949) 759-4367 APRIL 10, 2026 0 6 12 18 SECTION E KEY PLAN (NO SCALE) E LINE OF SIGHT - SOUTH SIDE SECTION E - ORANGE MOBILE HOMESA22.5 319
Schematic Landscape Plan
2375 Tustin St., Orange
Melia Homes
Project No.: MH25-D
Date: Dec. 16, 2025
Schematic 3rd Submittal
16 L-1
Central community open space area with enhanced paving courtyard, palm trees, shade sail overhead covers, and artificial turf for small social events and group gatherings.

Six community cluster mailboxes, per USPS review and approval.

Proposed wall, pilaster, gate or fence, per Wall & Fence Plan.

Proposed 20' wide access slide gate with depressed curve for vehicle access.

Automated Emergency Vehicle Access gate.

Enhanced paving at main project entry.

Proposed tree, per Planting Plan.
5' wide community natural colored concrete sidewalk, with light top-cast finish and saw-cut joints.
4' wide unit entry natural colored concrete walk, with light top-cast finish and saw-cut joints.

Accessible parking stall and striping, per Civil plans.

Guest parking stall.

12. Natural colored concrete driveway, with light broom finish and tooled joints.

13. 11.

10. 5.

9. 8.

7. 6.

4. 3.

2. 1.

LEGEND

14. 15.

16. 17.

18. 19.

20. 21.

22. 23.

Private patio / yard area, homeowner maintained.

Common area landscape, builder installed and HOA maintained.

Community dog bag station (black in color), for pet owners.

Property line.

Public street R.O.W.

Proposed public street sidewalk, per Civil plans.

Transformer to be screened with landscape, quantity and final locations to be determined.

Short term bike parking (1 bike rack to accommodate 2 bike stalls).

Modular wetland, per Civil plans.

Proposed AC condenser locations, per Architecture plans.

Existing landscape to remain in addition to new utility screen plantings. 6 *Conceptual images (provided herein are conceptual and subject to change) 60' Scale: 1" = 30'
0 15' 30'
16 16
4 1
1 2
3 3
5 6
8 8
9 9
9 10
11 11
11 12
12 12
14 14 23
14 16
16 17
18 18
19 19
19 19
7 19
20 21
22 22
22 2 15 20
15 19
3 7
9 13
13 16
14 16
17 17
320
Schematic Enlargement Plan - Central Open Space
2375 Tustin St., Orange
Melia Homes
Project No.: MH25-D
Date: Dec. 16, 2025
Schematic 3rd Submittal L-2
16'
Scale: 1/8" = 1'-0"
0 4' 8'
7 *Conceptual images (provided herein are conceptual and subject to change) 4 *Conceptual images (provided herein are conceptual and subject to change) Shade sail
overhead covers.
2 3 Picnic table seating.

Mailbox & parcel lockers.

Bike rack.

Modular wetland.

Dog bag station.
4 Enhanced paving.
3 2
1 6 Palms lining community
open space area.
7 Deciduous
flowering trees.
6 Artificial turf. 1
Specimen tree. 5
Irrigation submeter with
dual irrigation controller
and electrical pedestal
on stainless steel box.
5 321
POOL
ONLY

STOP THRU DRIVE THRU DRIVE
STOP
STOP
METER 2"-4" 4''FW
4''SS
2''W 2''W 2''W 2''W 6''SD
6''SD 6''SD
>
>
>
>
>
>
>
6''W 6''W 6''W 6''W 6''W 12''SD
METER METER 8''SD 12''FW 12''FW 12''FW
E E

E DIEBOLD ATM/ATA Z
||
T
>
> > > > > > >
> > >
Z
Z
Limit of Work
Limit of Work
Limit of Work Limit of Work Limit of Work N T U S T I N S T // // // //
// // //
Limit of Work

WALL, FENCE & GATE LEGEND
Existing ± 6'-0" High property line wall, protect in place.

Existing ± 8'-0" High Gray Precision property line wall by adjacent bank property, protect in place. 8'-0" New High precision block wall with rolled mortar cap, to match existing walls (tan color). 6'-0" New High precision block wall with 2" high precision cap (tan color). 3'-0" New Low precision block wall with 2" high precision cap (tan color). 5'-6" New High vinyl private yard gate (tan color).
8'-0" New High entry stucco pilaster with enhanced concrete cap and metal signage. 3'-6" New Low stucco pilaster with enhanced concrete cap (open space). ±8'-0" New High Sliding metal vehicular maintenance access gate (color to match wall). ±7'-0" New High Auto Emergency vehicle access metal gate (14' wide ea. gate for 26' total width, black color).

New Metal Wall Trellis vines.

ADA Path of Travel Schematic Wall & Fence Plan
2375 Tustin St., Orange
Melia Homes
Project No.: MH25-D
Date: Dec. 16, 2025
Schematic 3rd Submittal L-3
60'
Scale: 1" = 30'
0 15' 30'
Existing Gray Precision
wall by adjacent bank,
protect in place.

Existing Tan Precision wall
20' wide access
slide gate with
depressed curve
for vehicle access.
*Conceptual images (provided herein are conceptual and subject to change) Automated Emergency Vehicle
Access gate.
8' High screen wall to buffer noise
along the freeway.
3 4 5 6
8 7 9
Note:

Perimeter walls on west side of site must be coated with an anti-graffiti paint or have faux vegetation installed to counter potential vandalism/graffiti.

Existing Tan Precision wall
1 3
2 4
1 5
6 7
8 2
9 10
10 Property Line.
322

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Lagerstroemia indica x fauriei 'Natchez'
Jacaranda mimosifolia (Jacaranda)
Type/Form

PLANTING LEGEND
PALMS
Symbol
Deciduous
Specimen
Trunk
Multi
Botanical Name (Common Name)
Suggestions
Single
Flowering
Evergreen Arbutus unedo 'Marina' (Marina Strawberry Tree) Single Flowering
Size
36" Box
15 Gal.
24" Box
Vertical Phoenix dactylifera (Date Palm) Single 10' BT
TREES
Focal Magnolia grandiflora 'Little Gem (Southern Magnolia) Single 24" Box Low
Mod.

Low
(R3)
WUCOLS
Qty.
2 24
32 Low 3
Mod. 2
(Crape Myrtle)
Lophostemon confertus (Brisbane Box)
Laurus nobilis 'Columnar' (Sweet Bay)
Street
Columnar
Medium
Single
Single
Geijera parvilflora (Australian Willow) Single
24" Box
15 Gal.
15 Gal.

Low
Low
5 5
Low 53
TOTAL= 126
Vines Macfadyena unguis-cati (Cat's Claw Vine) -
VINES
15 Gal. Low 15
Artificial Turf - -

GROUNDCOVER
- - 1,835 SF
Type/Form

PLANTING LEGEND
PALMS
Symbol Trunk
Botanical Name (Common Name)
Suggestions Size (R3)
WUCOLS
Qty. Type/Form

PLANTING LEGEND
PALMS
Symbol Trunk
Botanical Name (Common Name)
Suggestions Size (R3)
WUCOLS
Qty.

Utility Screen Laurus nobilis (Bay Laurel) Single
SHRUBS
U 15 Gal. Low 83

BOTANICAL NAME COMMON NAME SIZE WUCOLS SPACING
SHRUBS
Agave x `Blue Flame` Blue Flame Agave 15 g Low 36" o.c.

Aloe x `Blue Elf` Aloe 1 g Low 24" o.c.

Anigozanthos x 'Big Red' Big Red Kangaroo Paw 5 g Low 24" o.c.

Callistemon viminalis `Little John` Dwarf Weeping Bottlebrush 5 g Low 36" o.c.

Dianella revoluta Little Rev Flax Lily 1 g Low 18" o.c.

Hesperaloe parviflora `Brake Lights` `Brake Lights` Red Yucca 1 g Low 36" o.c.

Laurus nobilis
Plant leaf to leaf. Evergreen shrub
for utility screen, Columnar.

Sweet Bay 15 g Low 36" o.c.

Lavandula stoechas `Silver Anouk` Spanish Lavender 5 g Low 30" o.c.

Muhlenbergia rigens Deer Grass 5 g Low 36" o.c.

Salvia clevelandii Cleveland Sage 5 g Low 48" o.c.

Salvia greggii `Furmans Red` Furman`s Red Salvia 5 g Low 24" o.c.

Salvia leucantha `Santa Barbara` Mexican Bush Sage 5 g Low 48" o.c.

Westringia fruticosa `Blue Gem` `Blue Gem` Coast Rosemary 15 g Low 36" o.c.

Westringia fruticosa `Low Horizon` Groundcover Coast Rosemary 5 g Low 24" o.c.

Westringia fruticosa `Morning Light` `Morning Light` Coast Rosemary 5 g Low 36" o.c.

GROUND COVERS
Carex divulsa Berkeley Sedge 1 g Low 24" o.c
Lantana x `New Gold` New Gold Lantana 1 g Low 36" o.c.

Salvia x 'Bee's Bliss' Bee's Bliss Sage 1 g Low 60" o.c.

Westringia fruticosa `Low Horizon` Low Horizon Coast Rosemary 1 g Low 36" o.c.

SHRUB & GROUNDCOVER SCHEDULE
Schematic Planting Plan
2375 Tustin St., Orange
Melia Homes
Project No.: MH25-D
Date: Dec. 16, 2025
Schematic 3rd Submittal L-4
NOTES:

1. Irrigation (including spray and/or drip) will be provided, in the Construction Document phase, and to be installed per local California water regulations (AB1881) .

2. Transformers, back-flow preventers & other above-ground utilities to be screened with landscape as permitted per local codes & regulations.

3. The plant palette listed provides a list of plant material to select from when preparing final landscape construction documents for this project. However, substitutions may be required due to availability, soils tests, or other conditions.

4. All trees within 5' of hardscape to be installed with deep root barriers.

5. Refer to lighting plans for site lighting and ambient enhanced lighting.

6. 12 existing palms to be retained at site entry and 73 trees on-site to be removed.

7. Locations and quantities of shrubs and groundcover to be determined in final design. 60'
Scale: 1" = 30'
0 15' 30'
Existing landscape to remain
in addition to new utility
screen plantings.
12 Existing Palms lining
site entry to remain.
323
Plant Images - Trees
2375 Tustin St., Orange
Melia Homes
Project No.: MH25-D
Date: Dec. 16, 2025
Schematic 3rd Submittal L-5A
Geijera parviflora
Australian Willow
Lophostemon confertus
Brisbane Box
Arbuts unedo 'Marina'
Marina Strawberry Tree
Magnolia grandiflora 'Little Gem'
Southern Magnolia
Jacaranda mimosifolia
Jacaranda
Phoenix dactylifera
Date Palm
Laurus nobilis
Sweet Bay
Lagerstroemia indica x fauriei 'Natchez'
Crape Myrtle
324
Plant Images - Shrubs & Groundcover
2375 Tustin St., Orange
Melia Homes
Project No.: MH25-D
Date: Dec. 16, 2025
Schematic 3rd Submittal L-5B
Westringia fruticosa 'Morning Light'
Morning Light Coast Rosemary
Aloe x 'Blue Elf'
Aloe
Anigozanthos x 'Big Red'
Kangaroo Paw
Callistemon viminalis 'Little John'
Dwarf Weeping Bottlebrush
Lantana 'New Gold'
New Gold Lantana
Lavandula stoechas 'Silver Anouk'
Spanish Lavender
Muhlenbergia rigens
Deer Grass
Salvia clevelandii
Cleveland Sage
Dianella 'Little Rev'
Flax Lily
Hesperaloe parviflora
Red Yucca
Salvia gregii 'Furmans Red'
Furman's Red Salvia
Salvia leucantha 'Santa Barbara'
Mexican Bush Sage
Carex divulsa
Berkeley Sage
Agave x 'Blue Flame'
Blue Flame Agave
Laurus nobilis
Sweet Bay
Westringia fruticosa 'Blue Gem'
Blue Gem Coast Rosemary
Westringia fruticosa 'Low Horizon'
Groundcover Coast Rosemary
Salvia x 'Bee's Bliss'
Bee's Blish Sage
SHRUBS

GROUNDCOVERS
325
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SHRUBS & GROUNDCOVER AREA
Takeoff: 30,330 sf

SHRUB & GROUNDCOVER LEGEND
Schematic Shrub and Groundcover Area Plan
2375 Tustin St., Orange
Melia Homes
Project No.: MH25-D
Date: Dec. 16, 2025
Schematic 3rd Submittal L-6
60'
Scale: 1" = 30'
0 15' 30'
Shrub & Groundcover Landscape Calculations:

Total Site Area
Shrub & Groundcover Area
184,499 SF
30,330 SF (16.4% of total site)
4'-2"
4'-0"
4'-11"
4'-0"
5'-5" 10'-0"
Artificial turf.
326
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TO REMAIN

TO REMOVE

EXISTING TREE LEGEND
Schematic Existing Tree Plan
2375 Tustin St., Orange
Melia Homes
Project No.: MH25-D
Date: Dec. 16, 2025
Schematic 3rd Submittal L-7
60'
Scale: 1" = 30'
0 15' 30'
NOTES:

1. 12 existing palms to be retained at site entry and 73 trees on-site to be removed. 327
POOL
ONLY

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METER 2"-4" 4''FW
4''SS
2''W 2''W 2''W 2''W 6''SD
6''SD 6''SD
>
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>
>
>
>
>
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METER METER 8''SD 12''FW 12''FW 12''FW
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PRIVATE REAR YARD AREAS
Takeoff: 11,436 sf

PUBLIC PERMEABLE LANDSCAPE AREAS
Takeoff: 30,309 sf

PERMEABLE AREA LEGEND
Schematic Permeable Area Plan
2375 Tustin St., Orange
Melia Homes
Project No.: MH25-D
Date: Dec. 16, 2025
Schematic 3rd Submittal L-8
60'
Scale: 1" = 30'
0 15' 30'
Permeable Area Landscape Calculations:

Total Site Area
Private Rear Yard Area
Public Permeable Landscape Area
184,499 SF
11,436 SF (6.2% of total site)
30,309 SF (16.4% of total site)
4'-2"
4'-0"
4'-11"
4'-0" 7'-8"
5'-5"
30'-7" 60'-0" 10'-0"
328

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METER METER 8''SD 12''FW 12''FW 12''FW
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D
A
C
B
Schematic Photometric Lighting Plan
2375 Tustin St., Orange
Melia Homes
Project No.: MH25-D
Date: Dec. 16, 2025
Schematic 3rd Submittal L-9A
60'
Scale: 1" = 30'
0 15' 30'
NOTES:

1. Proposed site lighting & Landscape lighting (landscape up-lights, path lights/bollards, etc.) to be coordinated, with Electrical Engineer in future Construction Documents phase.

2. Refer to Low Voltage lighting plan for 12V fixtures.

3. Proposed lighting specifications are subject to change and dependant future Electrical Engineer's drawings as well as product availability.

4. Parking lot light fixtures and light fixtures on buildings shall be full cut-off fixtures.

5. Outdoor lighting standards for multi-family uses. The average maintained lighting levels for multi-family units shall meet the following:

5.1.2. 1.0 foot-candles at parking lots & other parking areas.

5.1.3. 0.5 foot-candles at drive lanes & alleys.

5.1.4. 0.5 foot-candles at amenity areas and on-site walkways.

The existing entry drive consists of installed
lighting (north of entry drive) as well as approved
/ proposed site lighting for the Bank Parcel
(south of entry drive).

A
B
C
D
329
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METER METER 8''SD 12''FW 12''FW 12''FW
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PHOTO SYMBOL MANUFACTURER/MODEL/DESCRIPTION QTY
Wall Light - FX Luminaire XW-70
Die-cast aluminum high-output wall wash light
with adjustable body. IP67 rated.

Order code: XW-70, Aluminum, (BZ) Bronze
Metallic, 3-Prong Spike
Lamp: XW-70-H1, 18W / 23VA, 2700K,
Beamspread: Ultra Wide Flood
1 GFCI - Outlet
Exterior Electrical GFI Outlet [120V]
Exterior Grade, Staked or Wall, Location per
Electrical Engineer`s dwgs.

Accessories: Location per Electrical Engineer`s
dwgs.
2 LIGHTING SCHEDULE
Transformer - PX - 300 - TPC - BZ
Low-voltage transformer - FX luminair. model
#PX - 300 - TPC - BZ.

Cast Aluminum, Metallic Bronze., Wall, Install
with Mechanical Transformer Timer (#15557BK
& Plug-In Transformer Remote Photocell
(#15534K).

Lamp: 300W, 300W
1 Palm Uplight - FX Luminaire FC-RG
Large scale in grade fixture. 4in. Dia x 4.8in. H.

Order code: FC-RG, Aluminum Alloy, (BZ)
Bronze Metallic, Direct Mount
Lamp: FC-RG-1LED, 2W / 2.4VA, 2700K,
Beamspread: Spot
3 T
Schematic Lighting Plan (Low Voltage 12v)
2375 Tustin St., Orange
Melia Homes
Project No.: MH25-D
Date: Dec. 16, 2025
Schematic 3rd Submittal L-9B
60'
Scale: 1" = 30'
0 15' 30'
NOTES:

1. Landscape lighting (landscape up-lights, path lights/bollards, etc.) to be coordinated with Electrical Engineer in future phase.

2. Refer to Photometrics Lighting Plan for site safety lighting levels. 330
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O R T O R T

O R T O R T O R T O R T O R T O R T O R T O R T O R T O R T O R T O R T O R T O R T O R T

O T R O T R O T R O T R

O R T O R T O R T O R T O R T O R T O R T O R T O R T O R T O R T O R T O R T

O R T O R T O R T O R T O R T O R T O R T O R T O R T O R T O R T O R T O R T O R T O R T

O R T O R T O R T O R T O R T O R T O R T O R T O R T O R T O R T O R T O R T O R T O R T O R T O R T O R T O R T O T R
O R T
O R T
LEGEND
Regular trash cart. (35 gallon)
Recycle cart. (35 gallon)
Organic cart. (35 gallon)
Trash hauler path of travel.

O
T
R
Schematic Trash Cart Layout & Hauler Circulation Plan
2375 Tustin St., Orange
Melia Homes
Project No.: MH25-D
Date: Dec. 16, 2025
Schematic 3rd Submittal L-10
60'
Scale: 1" = 30'
0 15' 30'
NOTES:

1. All carts to be located outside Fire Department turning radii.

2. Trash, recyclables, and organics collected by CR&R Environmental Services.

3. All carts shall be labeled to identify the unit/address number. 331
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METER METER 8''SD 12''FW 12''FW 12''FW
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HYDROZONE 1
Takeoff: 30,282 sf

IRRIGATION SCHEDULE - HYDROZONES
Schematic Irrigation Hydrozone Plan
2375 Tustin St., Orange
Melia Homes
Project No.: MH25-D
Date: Dec. 16, 2025
Schematic 3rd Submittal L-11
60'
Scale: 1" = 30'
0 15' 30'
Dual irrigation controller and electrical
pedestal on stainless steel box.

Artificial turf.

HOA low water use shrubs and groundcover with in-line emitter drip irrigation. Plant factor = 0.3, irrigation efficiency factor = 0.8. Low water use trees with in-line emitter drip irrigation. Plant factor = 0.5, irrigation efficiency factor 0.8.
332

CAR STOP

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0 1" = 40'
20 40 80
VESTING TENTATIVE TRACT NO. 19392
2375 NORTH TUSTIN STREET

CITY OF ORANGE, COUNTY OF ORANGE

STATE OF CALIFORNIA
PLANNING LAND USE APPLICATION No. GPA25-0003 - DRC25-0019, ENV25-0001, MJSP25-0002, TTM25-0001, ZC25-0002, SMALL LOT ORDINANCE 333
//
// // //
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2''W 2''W 2''W 2''W 6''SD
6''SD 6''SD
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0 1" = 30'
15 30 60
VESTING TENTATIVE TRACT NO. 19392
2375 NORTH TUSTIN STREET

CITY OF ORANGE, COUNTY OF ORANGE

STATE OF CALIFORNIA
PLANNING LAND USE APPLICATION No. GPA25-0003 - DRC25-0019, ENV25-0001, MJSP25-0002, TTM25-0001, ZC25-0002, SMALL LOT ORDINANCE 334
//
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4''SS
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6''SD 6''SD
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0 1" = 30'
15 30 60
VESTING TENTATIVE TRACT NO. 19392
2375 NORTH TUSTIN STREET

CITY OF ORANGE, COUNTY OF ORANGE

STATE OF CALIFORNIA
PLANNING LAND USE APPLICATION No. GPA25-0003 - DRC25-0019, ENV25-0001, MJSP25-0002, TTM25-0001, ZC25-0002, SMALL LOT ORDINANCE 335
POOL
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STOP THRU DRIVE THRU DRIVE
STOP

STOP //
// // //
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4''SS
2''W 2''W 2''W 2''W 6''SD
6''SD 6''SD
>
>
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0 1" = 30'
15 30 60
VESTING TENTATIVE TRACT NO. 19392
2375 NORTH TUSTIN STREET

CITY OF ORANGE, COUNTY OF ORANGE

STATE OF CALIFORNIA
PLANNING LAND USE APPLICATION No. GPA25-0003 - DRC25-0019, ENV25-0001, MJSP25-0002, TTM25-0001, ZC25-0002, SMALL LOT ORDINANCE 336
VESTING TENTATIVE TRACT NO. 19392
2375 NORTH TUSTIN STREET

CITY OF ORANGE, COUNTY OF ORANGE

STATE OF CALIFORNIA
PLANNING LAND USE APPLICATION No. GPA25-0003 - DRC25-0019, ENV25-0001, MJSP25-0002, TTM25-0001, ZC25-0002, SMALL LOT ORDINANCE 337
2375 NORTH TUSTIN STREET

CITY OF ORANGE, COUNTY OF ORANGE

STATE OF CALIFORNIA
PRELIMINARY FIRE MASTER PLAN - VTTM 19392
0 1" = 60'
30 60 120
NO

PARKING

BEYOND THIS POINT

EXCEPT IN

DESIGNATED STALLS

VIOLATING VEHICLES

WILL BE CITED

OR TOWED AT
OWNER’S EXPENSE
CVC 22500.1, 22658(a)

FIRE LANE
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ONLY

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THRU
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STOP // //
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6''FW
2''W 2''W 2''W 2''W 2''W 2''W 2''W
> > > >
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6''W 6''W 6''W 6''W 6''W 6''W 6''W 6''W 12''FW 12''FW 12''FW 12''FW

E E E E
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338
········
339
340
341
342

NORTH TUSTIN STREET RESIDENTIAL PROJECT
FINAL

INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
NO. ENV25-0001
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:
949-346-4633
[email protected]
Date:

March 2026
Attachment 7
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TABLE OF CONTENTS
CHAPTER 1: PUBLIC REVIEW INITIAL STUDY/MITIGATED NEGATIVE DECLARATION ......1 CHAPTER 2: RESPONSE TO COMMENTS ON THE PUBLIC REVIEW IS/MND.................. ........2-1 CHAPTER 3: REVISIONS TO THE PUBLIC REVIEW IS/MND .......................................................3-1 CHAPTER 4: MITIGATION MONITORING AND REPORTING PROGRAM .................................4-1 345
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346
CHAPTER 1

NORTH TUSTIN STREET RESIDENTIAL PROJECT

PUBLIC REVIEW

INITIAL STUDY/MITIGATED NEGATIVE
DECLARATION NO. ENV25-0001
Lead Agency:

January 2026
347
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348
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TABLE OF CONTENTS
INTRODUCTION .................................................................................................................................... 1 EXISTING SETTING .............................................................................................................................. 2 Regional Setting.................................................................................................................................... 2 Existing Site Conditions....................................................................................................................... 2 Existing Land Uses and Zoning Designation ....................................................................................... 2 Surrounding Land Uses ........................................................................................................................ 2 PROJECT DESCRIPTION .................................................................................................................... 15 Project Overview ................................................................................................................................ 15 Project Features .................................................................................................................................. 15 Project Construction ........................................................................................................................... 17 Discretionary and Ministerial Actions................................................................................................ 18 Scheduled Public Meetings or Hearings:............................................................................................ 18 CHECKLIST OF ENVIRONMENTAL IMPACT ISSUES:................................................................. 47 AESTHETICS. ................................................................................................................................... 47 AGRICULTURE & FOREST RESOURCES.................................................................................... 52 AIR QUALITY................................................................................................................................... 54 BIOLOGICAL RESOURCES............................................................................................................ 60 CULTURAL RESOURCES............................................................................................................... 63 ENERGY. ........................................................................................................................................... 65 GEOLOGY AND SOILS. .................................................................................................................. 69 GREENHOUSE GAS EMISSIONS................................................................................................... 75 HAZARDS AND HAZARDOUS MATERIALS. ............................................................................. 83 HYDROLOGY AND WATER QUALITY. ...................................................................................... 88 LAND USE/PLANNING. .................................................................................................................. 96 MINERAL RESOURCES................................................................................................................ 102 NOISE............................................................................................................................................... 103 POPULATION AND HOUSING..................................................................................................... 123 PUBLIC SERVICES. ....................................................................................................................... 125 RECREATION................................................................................................................................. 129 TRANSPORTATION....................................................................................................................... 131 TRIBAL CULTURAL RESOURCES. ............................................................................................ 141 UTILITIES/SERVICE SYSTEMS................................................................................................... 147 WILDFIRE. ...................................................................................................................................... 152 MANDATORY FINDINGS OF SIGNIFICANCE.......................................................................... 154 REFERENCES ..................................................................................................................................... 157 349
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Figures
Figure 1: Regional Location ..................................................................................................................... 5 Figure 2: Local Vicinity............................................................................................................................ 7 Figure 3: Project Site Aerial ..................................................................................................................... 9 Figure 4: Existing General Plan Designation ......................................................................................... 11 Figure 5: Existing Zoning....................................................................................................................... 13 Figure 6: Proposed General Plan Designation ........................................................................................ 19 Figure 7: Proposed Zoning Designation ................................................................................................. 21 Figure 8: Conceptual Site Plan ............................................................................................................... 23 Figure 9: Building Elevations Duplex Type A ....................................................................................... 25 Figure 10: Building Elevations Duplex Type B ..................................................................................... 25 Figure 11: Building Elevations Duplex Type C ..................................................................................... 25 Figure 12: Building Elevations Plan 3A ................................................................................................. 31 Figure 13: Building Elevations Plan 3B ................................................................................................. 33 Figure 14: Building Elevations Plan 5B ................................................................................................. 35 Figure 15: Project Renderings ................................................................................................................ 37 Figure 16: Open Space Plan ................................................................................................................... 39 Figure 17: Wall Plan............................................................................................................................... 41 Figure 18: Conceptual Landscaping Plan............................................................................................... 43 Figure N-1: Noise Measurement Locations.......................................................................................... 107 Figure N-2: Sensitive Receiver Locations............................................................................................ 108 Figure N-3: Concrete Crushing Activities and Sensitive Receiver Locations ..................................... 112 Figure N-4: Noise and Vibration Measures .......................................................................................... 120 Figure T-1: Roadways Selected to Calculate Daily VMT.................................................................... 138 Tables
Table 1: Surrounding Existing Land Use and Zoning Designations ........................................................ 3 Table 2: Residential Unit Summary ....................................................................................................... 15 Table 3: Construction Schedule .............................................................................................................. 17 Table AES-1: Project Consistency with Site Development Standards................................................... 48 Table AQ-1: Maximum Daily Regional Emissions Thresholds ............................................................. 55 Table AQ-2: Construction Regional Emissions Summary..................................................................... 56 Table AQ-3: Operational Regional Emissions Summary....................................................................... 57 Table AQ-4: Localized Emissions from Construction ........................................................................... 58 Table E-1: Estimated Project Construction Energy Usage..................................................................... 65 Table E-2: Estimated Annual Project Operational Energy Usage.......................................................... 67 Table GHG-1: Project Construction Greenhouse Gas Emissions .......................................................... 77 Table GHG-2: Total Project Greenhouse Gas Emissions....................................................................... 78 Table GHG-3: 2022 Scoping Plan Consistency Summary ..................................................................... 79 Table GHG-4: General Plan GHG Policy Consiustency Summary ..................................................... 81 Table HYD-1: Comparison of Storm Flows with Project Implementation............................................ 91 Table LU-1: City of Orange General Plan Project Consistency............................................................. 97 Table N-1: City of Orange General Plan Interior and Exterior Noise Standards................................. 105 Table N-2: Ambient Noise Level Measurements................................................................................. 106 Table N-3: Project Construction Reference Noise Levels.................................................................... 109 Table N-4: Concrete Crushing Reference Noise Levels ....................................................................... 110 Table N-5: Project Construction Equipment Noise Levels at Receivers.............................................. 111 350
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Table N-6: Project Construction Noise Level Increases at Receivers.................................................. 113 Table N-7: Project Exterior Noise Levels ............................................................................................ 113 Table N-8: Noise Reduction Calculations............................................................................................ 114 Table N-9: First Floor Interior Noise Levels........................................................................................ 115 Table N-10: Second Floor Interior Noise Levels ................................................................................. 115 Table N-11: Third Floor Interior Noise Levels .................................................................................... 116 Table N-12: Daytime Project Operational Noise Levels...................................................................... 116 Table N-13: Nighttime Project Operational Noise Levels ................................................................... 117 Table N-14: Daytime Project Operational Noise Level Increases........................................................ 117 Table N-15: Nighttime Project Operational Noise Level Increases..................................................... 117 Table N-16: Vibration Source Amplitudes for Construction Equipment............................................. 118 Table N-17: Project Construction Vibration Levels - Unmitigated...................................................... 119 Table N-18: Project Construction Vibration Levels - Mitigated.......................................................... 119 Table N-19: Concrete Crushing Vibration Impacts at Nearest Receptor ............................................. 121 Table PS-1: Project Student Generation............................................................................................... 127 Table T-1: Former Best Buy Store Trip Generation............................................................................. 132 Table T-2: Project Trip Generation ...................................................................................................... 132 Table T-3: OCTAM VMT Analysis of Project .................................................................................... 137 Table T-4: Project Effects on VMT...................................................................................................... 138 Table UT-1: City of Orange Projected Water Supply Projections (acre-feet)...................................... 148 Table UT-2: Landfill Capacity ............................................................................................................. 150 Appendices
A Air Quality, Energy, and Greenhouse Gas Impact Analysis B Tree Survey and Arborist Report
C Cultural Resources Study
D Geotechnical and Infiltration Evaluation
E Paleontological Resources Assessment
F Phase I Environmental Site Assessment
G Preliminary Hydrology Report
H Preliminary Water Quality Management Plan
I Noise Impact Analysis
J Level of Service (LOS) Screening Analysis
K VMT Analysis
L Mitigation Monitoring and Reporting Program
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1 INITIAL STUDY/MITIGATED NEGATIVE DECLARATION NO. ENV25-0001 Project Title:

North Tustin Street Residential Project
Reference Application Numbers:

General Plan Amendment No. GPA25-
0003
Zone Change No. ZC25-0002
Major Site Plan Review No. MJSP25-
0002
Administrative Design Review No.

ADR25-0018
Vesting Tentative Tract Map No. TTM25-
0001
Environmental Review No. ENV25-0001
Lead Agency:

City of Orange
300 East Chapman Avenue
Orange, CA 92866
Contact Person and Telephone No.:

Monique Schwartz, Senior Planner
Community Development Department
(714) 744-7224
Project Proponent and Address:

Melia Homes
9860 Irvine Center Drive
Irvine, CA 92618
Contact Person and Telephone No.:

Chad Brown, Vice President of Planning
& Development
(949) 417-6264
Project Location:

The Project site is located at 2375 N. Tustin Street in the City of Orange, Orange County, California (Figure 1, Regional Location). The Project site is adjacent to N. Tustin Street to the east, State Route (SR) 55 to the west. The N. Tustin cross street with Meats Avenue is to the south and Lincoln Avenue to the north.

Existing General Plan Designation:

General Commercial, Max FAR 1.0 (GC)
Existing Zoning Classification:

Limited Business Tustin Redevelopment
Project Area (C-TR)

INTRODUCTION
The applicant for the North Tustin Street Residential Project (Project) is requesting approval from the City of Orange to demolish the existing structure and related improvements on the Project site and to construct a new residential development that would consist of 71 residences with open space, recreation, landscaping, and parking. The Project would result in a residential density of 16.76 dwelling units per acre.

The City has prepared this Initial Study/Mitigated Negative Declaration (IS/MND) to address and disclose the potential environmental effects of Project implementation in compliance with the California Environmental Quality Act (CEQA) and the Guidelines for the Implementation of the CEQA (CEQA Guidelines).

Consistent with CEQA Guidelines Section 15071, this IS/MND includes a description of the Project, an evaluation of the potential environmental impacts, mitigation as needed, and findings from the environmental review. This IS/MND evaluates the potential environmental impacts that may result from 353
2 implementation of the Project. The City is the Lead Agency under CEQA, and its City Council is responsible for the adoption of the environmental analysis and approval of the Project.

EXISTING SETTING
Regional Setting
The Project site is located at 2375 N. Tustin Street in the northern portion of the City of Orange. The Project site is identified by Assessor’s Parcel Number (APN) 372-642-31. Regional access to the Project site is provided by SR-55, from either the Katella Avenue interchange or the Lincoln Avenue interchange, which both intersect with N. Tustin Street.

The Project site is located within an unsectioned area, Township 4 South, Range 9 West, of the San Bernardino Baseline and Meridian, as shown on the United States Geologic Survey (USGS) Orange, California Topographic Quadrangle map. Regional location and local vicinity maps are provided in Figure 1, Regional Location, and Figure 2, Local Vicinity.

Existing Site Conditions
The Project site comprises one parcel encompassing approximately 4.235 gross acres that is fully developed with a vacant 45,676 square-foot Best Buy retail store building that is approximately 30 feet in height. The building is surrounded by surface parking lot areas and landscaping that includes 86 ornamental trees. The existing onsite improvements were constructed in 2007 and were operational through October 2023.

The entire site is relatively flat and is accessible via the existing driveway to N. Tustin Avenue. The site is bound on the north and south sides by six- to eight-foot-high walls followed by residential uses. A temporary chain linked fence is located on the west side of the site. The Project site’s existing conditions are shown in Figure 3, Project Site Aerial.

Existing Land Uses and Zoning Designation
The Project site has a General Plan land use designation of General Commercial (GC) that allows a maximum Floor Area Ratio (FAR) of 1.0 and is zoned Limited Business Tustin Redevelopment Project Area (C-TR), as shown on Figure 4, Existing General Plan Designations, and Figure 5, Existing Zoning Designations. The General Plan states that the GC land use designation provides for a wide range of retail and service commercial uses and professional offices. Regional shopping centers, mid- and highrise office projects, corridor shopping districts, and neighborhood corner stores are all permitted uses.

The Limited Business Tustin Redevelopment Project Area (C-TR) zoning designation is intended to provide for limited commercial uses for a wide variety of goods and services.

Surrounding Land Uses
The Project site is located within a developed residential and commercial area. The site is adjacent to commercial parcels developed with an office building that fronts N. Tustin Street to the west and a parcel that contains a freeway billboard sign to the east. The parcels that are adjacent to the east and west of the site have a General Plan land use designation of GC and a zoning designation of C-TR, which is consistent with the Project site.

The existing residential land uses to the north consist of single-story condominiums with a driveway and garages immediately adjacent to the Project site. Adjacent residential to the north of the site has a General Plan land use designation of Medium Density Residential (MDR) with an allowable density of 15-24 du/ac and a zoning designation of Residential Multiple Family Single Story Overlay (R-3(A)). 354
3 The existing residential land uses to the south of the site consist of both single-story condominiums with garages and mobile homes that have a General Plan land use designation of Low Medium Density Residential (LMDR) with an allowable density of 6-15 du/ac and zoning designations of Residential Multiple Family Single Story Overlay (R-3(A)) and Mobile Home Residential (M-H). The existing land uses, General Plan land uses, and zoning designations of areas surrounding the Project site are described in Table 1.

Table 1: Surrounding Existing Land Use and Zoning Designations Existing Land Use General Plan
Designation
Zoning
Designation
North Multi-Family Residences MDR R-3(A)
West
Commercial office building, vacant
fenced parking lot, followed by N.

Tustin Street

GC C-TR
South Multi-Family Residences and
Mobile Home Residences
LMDR R-3(A) and M-H
East Billboard parcel followed by SR-55 GC C-TR
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5 Figure 1: Regional Location
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7 Figure 2: Local Vicinity
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9 Figure 3: Project Site Aerial
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11 Figure 4: Existing General Plan Designation
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13 Figure 5: Existing Zoning Designation
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15 PROJECT DESCRIPTION
Project Overview
The applicant for the Project is requesting approval from the City of Orange to demolish the existing vacant retail commercial structure and improvements on the Project site and construct 71 paired and detached residences, open space/recreation, and parking. The residential structures would be threestories. Each residential unit would have three or four bedrooms, ranging in size from approximately 2,008 square feet to 2,117 square feet and would be developed above two-car garages. The 71 residences on the 4.235-acre site would result in a density of 16.76 units per acre. The Project would include parking, open space, ornamental landscaping, and associated infrastructure.

The Project requests the approval of a General Plan Amendment to change the land use from GC to Medium Density Residential (MDR), as shown in Figure 6, Proposed General Plan Land Use Designation, which allows residential densities between 15 and 24 dwelling units per acre. The Project also includes a Zone Change to change the site zoning from C-TR to R3 (Multiple-Family Residential) (shown in Figure 7) with application of the Small Lot Subdivision Development Standards for fee simple duplex and detached residences. Additionally, the Project includes a Vesting Tentative Tract Map (TTM) for sale purposes a Major Site Plan Review, and an Administrative Design Review for consideration of the architectural design, conceptual landscaping, and overall compliance with the City’s zoning regulations.

Project Features
Residential Summary and Architecture
The Project would redevelop the 4.235-acre site to provide 71 residences, as shown in Figure 8, Conceptual Site Plan. The Project includes 58 paired duplex homes and 13 detached residences within three-story structures that would have a maximum height of 35 feet. The Project would result in a density of 16.76 dwelling units per acre. The Project proposes five different floor plans with two variations of the floor plans. The residences would range from approximately 2,008 to 2,117 square feet, have three or four bedrooms, and a two-car garage, as shown in Table 2.

Table 2: Residential Unit Summary
Unit
Type
Number
of Units
Number
of
Stories
Number
of
Bedrooms
Number of
Bathrooms including
Powder Rooms
Square
Footage
Plan 1 10 3 3 4 2,008
Plan 2 16 3 3 4 2,014
Plan 3 14 3 4 4 2,026
Plan 4 13 3 3 4 2,086
Plan 5 18 3 3 4 2,117
All of the residences would include either a roof deck (36 units) ranging from 235 to 300 square feet or a ground level fenced rear private yard (35 units) with a minimum of 240 square feet. The perimeter lots with the rear yards are adjacent to existing residences to the north and south of the site and would not have roof decks.
367
16 All residences along the east (rear) boundary would have a 10-foot setback or greater consistent with the Small Lot Subdivision Development Standards. Residences along north and south boundaries would have a minimum 10-foot setback to allow for ground level private open space yards. Five residences (four paired and one detached) would front along the west side of the parcel (towards N. Tustin Street) and would have a minimum front setback of 15 feet, consistent with the Small Lot Subdivision Development Standards.

Due to the proximity of SR-55 to the Project site, Project Design Feature (PDF) 1 is included to ensure that the third floor of the proposed residence in the northeastern most portion of the site (Lot 54) would be developed with upgraded windows that have a minimum Sound Transmission Class (STC) rating of

31. PDF-1 would be included in the Mitigation Monitoring and Reporting Program for the Project.

The residential structures would have contemporary highly articulated exterior designs utilizing a mix of stuccos, colors, variations of architectural siding elements, such as resawn wood and Hardie lap siding.

Architectural elements include, metal railings, decorative metal awnings, vinyl windows with white frames and stucco trim, decorative exterior light fixtures, sectional garage doors, and articulation along building facades and roof variations with asphalt shingles. Consistent with the Small Lot Subdivision Guidelines, primary entrance doorways would face the drive aisle or landscape paseo passage and are covered by an entry porch or shallow alcove that accentuates the point of entry. The proposed building elevations are provided in Figures 9 through 14 and renderings of the Project are provided in Figure 15.

Open Space Recreation
The Project includes 6,031 square feet of common open space with a large common recreation area with sail shade structures, shaded tables and seating, a multipurpose turf area, and enhanced paving. An open space feature with landscaping and walkways is proposed throughout the internal walks in the paseo areas, as shown in Figure 16, Open Space Plan.

Parking and Circulation
The Project would be accessed from a 29-foot-wide driveway along the west side of the site. A 22-footwide secondary driveway for emergency access would be located at the northeast corner of the Project site. Each of the proposed residences would be accessed from the 25-foot-wide driveway that would circle the site and have a fire access corner radii of a 50-foot outside radius and 55-foot inside radius compliant with the City of Orange Fire Master Plan access standards.

Each of the residences would have a two-car garage, and 14 of the residences (the four-bedroom units) would have an extra dedicated unenclosed parking space on the same lot. In addition, the Project would provide 23 unenclosed guest parking spaces on the site. The Project includes a total of 179 parking spaces, which is a parking ratio of 2.52 spaces per residential unit.

Walls and Landscaping
Existing cement block walls along the north, south, and southwest boundaries of the site that range between six and eight feet in height would remain; with exception of new seven-foot-high 26-foot-wide emergency vehicle access gates that would be installed at the northeast corner of the site. A new eightfoot-high block wall with a sliding gate for vehicular access would be located along the eastern site boundary for maintenance of the existing billboard sign that is adjacent to SR-55. Additionally, a new six-foot-high wall would be located at the northwestern boundary of the site along the Project frontage.

The Project wall plan is shown in Figure 17.
368
17 The proposed Project includes approximately 30,309 square feet (16.4% of the site) of landscaping with 24-inch and 36-inch box trees, 15-gallon trees, various shrubs, and groundcover. Although most of the existing trees would be removed and replaced in open space areas, the Project would retain 13 date palm trees that line the entrance to the site, as shown in Figure 18, Conceptual Landscape Plan.

Infrastructure
Water and Sewer
The Project applicant would install new onsite water and sewer lines, which connect to the existing 12- inch diameter water main located in N. Tustin Avenue and the existing 12-inch sewer main located within E. Heim Avenue to the north of the Project site.

Drainage
The Project would install a new onsite drainage system to accommodate the proposed site plan.

Stormwater runoff would be captured by five sump curb inlet catch basins, one grate inlet, and an onsite area drain system that would route runoff to biofiltration treatment devices prior to discharge to the existing stormwater sump pump system. The sump pump system would discharge runoff into N. Tustin Street through a parkway drain, consistent with the current condition, but with an approximate seven percent decreased volume compared to the existing condition.

Project Construction
Construction activities for the Project include demolition, site preparation, grading, building construction, paving, and architectural coatings. The Project grading activities would involve removal and recompaction of the upper five feet of soil that would include approximately 8,200 cubic yards (cy) of cut and approximately 850 cy of fill, with an estimated export volume of approximately 7,350 cy.

Construction is expected to occur over approximately 14 months and would occur within the hours allowable by Orange Municipal Code Section 8.24.050, which states that construction shall occur only between the hours of 7:00 a.m. and 8:00 p.m. Monday through Saturday. No construction activity is permitted on Sunday or Federal holidays. Demolition, site preparation, and grading would occur at one time, and the construction of the residences would be phased with three to 16 residences being developed at one time. The building construction listed in Table 3 provides the modeling estimate of the total days of construction and equipment, which is used for analysis purposes.

Table 3: Construction Schedule
Construction Phase Working Days Equipment
Demolition 20 Excavator, Rubber Tired Dozer, Concrete/Industrial saw, Crushing/Proc. Equipment
Site Preparation 5 Rubber Tired Dozer, Tractors, Loaders, Backhoes, Crawler Tractors
Grading 8 Grader, Rubber Tired Dozer, Tractors, Loaders, Backhoes, Crawler Tractors, Excavators
Building Construction 230 Crane, Forklifts, Tractors, Loaders, Backhoes, Generator Sets, Welders
Paving 18 Tractors, Loaders, Backhoes, Cement and Mortar Mixers, Pavers, Rollers, Paving Equipment
Architectural Coatings 18 Air Compressor
369
18 Discretionary and Ministerial Actions
The following discretionary and ministerial approval, permits, and studies are anticipated to be necessary for implementation of the Project:

City of Orange
• General Plan Amendment to change the land use designation from CG to MDR. • Zone Change to change the zoning designation from C-TR to R-3 with application of the Small Lot Subdivision Ordinance (SLO) for fee simple duplex and detached residences. • Vesting Tentative Tract Map for creation of a small lot subdivision • Administrative Design Review
• Adoption of this IS/MND
• Ministerial approvals and permits necessary to execute the Project, including but not limited to, demolition permit, grading permit, building permit, etc.

Other Public Agencies Whose Approval is Required (Responsible or Trustee Agencies):
• SCAQMD Permit to Construct
Scheduled Public Meetings or Hearings:

This IS/MND will be considered for approval along with the Project’s entitlements and schematic design plans at a noticed public hearing, which will be scheduled and noticed at a later date. 370
19 Figure 6: Proposed General Plan Designation
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21 Figure 7: Proposed Zoning Designation
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23 Figure 8: Conceptual Site Plan
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24 .

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PLAN 4 PLAN 1
35'-0"
BLD'G. HT.
9'-1" 8'-6"
4 7 8 6 12 9 12 2 1 3 6 9
PLAN 4
13 PLAN 1 PLAN 4
11 9
PLAN 1
13 MATERIAL SCHEDULE

1. ROOF - ASPHALT SHINGLES

2. FASCIA - 2X RESAWN WOOD

3. 16/20 SAND FINISH STUCCO

4. HARDIE LAP SIDING - 6" EXPOSURE

5. DECORATIVE METAL RAILING

6. VINYL WINDOW W/ WHITE FRAME

AND STUCCO TRIM

7. STUCCO CONTROL REGLET

8. EXTERIOR LIGHT FIXTURE

9. DECORATIVE METAL AWNING

10. DECORATIVE STUCCO EYEBROW11. SECTIONAL GARAGE DOOR

12. COVERED ENTRY OR PORCH13. WALL VINE ESPALIER
PLAN 4 SIDE ELEVATION PASEO ELEVATIONPLAN 1 SIDE ELEVATION DRIVE AISLE ELEVATION )LJXUH

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377
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378
PLAN 5A PLAN 2
35'-0"
BLD'G. HT.
" 9'-1" 8'-6"
12 7 8 6 9 11 4 2 12 1 3 6
PLAN 5A
PLAN 2 PLAN 2 PLAN 5A

MATERIAL SCHEDULE

1. ROOF - ASPHALT SHINGLES

2. FASCIA - 2X RESAWN WOOD

3. 16/20 SAND FINISH STUCCO

4. HARDIE LAP SIDING - 6" EXPOSURE

5. DECORATIVE METAL RAILING

6. VINYL WINDOW W/ WHITE FRAME

AND STUCCO TRIM

7. STUCCO CONTROL REGLET

8. EXTERIOR LIGHT FIXTURE

9. DECORATIVE METAL AWNING

10. DECORATIVE STUCCO EYEBROW11. SECTIONAL GARAGE DOOR12. COVERED ENTRY OR PORCH13. WALL VINE ESPALIER

REAR - PRIVATE YARD ELEVATION
PLAN 5A SIDE ELEVATION FRONT - DRIVE AISLE ELEVATION
PLAN 2 SIDE ELEVATION
)LJXUH
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379
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380
PLAN 3C
35'-0"
BLD'G. HT.
9'-1" 8'-6"
4 7 10 6 1 6 7 9 2 8 3 6 5
PLAN 4 PLAN 4
PLAN 3C

MATERIAL SCHEDULE

1. ROOF - ASPHALT SHINGLES

2. FASCIA - 2X RESAWN WOOD

3. 16/20 SAND FINISH STUCCO

4. HARDIE LAP SIDING - 6" EXPOSURE

5. DECORATIVE METAL RAILING

6. VINYL WINDOW W/ WHITE FRAME

AND STUCCO TRIM

7. STUCCO CONTROL REGLET

8. EXTERIOR LIGHT FIXTURE

9. DECORATIVE METAL AWNING

10. DECORATIVE STUCCO EYEBROW11. SECTIONAL GARAGE DOOR

12. COVERED ENTRY OR PORCH13. WALL VINE ESPALIER
PLAN 3C PLAN 4
11 9
PLAN 2C SIDE - ENTRY ELEVATION PASEO ELEVATIONPLAN 3C SIDE - ENTRY ELEVATION DRIVE AISLE ELEVATION )LJXUH
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381
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382
35'-0"
BLD'G. HT.
9'-1" 8'-6"
12 1 3 11 3 9 2 1 4

MATERIAL SCHEDULE

1. ROOF - ASPHALT SHINGLES

2. FASCIA - 2X RESAWN WOOD

3. 16/20 SAND FINISH STUCCO

4. HARDIE LAP SIDING - 6" EXPOSURE

5. DECORATIVE METAL RAILING

6. VINYL WINDOW W/ WHITE FRAME

AND STUCCO TRIM

7. STUCCO CONTROL REGLET

8. EXTERIOR LIGHT FIXTURE

9. DECORATIVE METAL AWNING

10. DECORATIVE STUCCO EYEBROW11. SECTIONAL GARAGE DOOR12. COVERED ENTRY OR PORCH13. WALL VINE ESPALIER

LEFT SIDE ELEVATION FRONT - DRIVE AISLE ELEVATION

RIGHT SIDE ELEVATION PRIVATE YARD - REAR ELEVATION
)LJXUH
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383
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384
35'-0"
BLD'G. HT.
'-1" 9'-1" 8'-6"
7 1 2 9 8 3 6 5
11 9

MATERIAL SCHEDULE

1. ROOF - ASPHALT SHINGLES

2. FASCIA - 2X RESAWN WOOD

3. 16/20 SAND FINISH STUCCO

4. HARDIE LAP SIDING - 6" EXPOSURE

5. DECORATIVE METAL RAILING

6. VINYL WINDOW W/ WHITE FRAME

AND STUCCO TRIM

7. STUCCO CONTROL REGLET

8. EXTERIOR LIGHT FIXTURE

9. DECORATIVE METAL AWNING

10. DECORATIVE STUCCO EYEBROW11. SECTIONAL GARAGE DOOR

12. COVERED ENTRY OR PORCH13. WALL VINE ESPALIER

SIDE ELEVATION PASEO ELEVATION

ENTRY ELEVATION DRIVE AISLE ELEVATION
)LJXUH
%XLOGLQJ(OHYDWLRQV3ODQ%
385
34 This page is intentionally left blank.
386
35'-0"
BLD'G. HT.
-1" 9'-1" 8'-6"
12 1 3 11 3 9 2 1 4

MATERIAL SCHEDULE

1. ROOF - ASPHALT SHINGLES

2. FASCIA - 2X RESAWN WOOD

3. 16/20 SAND FINISH STUCCO

4. HARDIE LAP SIDING - 6" EXPOSURE

5. DECORATIVE METAL RAILING

6. VINYL WINDOW W/ WHITE FRAME

AND STUCCO TRIM

7. STUCCO CONTROL REGLET

8. EXTERIOR LIGHT FIXTURE

9. DECORATIVE METAL AWNING

10. DECORATIVE STUCCO EYEBROW11. SECTIONAL GARAGE DOOR12. COVERED ENTRY OR PORCH13. WALL VINE ESPALIER

LEFT SIDE ELEVATION FRONT - DRIVE AISLE ELEVATION

RIGHT SIDE ELEVATION PRIVATE YARD - REAR ELEVATION
)LJXUH
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387
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388
FRONT ENTRY PERSPECTIVE (PLANS 2 AND 5A) PASEO PERSPECTIVE AT UNIT 32 TOWARD SOUTHEAST

PERSPECTIVE OF PROJECT ENTRY
PERSPECTIVE OF PLANS 5A/3B LOOKING NORTHEAST (LOT 67/71 ) PERSPECTIVE OF TYPICAL INTERIOR PASEO )LJXUH
3URMHFW5HQGHULQJV
389
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390
39 Figure 16: Open Space Plan
391
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392
2''W
6''SD
Limit of >Work
4''SS
Existing Tan Precision wall Automated Emergency Vehicle Access gate.

Property Line.
20' wide access
slide gate with
depressed curve
for vehicle access.
8' High screen wall to buffer noise
along the freeway.

STOP
METER
10 Existing Gray Precision
wall by adjacent bank,
protect in place.
6''W
E

WALL, FENCE & GATE LEGEND
1 Existing ± 6'-0" High property line wall, protect in place.

New Metal Wall Trellis vines.

Existing Tan Precision wall
*Conceptual images (provided herein are conceptual and subject to change) 8 Note: 0 15' 30' 60'
ADA Path of Travel
Figure 17: Wall Plan
Perimeter walls on west side of site must be coated with an anti-graffiti paint or have faux vegetation installed to counter potential vandalism/graffiti. Scale: 1" = 30' Limit of Work
Limit of Work
1 2 3 4 5 6 7 9
2 3
4 5
6 7
8 9
10 2''W6''W
6''SD
6''W 6''W 6''W
Limit of Work
/ /
12''FW 12''FW 12''FW
THRU
DRIVE
> 4''FW
> > >
THRU
DRIVE
>

N T U S T I N S T
||
8''SD
6''SD
>
2''W 2''W
Limit of Work
12''SD
/
Limit of Work
393
42 This page is intentionally left blank.
394
16 Central community open space area with enhanced paving courtyard, palm trees, shade sail overhead covers, and artificial turf for small social events and group gatherings.

Six community cluster mailboxes, per USPS review and approval.

Proposed wall, pilaster, gate or fence, per Wall & Fence Plan.Proposed 20' wide access slide gate with depressed curve for vehicle access.

Automated Emergency Vehicle Access gate.

Enhanced paving at main project entry.Proposed tree, per Planting Plan. 5' wide community natural colored concrete sidewalk, with light top-cast finish and saw-cut joints.
4' wide unit entry natural colored concrete walk, with light top-cast finish and saw-cut joints.

Accessible parking stall and striping, per Civil plans.

Guest parking stall.

12. Natural colored concrete driveway, with light broom finish and tooled joints.

13. 11.10.

5.9.8.7.6.4.3.2.1. LEGEND

14.15.16.17.18.19.20.21.22.23. Private patio / yard area, homeowner maintained.

Common area landscape, builder installed and HOA maintained.Community dog bag station (black in color), for pet owners.

Property line.Public street R.O.W.Proposed public street sidewalk, per Civil plans.

Transformer to be screened with landscape, quantity and final locations to be determined.

Short term bike parking (1 bike rack to accommodate 2 bike stalls).

Modular wetland, per Civil plans.Proposed AC condenser locations, per Architecture plans.Existing landscape to remain in addition to new utility screen plantings. 16 16
4 1
1 2
3 35
6 8
8 9
9 9
1011
11 11
12 12
12 14
14 23
1416
16 171818
1919
19 19
7 19
2021
22 22
22 15
19 3
7 9
13 13
16 14
16 1717
)LJXUH
&RQFHSWXDO/DQGVFDSLQJ3ODQ
395
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396

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" or "Less Than Significant with Mitigation Incorporated" as indicated by the checklist on the following pages.

D Aesthetics
fZI Biological Resources
0 Geology/Soils
D Hydrology/Water Quality
fZI Noise
0 Recreation
0 Utilities/Service Systems
0 Agriculture & Forest Resources
0 Cultural Resources
0 Greenhouse Gas Emissions
0 Land Use/Planning
0 Population/Housing
0 Transportation
0 Wildfire
DETERMINATION. On the basis of this initial evaluation:
0 Air Quality
0 Energy
0 Hazards & Hazardous
Materials
0 Mineral Resources
0 Public Services
fZI Tribal Cultural Resources
fZI Mandatory Findings of
Significance

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

2. I find that although the Project could have a significant effect on the enviromnent, there [gj 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 Project may have a significant effect on the environment, and an D ENVIRONMENT AL IMPACT REPORT is required.

4. I find that the 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 ENVIRONMENT AL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.

5. I find that although the Project could have a significant effect on the environment, because D 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 mitigatr:es that are imposed upon the Project, not
.
bing further is required.
um ��· 1 1 q - 11,
Monique �hwartz, Senior Planner Date
45 397
46 EVALUATION OF ENVIRONMENTAL IMPACTS:

1. A brief explanation is required for all answers except “No Impact” answers that are adequately supported by the information sources a lead agency cites in the parentheses following each question. A “No Impact” answer is adequately supported if the referenced information sources show that the impact simply does not apply to projects like the one involved (e.g., the project falls outside a fault rupture zone). A “No Impact” answer should be explained where it is based on project-specific factors as well as general standards (e.g., the project will not expose sensitive receptors to pollutants, based on a project-specific screening analysis).

2. All answers must take account of the whole action involved, including off-site as well as on-site, cumulative as well as project-level, indirect as well as direct, and construction as well as operational impacts.

3. Once the lead agency has determined that a particular physical impact may occur, then the checklist answers must indicate whether the impact is potentially significant, less than significant with mitigation, or less than significant. “Potentially Significant Impact” is appropriate if there is substantial evidence that an effect may be significant. If there are one or more “Potentially Significant Impact” entries when the determination is made, an EIR is required.

4. “Negative Declaration: Less Than Significant With Mitigation Incorporated” applies where the incorporation of mitigation measures has reduced an effect from “Potentially Significant Impact” to a “Less Than Significant Impact”. The lead agency must describe the mitigation measures, and briefly explain how they reduce the effect to a less than significant level (mitigation measures from earlier analyses may be cross-referenced, as discussed below).

5. Earlier analyses may be used where, pursuant to the tiering, program EIR, or other CEQA process, an effect has been adequately analyzed in an earlier EIR or negative declaration. Section 15063 (c)(3)(D). In this case, a brief discussion should identity the following:
a. Earlier Analysis Used. Identify and state where they are available for review. b. Impacts Adequately Addressed. Identify which effects from the above checklist were within the scope of and adequately analyzed in an earlier document pursuant to applicable legal standards, and state whether such effects were addressed by mitigation measures based on the earlier analysis. c. Mitigation Measures. For effects that are “Less than Significant with Mitigation Measures Incorporated”, describe the mitigation measures which were incorporated or refined from the earlier document and the extent to which they address site-specific conditions for the project.

6. Lead agencies are encouraged to incorporate into the checklist references to information sources for potential impacts (e.g., general plans, zoning ordinances). Reference to a previously prepared or outside document should, where appropriate, include a reference to the page or pages where the statement is substantiated.

7. Supporting Information Sources: A source list should be attached, and other sources used or individuals contacted should be cited in the discussion.

8. This is only a suggested form, and lead agencies are free to use different formats; however, lead agencies should normally address the questions from this checklist that are relevant to a project’s environmental effects in whatever format is selected.

9. The explanation of each issue should identify:
a) the significance criteria or threshold, if any, used to evaluate each question; and b) the mitigation measure identified, if any, to reduce the impact to less than significance. 398
47 CHECKLIST OF ENVIRONMENTAL IMPACT ISSUES:

1. AESTHETICS.

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

Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(a) Have a substantial adverse effect on a scenic vista? (b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway?
(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?
(d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Impact Analysis
a) Scenic vistas consist of expansive, panoramic views of important, unique, or highly valued visual features that are seen from public viewing areas. This definition combines visual quality with information about view exposure to describe the level of interest or concern that viewers may have for the quality of a particular view or visual setting. A scenic vista can be impacted in two ways: a development project can have visual impacts by either directly diminishing the scenic quality of the vista or by blocking the view corridors or “vista” of the scenic resource. Important factors in determining whether the Project would block scenic vistas include the Project’s proposed height, mass, and location relative to surrounding land uses and travel corridors. The City’s General Plan defines scenic vistas as those “...hillsides, ridgelines or open space areas that provide a unifying visual backdrop to the urban environment.”
The Project site is in an urbanized area where views are limited due to the surrounding commercial and residential developments. The Project site is currently developed with a 45,676 square foot retail commercial building that is approximately 30 feet in height with higher signage. There are no views of the surrounding foothills of the Santa Ana Mountains or the Puente-Chino Hills from public vantage points on N. Tustin Street near the Project site.

The Project would develop 71 new 3-story townhouse residences on the Project site that that would have a maximum height of 35 feet and would be setback a minimum of 290 feet from N. Tustin Street and over 50 feet from SR-55. Also, the Project would be in compliance with Orange Municipal Code Sections

17.14.270, Small Lot Subdivision Standards. Due to the proposed setbacks, the proposed Project would not impede any views from either N. Tustin Street or SR-55. As no scenic vistas or protected viewsheds are visible from the Project site and the proposed structures would be setback from roadway viewsheds, and the Project is consistent City development standards, no impacts to any scenic vistas would occur.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact. 399
48 b) There are no officially designated state scenic highways in the vicinity of the Project (Caltrans 2025).

The nearest officially designated scenic highway is State Route 91, approximately 1.3 miles northeast of the Project site. The Orange General Plan identifies portions of Santiago Canyon Road, Jamboree Road, and Newport Boulevard as potential City scenic highways. However, these roadways are not located within the vicinity of the Project site. Therefore, impacts to scenic resources within a state scenic highway would not occur.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact. c) The Project site is located within a mixed commercial and residential area and is adjacent to commercial offices on the west, residential to the north and south, and a billboard parcel and the SR-55 to the east. The Project site is developed with a vacant 45,676 square foot BestBuy retail store building that is approximately 30 feet in height, surface parking lot, and landscaping. The existing character of the Project site is neither unique nor of special aesthetic value or quality.

The Project includes a General Plan Amendment to change the land use designation of the site from GC to MDR and a Zone Change to change the zoning designation from C-TR to R-3 with application of the Small Lot Subdivision Ordinance (SLO). The Project development would be consistent with the applicable land use and zoning development standards from Municipal Code Chapter 17.14, as detailed in Table AES-1.

Table AES-1: Project Consistency with Site Development Standards Development Feature R-3 Zoning Small Lot
Subdivision Standards
Project Consistency
Minimum Lot Frontage 25 feet Consistent. The Project would have minimum lot frontages of 25.02 to 52.54
feet. Therefore, the Project is consistent with
this zoning standard.

Minimum Lot Depth 50 feet Consistent. The Project would have minimum lot depths of 55.58 to 68.03 feet.

Therefore, the Project is consistent with this
zoning standard.

Minimum Yard Setbacks:

Front
Side
Rear
15 feet
5 feet
10 feet
Consistent. The Project would have
minimum setbacks of 15.1 feet on the front,

10.1 feet on the side, and 10.1 feet on the
rear, and would be consistent with this
zoning standard.

Maximum Height 35 feet
3-stories
Consistent. The Project would provide 3-
story townhomes with a maximum height of
35 feet. Therefore, the Project is consistent
with this zoning standard.

Lot Coverage 75 percent Consistent. The Project would provide lot coverages of 25 to 55.7 percent. Therefore,
the Project is consistent with this zoning
standard.

Minimum Usable Open Space 250 sf/unit Consistent. The Project includes 6,031 square feet of common open space with a
400
49 Development Feature R-3 Zoning Small Lot
Subdivision Standards
Project Consistency
large common recreation area. Also,
residences would include either a roof deck
ranging from 235 to 300 square feet or a
ground level fenced rear private yard with a
minimum of 240 square feet. The total
private open space provided is 19,912 square
feet, which equates to 280 square feet per
unit. Therefore, the Project is consistent with
this zoning standard.

Minimum Private Open Space 150 sf/unit Consistent. The Project would provide either a 240-square-foot minimum fenced
rear yard or a 235- to 300-square-foot roof
deck with each residence. Therefore, the
Project is consistent with this zoning
standard.

Common Open Space Only required when lot
coverage of each lot exceeds
75 percent.

Consistent. Each lot does not exceed 75
percent lot coverage; however, 6,031 square
feet of common open space is provided in the
form of a central courtyard with shade sail
overhead covers, picnic table seating, and
open turf area. Therefore, the Project is
consistent with this zoning standard.

Maximum Fence Height 6 feet: Side and rear yard
setback areas along the
perimeter of the proposed
subdivision.
8 feet: When adjacent to
commercial development.

Consistent. As shown on Figure 17, Wall
Plan, a new 6-foot-high perimeter wall
adjacent to commercial development to the
west and a new 8-foot-high perimeter wall
along the east (rear) property line adjacent to
commercial development would be installed
as part of the Project. The existing 6-foothigh walls on the northern and southern property lines would remain, and the existing
8-foot-high wall on the southwestern
boundary adjacent to the bank property
would remain.

Landscaping Setbacks and open areas of
the site not occupied by
buildings shall be landscaped,
including surface parking lot
areas.

Consistent. The Project includes 51,464
square feet of landscaping / hardscaping
provided.

Secured Storage 120 cubic feet / unit
Must be in addition to
cabinets and closets typically
found within a unit (such as
kitchen and bathroom
cabinets, clothes, and linen
closets)
Consistent. The Project includes 120 cubic
feet per unit provided in either designated
areas for shelves or overhead storage in
garages.

Parking 174 Spaces Required
2 parking spaces per unit,
either enclosed or covered
(i.e., garage or carport). For
Consistent. The Project includes 179 total
spaces, plus one dedicated USPS space.
142 enclosed garages spaces (71 units)
401
50 Development Feature R-3 Zoning Small Lot
Subdivision Standards
Project Consistency
units with 4 or more
bedrooms, 1 additional space
shall be provided on each lot
which may be enclosed or
unenclosed. Enclosed or
covered parking may be
provided in a tandem format,
except for guest parking in
common parking areas.

A minimum of 0.25 spaces
per unit (with a minimum of 2
guest spaces) shall be
provided as easily accessible
and distinguishable guest
parking in addition to the
required parking for each
unit. Guest parking may be
unenclosed.
3 Bed: 114
4 Bed: 42
Guest: 18
Total Required: 174
14 unenclosed on-lot resident spaces (14
four-bedroom units)
23 unenclosed guest spaces
5 surplus parking spaces
Source: Municipal Code Tables 17.14.070 and 17.14.270
As shown in Table AES-1, the Project would adhere to the R-3 development standards with application of the Small Lot Subdivision Ordinance. Therefore, the Project would not conflict with applicable zoning or other regulations governing scenic quality and would not degrade the visual character or quality of the site or surrounding area. Impacts would be less than significant.

Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact. d) The Project site is located within a developed urban area, adjacent to residential, commercial, office and roadways. Existing sources of light in the vicinity of the Project site include streetlights, security lighting, landscape lighting, and lighting from building interiors that pass-through windows.

The Project includes installation of security lighting, signage lighting, parking area lighting, and exterior residential lighting that would have the potential to create a new source of light that could adversely affect nighttime views at adjacent residences. However, lighting on the Project site would be designed, located, and shielded in compliance with Orange Municipal Code Section 17.12.030, which would be verified by the City during the development review and permitting process. Therefore, the increase in light that would be generated by the Project would not adversely affect day or nighttime views in the area, and lighting impacts would be less than significant. 402
51 Reflective light (glare) can be caused by sunlight or artificial light reflecting from finished surfaces such as window glass or other reflective materials. Generally, dark or mirrored glass would have a higher visible light reflectance than clear glass. Buildings constructed of highly reflective materials from which the sun reflects at a low angle can cause adverse glare. The proposed residential structures would include windows; however, the windows would be separated by building stucco and architectural elements and the residences would not be constructed with reflective material. Pursuant to Orange Municipal Code Section 17.12.030, exterior lighting would be shielded or oriented to prevent glare beyond the exterior boundaries of the site. With compliance to City regulations, the Project would not generate substantial sources of glare, and impacts would be less than significant.

Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact.

Existing Plans, Programs, or Policies
PPP AES-1: Exterior Lighting. Exterior lighting on the Project site shall conform to the regulations within Orange Municipal Code Section 17.12.030. Lighting on any premises shall be directed, controlled, screened or shaded in such a manner as not to shine directly on surrounding premises.

Lighting on any residential property shall be controlled so as to prevent glare or direct illumination of any public sidewalk or thoroughfares.

Sources
Caltrans (California Department of Transportation). 2025. California State Scenic Highway System Map:
https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e8057 116f1aacaa. Accessed April 2025.

City of Orange General Plan. [online]: https://www.cityoforange.org/our-city/departments/communitydevelopment/general-plan. Accessed April 2025.

City of Orange Municipal Code. 2022. [online]: https://ecode360.com/OR5214. Accessed April 2025. 403
52 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 California 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:

Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(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?
(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 nonforest use? (e) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to nonagricultural use? Impact Analysis:
a) The Project site is in an urbanized area and void of agricultural uses. The existing site is comprised of a vacant 45,676 square foot retail store building, surface parking lot, and landscaping. The California Department of Conservation Farmland Mapping and Monitoring Program identifies the Project site and surrounding areas as Urban and Built-Up land (CDC 2025). No areas of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance would be affected by the Project or converted to a non-agricultural use. Thus, no impacts would occur.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact. b) As described in the previous response, the Project area is void of any agricultural uses. The Project site is currently zoned C-TR (as shown in Figure 6) and is also surrounded by areas zoned and developed for commercial and residential uses. The Project site and surrounding areas are not under a Williamson Act contract. Therefore, implementation of the Project would not conflict with existing agricultural zoning or a Williamson Act contract, and no impacts would occur.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required. 404
53 Significance Determination After Mitigation: No impact. c) The Project site is developed and located in an area that is completely developed with urban uses. The Project site and vicinity are void of forest land or timberland. In addition, the Project site currently has a land use designation of GC and is zoned C-TR. The surrounding areas are zoned for commercial and residential uses. Therefore, the Project would not conflict with forest land, timberland, or zoning for forest or timberland use and no impacts would occur.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact. d) As described in the previous response, the Project area is void of any forest land and is not zoned for forest uses. Thus, the Project would not result in the loss of forest land or conversion of forest land to non-forest uses and no impacts would occur.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact. e) As described in the previous responses, the Project area does not include and is not near any farmland or forest land or land zoned for either farm or forest uses. No other changes to the existing environment would occur from implementation of the Project that could result in conversion of farmland to nonagricultural use or forest land to non-forest use. Thus, no impacts would occur.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact.

Existing Plans, Programs, or Policies
None.

Sources
California Department of Conservation 2025. Important Farmland Finder. [online]:
https://maps.conservation.ca.gov/DLRP/CIFF/. Accessed April 2025.

City of Orange General Plan: https://www.cityoforange.org/our-city/departments/communitydevelopment/general-plan. Accessed April 2025. 405
54 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:

Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(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?
The discussion below is based on the Air Quality, Energy, and Greenhouse Gas Impact Analysis, included as Appendix A.

Impact Analysis:
a) The Project site is located in the South Coast Air Basin (SCAB), which is within the jurisdictional boundaries of the South Coast Air Quality Management District (SCAQMD). The SCAQMD and Southern California Association of Governments (SCAG) are responsible for preparing the Air Quality Management Plan (AQMP), which addresses federal and state Clean Air Act (CAA) requirements. The 2022 AQMP details goals, policies, and programs for improving air quality in the Basin. The 2022 AQMP is based on General Plan land use designations and regional growth projections developed by SCAG.

As described in Chapter 12, Section 12.2 and Section 12.3 of the SCAQMD’s CEQA Air Quality Handbook (1993), for purposes of analyzing consistency with the AQMP, if a proposed project would result in growth that is substantially greater than what was anticipated, then the proposed project would conflict with the AQMP. On the other hand, if a project’s density is within the anticipated growth of a jurisdiction, its emissions would be consistent with the assumptions in the AQMP, and the project would not conflict with SCAQMD’s attainment plans. In addition, the SCAQMD considers a project consistent with the AQMP if the project would not result in an increase in the frequency or severity of existing air quality violations or cause a new violation.

The Project would redevelop the site to provide 71 residential townhomes on 4.32 gross acres. The Project would not house more than 1,000 persons, occupy more than 40 acres of land, or encompass more than 650,000 square feet of floor area. Thus, the Project would not be defined as a regionally significant project under CEQA and would not meet SCAG’s Intergovernmental Review criteria.

The 2022 AQMP was based on the Project site’s existing General Plan land use designation of General Commercial (GC) that allows a maximum Floor Area Ratio (FAR) of 1.0 and emissions generated by the existing 45,676 square foot retail store building that was constructed in 2007. As detailed in Section, 17, Transportation, the former Best Buy store generated approximately 1,875 daily vehicle trips (Table T-1) and the proposed 71 residential units under the proposed General Plan land use designation of Medium Density Residential (MDR) would generate approximately 511 daily vehicle trips (Table T-2). Thus, the proposed Project would not result in growth in vehicle trips or related emissions and would not conflict with the AQMP attainment plan.

The Orange General Plan and General Plan Program EIR assumed population estimates based on an average of 3.16 persons per single-family dwelling unit and 2.50 persons per multiple-family unit 406
55 (General Plan EIR Table 3-1, page 3-14). The Project would develop 71 townhome residences, which would generate between 178 and 224 residents. According to the California Department of Finance, the City had a population of 139,724 in 2025 with 48,301 housing units. The increase in 71 housing units would equate to a 0.15 percent increase in housing units within the City and the increase of 224 residents would equate to a 0.16 percent increase in population, which is a less than significant increase.

Therefore, Project-generated growth and emissions would be consistent with the 2022 AQMP. In addition, as described in Response 3(b) below, the Project would not generate air quality emissions above SCAQMD significance thresholds during construction or operation. Therefore, impacts related to conflict with the AQMP from the Project would be less than significant.

Significance Determination: Less than significant.

Mitigation Measures: No mitigation required.

Significance Determination After Mitigation: Less than significant. b) The SCAB has a non-attainment status for not meeting federal ozone standards, federal carbon monoxide standards, and state and federal particulate matter standards. Any development in the SCAB, including the Project, could cumulatively contribute to these pollutant violations. SCAQMD has established daily mass thresholds for regional pollutant emissions, listed in Table AQ-1. The methodologies from the SCAQMD CEQA Air Quality Handbook are used to evaluate project impacts, which describes that a project that would exceed any listed thresholds would have both an individually (project-level) and cumulatively significant air quality impact. If estimated emissions are less than the thresholds or reduced to below the thresholds with implementation of mitigation, impacts would be considered less than significant.

Table AQ-1: Maximum Daily Regional Emissions Thresholds Pollutant Construction (lbs/day) Operations (lbs/day)
VOC 75 55
NOx 100 55
CO 550 550
PM10 150 150
PM2.5 55 55
SOx 150 150
lbs/day = pounds per day
VOCs = volatile organic compounds
NOx = nitrogen oxides
CO = carbon monoxide
Source: Appendix A
PM10 = particulate matter less than 10 microns in
size
PM2.5 = particulate matter less than 2.5 microns
in size
SOX = sulfur oxides
Construction
Construction associated with the Project would generate pollutant emissions from the following activities: (1) demolition of the existing structure, foundation, and pavement; (2) site preparation with removal of infrastructure; (3) grading; (4) building construction; (5) paving; and (6) architectural coating/striping. The amount of emissions generated on a daily basis would vary, depending on the intensity and the types of construction activities occurring.

In addition to PM10 and PM2.5 derived from exhaust, emissions resulting from crushing asphalt hardscape had been calculated. It is mandatory for all construction projects to comply with several SCAQMD Rules, including Rule 403 for controlling fugitive dust, PM10, and PM2.5 emissions from construction 407
56 activities. Rule 403 requirements include, but are not limited to: applying water in sufficient quantities to prevent the generation of visible dust plumes, applying soil binders to uncovered areas, reestablishing ground cover as quickly as possible, utilizing a wheel washing system to remove bulk material from tires and vehicle undercarriages before vehicles exit the site, covering all trucks hauling soil with a fabric cover and maintaining a freeboard height of 12-inches, and maintaining effective cover over exposed areas. Compliance with Rule 403 and Rule 1113, included as PPP AQ-2 and PPP AQ-3 respectively, were accounted for in the construction emissions modeling for the Project. Project-generated emissions were calculated using CalEEMod version 2022.1 (provided in Appendix A). As shown in Table AQ-2, construction emissions generated by the Project would not exceed SCAQMD regional thresholds.

Therefore, emissions from construction activities would be less than significant.

Table AQ-2: Construction Regional Emissions Summary
Construction Year
Maximum Daily Regional Emissions
(pounds/day)
ROG NOx CO SO2 PM10 PM2.5
Year 1 (2026) 3.9 34.7 32.1 0.1 7.7 4.4
Year 2 (2027) 66.9 10.5 15.4 <0.01 0.8 0.4
Maximum Daily Emissions 2026-2027 66.9 34.7 32.1 0.1 7.7 4.4 SCAQMD Significance Thresholds 75 100 550 150 150 55
Threshold Exceeded? No No No No No No
Notes: ROG = reactive organic gases, NOx = nitrogen oxides, CO = carbon monoxide, SO2 = sulfur dioxide, PM10 = particulate matter 10 microns in diameter, PM2.5 = particulate matter 2.5 microns in diameter Source: Appendix A.

Operation
Long-term air pollutant emission impacts are those typically associated with mobile sources (e.g., vehicle and truck trips), energy sources (e.g., natural gas), area sources (e.g., architectural coatings and the use of landscape maintenance equipment), and stationary sources (e.g., use of the backup emergency generator and fire pump).

PM10 emissions result from running exhaust, tire and brake wear, and the entrainment of dust into the atmosphere from vehicles traveling on paved roadways. Entrainment of PM10 occurs when vehicle tires pulverize small rocks and pavement, and the vehicle wakes generate airborne dust. The contribution of tire and brake wear is small compared to the other PM emission processes. Gasoline-powered engines have small rates of PM emissions compared with diesel-powered vehicles.

Energy source emissions result from activities in buildings for which natural gas is used. The quantity of emissions is the product of usage intensity (i.e., the amount of natural gas) and the emission factor of the fuel source. Greater building or appliance efficiency reduces the amount of energy for a given activity and thus lowers the resultant emissions. The emission factor is determined by the fuel source, with cleaner energy sources, like renewable energy, producing fewer emissions than conventional sources.

However, the Project would not include natural gas connections, and no natural gas demand is anticipated during operation. Typically, area source emissions consist of direct sources of air emissions located at the Project site, including architectural coatings and the use of landscape maintenance equipment.

As shown in Table AQ-3, the Project would not exceed the significance criteria for VOCs, NOX, CO, SOX, PM10, or PM2.5 emissions. Therefore, the Project would not have a significant effect on regional air quality and operations would not result in a cumulatively considerable net increase of any criteria 408
57 pollutant for which the Project is nonattainment under an applicable federal or State ambient air quality standard. Impacts would be less than significant.

Table AQ-3: Operational Regional Emissions Summary
Operational Activity
Maximum Daily Regional Emissions
(pounds/day)
ROG NOx CO SO2 PM10 PM2.5
Mobile 1.9 1.5 16.6 <0.1 4.3 1.1
Area 4.7 <0.1 4.0 <0.1 <0.1 <0.1
Energy <0.1 0.7 0.3 <0.1 0.1 0.1
Operational Emissions 6.7 2.3 21.0 <0.1 4.4 1.2
SCAQMD Significance Thresholds 55 55 550 150 150 55
Threshold Exceeded? No No No No No No
Notes: ROG = reactive organic gases, NOx = nitrogen oxides, CO = carbon monoxide, SO2 = sulfur dioxide, PM10 = particulate matter 10 microns in diameter, PM2.5 = particulate matter 2.5 microns in diameter Source: Appendix A
Significance Determination: Less than significant.

Mitigation Measures: No mitigation required.

Significance Determination After Mitigation: Less than significant. c) Sensitive receptors are defined as people that have an increased sensitivity to air pollution or environmental contaminants. Sensitive receptor locations include schools, parks and playgrounds, daycare centers, nursing homes, hospitals, and residential dwelling units. The closest sensitive receptors to the Project site are residential uses located to the north and south of the Project site; the closest of which is approximately 16 feet (5 meters) to the south of the Project site boundary.

Localized Significance Analysis
The SCAQMD’s Final Localized Significance Threshold Methodology recommends the evaluation of localized NO2, CO, PM10, and PM2.5 construction-related impacts to sensitive receptors in the immediate vicinity of a project site. Such an evaluation is referred to as a localized significance threshold (LST) analysis. SCAQMD has developed LSTs that represent the maximum emissions from a project that are not expected to cause or contribute to an exceedance of the most stringent applicable federal or state ambient air quality standards and thus would not cause or contribute to localized air quality impacts.

LSTs are developed based on the ambient concentrations of NOx, CO, PM10, and PM2.5 pollutants for each of the 38 source receptor areas (SRAs) in the SCAB. The Project site is located in SRA 17, Central Orange County. Project construction and operation emissions were compared to the LST screening tables in SRA 17, based on a 25-meter source-receptor distance (which is the closest screening distance provided by SCAQMD) and a disturbed acreage of 3.5 acres.

Construction. Table AQ-4 identifies the localized construction emissions at the nearest receptor location in the vicinity of the Project. As shown in Table AQ-4, the proposed Project would not exceed the SCAQMD LST thresholds. Therefore, localized construction air quality impacts would be less than significant. 409
58 Table AQ-4: Localized Emissions from Construction
Construction Year
Maximum Daily Regional Emissions
(pounds/day)
NOx CO PM10 PM2.5
Year 1 (2026) 34.6 31.0 7.4 4.3
Year 2 (2027) 10.2 14.0 0.4 0.3
Maximum Daily Emission 2026-2027 34.6 31.0 7.4 4.3
SCAQMD LST Screening Thresholds1 149 984 9.5 5.5
Threshold Exceeded? No No No No
Notes: NOx = nitrogen oxides, CO = carbon monoxide, PM10 = particulate matter 10 microns in diameter, PM2.5 = particulate matter

2.5 microns in diameter
1Significance thresholds obtained by interpolating values for 2 acres and 5 acres at a receptor distance of 25 meters.

Source: Appendix A
Operation. According to the SCAQMD LST methodology, LSTs apply to a project’s stationary and on-site mobile sources. Projects that involve mobile sources that spend long periods queuing and idling at a site, such as transfer facilities or warehousing and distribution buildings, have the potential to exceed the operational LSTs. The proposed Project consists of 71 residences and is not anticipated to result in significant vehicle idling or queuing activity. Therefore, due to the lack of significant stationary source emissions, impacts related to operational LSTs would be less than significant.

Significance Determination: Less than significant.

Mitigation Measures: No mitigation required.

Significance Determination After Mitigation: Less than significant. d) The Project would not emit other emissions, such as those generating objectionable odors, that would affect a substantial number of people. The threshold for odor is identified by SCAQMD Rule 402, Nuisance, which states:

A person shall not discharge from any source whatsoever such quantities of air contaminants or other material which cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property. The provisions of this rule shall not apply to odors emanating from agricultural operations necessary for the growing of crops or the raising of fowl or animals.

The SCAQMD lists land uses primarily associated with odor complaints as agricultural uses, wastewater treatment plants, food processing plants, chemical plants, composting operations, refineries, landfills, dairies, and fiberglass molding facilities. Residential uses are not associated with objectionable odors.

During construction, some odors may be present due to diesel exhaust. However, these odors would be temporary and limited to the construction period. The Project would not include any activities or operations that would generate objectionable odors and once operational, the Project would not be a source of odors. The Project would also be required to comply with SCAQMD Rule 402, as included in PPP AQ-1, which would prevent occurrences of public nuisances. Therefore, odors associated with the Project would be less than significant.

Significance Determination: Less than significant.

Mitigation Measures: No mitigation required.
410
59 Significance Determination After Mitigation: Less than significant.

Existing Plans, Programs, or Policies
PPP AQ-1: Rule 402. The Project is required to comply with the provisions of South Coast Air Quality Management District (SCAQMD) Rule 402. The Project shall not discharge from any source whatsoever such quantities of air contaminants or other material which cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property.

PPP AQ-2: Rule 403. The Project is required to comply with the provisions of South Coast Air Quality Management District (SCAQMD) Rule 403, which includes the following:
• All clearing, grading, earth-moving, or excavation activities shall cease when winds exceed 25 mph per SCAQMD guidelines in order to limit fugitive dust emissions. • The contractor shall ensure that all disturbed unpaved roads and disturbed areas within the Project are watered, with complete coverage of disturbed areas, at least 3 times daily during dry weather; preferably in the mid-morning, afternoon, and after work is done for the day. • The contractor shall ensure that traffic speeds on unpaved roads and Project site areas are reduced to 15 miles per hour or less.

PPP AQ-3: Rule 1113. The Project is required to comply with the provisions of South Coast Air Quality Management District Rule (SCAQMD) Rule 1113. Only “Low-Volatile Organic Compounds” paints (no more than 50 gram/liter of VOC) and/or High Pressure Low Volume (HPLV) applications shall be used.

Sources:

Air Quality, Energy, and Greenhouse Gas Impact Analysis. 2025. Prepared by EPD Solutions. (Appendix A).
411
60 4. BIOLOGICAL RESOURCES.

Would the project:

Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(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:
a) The Project site is fully developed and currently contains a vacant 45,676 square foot retail store building, surface parking lot, and non-native ornamental landscaping. The surrounding area is urbanized with residential and commercial buildings and roadways. No endangered, rare, threatened, or special status plant species (or associated habitats) or wildlife species designated by the U.S. Fish and Wildlife Service (USFWS), California Department of Fish and Wildlife (CDFW), or California Native Plant Society (CNPS) occur on or adjacent to the site due to lack of habitat.

The Project would redevelop the site with residences, parking areas, open space recreation areas, which would include installation of new ornamental landscaping. As no sensitive species or habitats are located within the urban and developed site, implementation of the Project would not result in a substantial adverse effect, either directly or through habitat modifications, on any sensitive species, and no impacts would occur.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact. b) Riparian habitats occur along the banks of rivers and streams. Sensitive natural communities are natural communities that are considered rare in the region by regulatory agencies, known to provide habitat for sensitive animal or plant species, or known to be important wildlife corridors. As previously described, the Project site is fully developed and located in an urbanized area and does not contain any riparian or riverine features. According to the National Wetlands Inventory, no riparian habitat or other sensitive natural communities occur on or adjacent to the Project site (USFWS 2025). Additionally, the 412
61 Project site and adjacent areas are not included in any local or regional plans, policies, and regulations that identify riparian habitat or other sensitive natural community. Therefore, no impacts would occur.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact. c) Wetlands are defined under the Federal Clean Water Act as land that is flooded or saturated by surface water or groundwater sufficient to support vegetation adapted to saturated soils. Wetlands include areas such as swamps, marshes, and bogs. As previously described, the Project is fully developed and located in an urbanized area and does not contain any wetlands (USFWS 2025). Therefore, the redevelopment of the Project site would not result in impacts to wetlands.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact. d) Wildlife corridors are linear features that connect areas of open space and provide avenues for the migration of animals and access to additional areas of foraging. The Project site is within an urbanized area and is developed, paved, and surrounded on three sides by walls. The Project site is surrounded by residential and commercial uses and roadways. Therefore, the Project site does not contain, and is not adjacent to, any wildlife corridors.

The Project site currently contains 86 ornamental trees in the parking area and adjacent to the site perimeter that may be utilized by nesting birds and raptors during the nesting bird season of February 1 through August 31. If vegetation is required to be removed during nesting bird season, Mitigation Measure BIO-1 has been included to require a nesting bird survey to be conducted prior to initiating vegetation clearing to ensure that nesting birds are not harmed during Project construction. The Project includes approximately 30,309 square feet (16.4% of the site) of landscaping with 24-inch and 36-inch box trees, 15-gallon trees, various shrubs, and groundcover. Although most of the existing trees would be removed and replaced in open space areas, the Project would retain 13 date palm trees that line the entrance to the site. With the implementation of Mitigation Measure BIO-1, impacts related to nesting birds would be reduced to a less than significant level.

Significance Determination: Less than significant with mitigation incorporated.

Mitigation Measures:

MM BIO-1: Pre‐construction Nesting Bird Survey. Construction plans and Project specifications shall state that if construction or vegetation removal activities are scheduled to occur during the bird breeding season (February 1 through August 31), a pre‐construction nesting bird survey shall be conducted by a qualified biologist to ensure that active bird nests will not be disturbed or destroyed. The survey shall be completed no more than three days prior to initial ground disturbance. The nesting bird survey shall include the Project area and adjacent areas where Project activities have the potential to affect active nests, either directly or indirectly due to construction activity or noise. If an active nest is identified, a qualified biologist shall establish an appropriate disturbance limit buffer around the nest using flagging or staking. Construction activities shall not occur within any disturbance limit buffer zones until the nest is deemed inactive by the qualified biologist.

Significance Determination After Mitigation: Less than significant. 413
62 e) The Project contains ornamental trees in the parking area and adjacent to the site perimeter. The Project would replace most of the existing trees and install new landscaping as shown in Figure 18, Conceptual Landscape Plan. The City’s participation in the Natural Community Conservation Planning (NCCP) program and the Master Street Tree Plan are the primary local measures to protect biological resources. Orange Municipal Code Chapter 12.28 prohibits the removal of trees, including historic trees, from undeveloped and public interest property without a permit. In addition, the removal of recognized City of Orange Street Trees must be approved by the Director of Public Works and must comply with the provisions within the Master Street Tree Plan. These requirements include replacement or relocation of trees as necessitated. The Project would not include removal of trees from an undeveloped property or a public right-of-way. With City review and approval of the proposed landscaping site plan, the Project would not conflict with local policies and impacts would be less than significant.

Significance Determination: Less than significant.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant. f) The City is a participant in the Orange County NCCP, which was approved in 1996. As shown in Figure 5.4-2, NCCP Habitat Reserve Area, from the Orange General Plan Program EIR, the Project site is not identified as a reserve, non-reserve open space, or special linkage. As such, the Project would not conflict with any of the provisions set forth in the Orange County NCCP. The Project site does not fall within any other local or regional conservation plans. Therefore, no conflict with such plans is identified and no impacts would occur.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact.

Existing Plans, Programs, or Policies
None.

Sources
Tree Survey and Arborist Report. June 2025. Prepared by CalPacific Sciences. Appendix B City of Orange. Master Street Tree Plan. [online]:
https://www.cityoforange.org/home/showpublisheddocument/336/637699043683430000.

Accessed March 2025.

City of Orange. 2010. Orange General Plan Program Environmental Impact Report. [online]:
https://www.cityoforange.org/home/showpublisheddocument/240/637698173340500000.

Accessed March 2025.

City of Orange Municipal Code. 2025. [online]: https://ecode360.com/OR5214. Accessed March 2025.

USFWS (United States Fish and Wildlife Service). 2025. National Wetlands Inventory. [online]:
https://fwsprimary.wim.usgs.gov/wetlands/apps/wetlands-mapper/. Accessed March 2025. 414
63 5. CULTURAL RESOURCES. Would the project:

Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(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 discussion below is based on the Cultural Resources Study prepared by BFSA Environmental included as Appendix C.

Impact Analysis:
a) According to the State CEQA Guidelines, a historical resource is defined as something that meets one or more of the following criteria:
1) Listed in, or determined eligible for listing in, the California Register of Historical Resources; 2) Listed in a local register of historical resources as defined in Public Resources Code (PRC) Section 5020.1(k);
3) Identified as significant in a historical resources survey meeting the requirements of PRC Section 5024.1(g); or
4) Determined to be a historical resource by the project’s Lead Agency.

A record search of the California Historic Resources Information System (CHRIS) was completed at the South Central Coastal Information Center (SCICC) at California State University, Fullerton (CSU Fullerton) for the Project site and a one-mile radius. The search indicated that seven historic resources have been identified within a mile of the Project site. However, no historic resources were identified as within or adjacent to the Project site. Additionally, no historical resources were identified during the field survey. The Project site contains a vacant Best Buy commercial retail building and parking lot built in 2007, which does not meet the minimum age threshold of 50 years to be considered potentially historic in accordance with CEQA. Therefore, impacts related to historic resources would not occur.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact
b) As part of the Cultural Resources Study prepared for the Project, all pertinent data within a one-mile radius surrounding the Project area, including a review of the National Register of Historic Places index, USGS data, and historic photographs were researched. Based on aerial photographs, the Project site was used as an agricultural grove as early as 1923. The grove is visible through 1963; however, by 1972 it had been removed and a commercial structure (bowling alley) with parking was developed onsite.

Between 1972 and 2005 that structure and lot appear unaltered. Sometime around 2005 that structure was demolished and in 2007 the existing structure was developed onsite (Appendix C).

No archaeological resources were identified within the Project site as part of the records search with SCCIC (Appendix C). Also, the Sacred Lands File (SLF) search results were negative for any recorded 415
64 Native American sacred sites or locations of religious or ceremonial importance within the project vicinity. In addition, the Geotechnical and Infiltration Evaluation describes that the onsite soils consist of three to 5.5 feet of artificial fill overlying late to middle Pleistocene aged old alluvial fan deposits. As a result, the Cultural Resources Study (Appendix C) determined that due to the disturbed nature of the site from previous agricultural use (1946 to 1966), development occurring in 1972 and 2007, and existence of fill soils in the site, there is little to no potential for the inadvertent discovery of significant archaeological deposits. Thus, impacts would be less than significant.

Significance Determination: Less than significant.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact. c) The Project site has not been previously used as a cemetery. Thus, human remains are not anticipated to be uncovered during construction. In the event of an accidental discovery of any human remains, California Health and Safety Code Section 7050.5 requires that disturbance of the site shall remain halted until the coroner has conducted an investigation into the circumstances, manner, and cause of death, and made recommendations concerning the treatment and disposition of the human remains to the person responsible for the excavation, or to his or her authorized representative. Pursuant to Section 5097.98 of the California Public Resources Code, as included as PPP CUL-1, if the coroner determines that the remains are not subject to his or her authority and if the coroner has reason to believe the human remains to be those of a Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission. Compliance with existing law would ensure that no impacts to human remains would occur.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact.

Existing Plans, Programs, or Policies
PPP CUL-1: Human Remains. In the event that human remains are encountered on the Project site, work within 50 feet of the discovery shall cease and the County Coroner shall be notified immediately consistent with the requirements of CEQA Guidelines Section 15064.5(e). State Health and Safety Code Section 7050.5 states that no further disturbance shall occur until the County Coroner has made a determination of origin and disposition pursuant to Public Resources Code (PRC) Section 5097.98. Prior to the issuance of grading permits, the City Community and Planning, Building, and Code Enforcement Department Director, or designee, shall verify that all grading plans specify the requirements of CEQA Guidelines Section 15064.5(e), Health and Safety Code Section 7050.5, and PRC Section 5097.98, as stated above.

Sources
Cultural Resources Study. 2025. Prepared by BFSA Environmental Services. (Appendix C). 416
65 6. ENERGY. Would the project:

Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
(b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
The discussion below is based on the Air Quality, Energy, and Greenhouse Gas Impact Analysis, included as Appendix A.

Impact Analysis:
a) The proposed 71 residences would not result in wasteful, inefficient, or unnecessary consumption of energy resources during either construction or operation.

Construction
During the 14-month construction period, energy would be consumed in three general forms listed below. No natural gas use is anticipated to be used during construction.

1. Petroleum-based fuels used to power off-road construction vehicles and equipment, construction worker travel to and from the site, as well as delivery truck trips;

2. Electricity associated with providing temporary power for lighting and electric equipment; and

3. Energy used in the production of construction materials, such as asphalt, paint, fencing, lighting, and gate materials.

Transportation energy represents the largest energy use during construction and would occur from the transport and use of construction equipment, delivery vehicles and haul trucks, and construction worker vehicles that would use petroleum fuels (e.g., diesel fuel and/or gasoline). Therefore, the analysis of energy use during construction focuses on fuel consumption. Haul trucks, construction trucks, and vendor trucks are anticipated to use diesel fuel, whereas construction workers travel are anticipated to use gasoline-powered vehicles. Estimates of diesel and gasoline fuel usage were based on default construction equipment assumptions and trip estimates from CalEEMod version 2022.1 and fuel efficiencies from EMFAC2021. The equipment total fuel consumption is a conservative estimate and likely overstates the amount of fuel usage, as various pieces of construction equipment are not expected to operate during the entire duration of the construction activity. Fuel consumption estimates are shown below in Table E-1.

Table E-1: Estimated Project Construction Energy Usage
Source Diesel Fuel (Gallons) Gasoline Fuel (Gallons)
Proposed Project On-Road Construction Vehicles 20,357 10,431 Proposed Project Off-Road Construction Equipment 28,458 0 Proposed Project Total Consumption 48,815 10,431
Orange County On-Road Vehicles 148,172,563 907,921,969
Orange County Off-Road Construction Equipment 14,253,307 977,564 On-Road Project Percentage (%) 0.014 0.001
Off-Road Project Percentage (%) 0.200 -
Source: Appendix A
417
66 As shown in Table E-1, the Project is estimated to consume a total of approximately 48,815 gallons of diesel fuel and approximately 10,431 gallons of gasoline fuel during construction. According to the projected 2026 fuel consumption data obtained from EMFAC2025 for Orange County, on-road vehicles would consume approximately 148,172,563 gallons of diesel fuel and 907,921,969 gallons of gasoline.

On-road construction vehicles from the proposed Project would account for 0.014 percent of diesel fuel consumption and 0.001 percent of gasoline fuel consumption within Orange County in 2026. Off-road consumption within Orange County in 2026 would total approximately 14,253,307 gallons of diesel fuel and 977,564 gallons of gasoline fuel. Off-road construction equipment from the proposed Project would account for 0.2 percent of diesel consumption within Orange County in 2026.

As such, Project construction would have a negligible effect on energy supplies within Orange County.

Additionally, through construction permitting, the Project would be required to comply with regulations implemented to reduce emissions from construction, such as CCR Title 13, Motor Vehicles, Section 2449(d)(3), Idling, which limits idling times of construction vehicles to no more than 5 minutes. Thus, construction of the Project would not result in wasteful, inefficient, or unnecessary consumption of energy, and the proposed Project would result in less-than-significant energy impacts during construction. No mitigation would be required.

Operation
The operation of the proposed Project would consume electricity and petroleum. Pursuant to Title 24 Part 6 standards, the Project would be required to be all-electric. Therefore, the Project would not consume natural gas during operation. However, to provide a conservative analysis of energy impacts, default natural gas consumption values from CalEEMod have been included.

The Project would be required to install solar panels in accordance with Title 24, Part 6 requirements.

However, the Project’s energy consumption, shown below in Table E-2, presents a conservative estimate of energy consumption without taking credit for solar use. As shown, operation of the proposed 71 residences is estimated to use 502,606 kilowatt-hours of electricity and 77,411 gallons of gasoline per year.

The most recent data available for electricity and natural gas usage from the California Energy Commission is from 2023. In 2023, electricity consumption in Orange County was estimated at 18,759,000,000 kilowatt-hours and natural gas consumption was estimated at 60,825,476,870 thousand British thermal units. As shown in Table E-2, the proposed Project would result in a 0.003 percent increase in electricity consumption and a 0.004 percent increase in natural gas consumption within Orange County. Also, the proposed Project operations would account for 0.009 percent of gasoline fuel consumption in Orange County.

The Project would be required to adhere to all federal, State, and local requirements for energy efficiency, including the Title 24 standards, listed as PPP-1. Title 24 building energy efficiency standards establish minimum efficiency standards related to various building features, including appliances, water and space heating and cooling equipment, building insulation and roofing, solar, and lighting, which would reduce energy usage.
418
67 Table E-2: Estimated Annual Project Operational Energy Usage Electricity (Kilowatt-Hours)
Proposed Project 502,606
Orange County (2023) 18,759,000,000
Project Percent Increase (%) 0.003
Natural Gas (Thousands British Thermal Units)
Proposed Project 2,721,810
Orange County (2023) 60,825,476,870
Project Percent Increase (%) 0.004
Petroleum (Gasoline) Consumption
Annual VMT Gallons of Gasoline
Fuel
Proposed Project 1,881,157 77,411
Orange County (2026) - 907,921,969
Project Percentage (%) - 0.009
Notes: VMT = vehicle miles traveled
Source: Appendix A
Fuel consumption associated with vehicle trips generated by Project operations would not be considered inefficient, wasteful, or unnecessary in comparison to other similar developments in the region. Overall, there are no unusual Project characteristics that would cause the use of energy that would be less energy efficient compared with other similar residential projects throughout the state. Therefore, impacts would be less than significant.

Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact. b). The proposed Project would be required to meet the Calgreen energy efficiency standards in effect during permitting of the Project, which are included in Chapter 15.17 of the City of Orange Municipal Code. The City’s administration of the requirements includes review of design components and energy conservation measures during the permitting process, which ensures that all requirements are met. In addition, the Project would not conflict with or obstruct opportunities to use renewable energy, such as solar energy, which would be included on the residential rooftops as required by the existing Title 24 standards that are adopted by reference in Chapter 15.54 of the City of Orange Municipal Code. As such, the Project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency, and impacts would not occur.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact.

Existing Plans, Programs, or Policies
PPP E-1. Title 24 and CalGreen Compliance: The Project is required to comply with the Title 24 standards that are adopted by reference in Chapter 15.54 of the City of Orange Municipal Code and the CalGreen Building Code as included in the Orange Municipal Code Section 15.17.010 to ensure efficient use of energy. Title 24 and CalGreen specifications are required to be incorporated into building plans as a condition of building permit approval.
419
68 Sources
Air Quality, Energy, and Greenhouse Gas Impact Analysis. 2025. Prepared by EPD Solutions, Inc. (Appendix A).
420
69 7. GEOLOGY AND SOILS. Would the project:

Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(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 onor 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 discussion below is based on the Geotechnical and Infiltration Evaluation, included as Appendix D and the Paleontological Resources Assessment, included as Appendix E.

Impact Analysis:
a) i) The Project site is not located within an Alquist-Priolo Earthquake Fault Zone. The nearest AlquistPriolo Fault Zone and known active fault is the Elsinore fault (Whittier Section), located approximately

6.4 miles north of the Project site. Additionally, there are no known active faults traversing the site (Appendix D). Thus, the Project would not expose people or structures to potential substantial adverse effects from rupture of a known earthquake fault that is delineated on an Alquist-Priolo Earthquake Fault Zoning Map, and impacts would not occur.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact. a) ii) The Project site is located within a seismically active region of Southern California. According to the Geotechnical and Infiltration Evaluation, the nearest fault to the Project site is the is the Elsinore fault (Whittier Section) located approximately 6.4 miles north of the site. However, other active faults are located across the region. Thus, moderate to strong ground shaking can be expected at the site. The amount of motion can vary depending upon the distance to the moving fault, the magnitude of the earthquake, and the local geology.
421
70 Structures built in the City are required to be built in compliance with the California Building Code (CBC [California Code of Regulations, Title 24, Part 2]), included in Orange Municipal Code Chapter

15.04. In addition, PPP GEO-1 has been included to provide CBC provisions for earthquake safety based on factors including occupancy type, the types of soils onsite, and the probable strength of the ground motion. Compliance with the CBC would include the incorporation of: 1) seismic safety features to minimize the potential for significant effects as a result of earthquakes; 2) proper building footings and foundations; and 3) construction of the building structures so that it would withstand the effects of strong ground shaking. With compliance to the CBC, the Project would result in a less than significant impact related to strong seismic ground shaking.

Significance Determination: Less than significant.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant. a) iii) Liquefaction is a seismic phenomenon in which loose, saturated, granular soils behave similarly to a fluid when subjected to high-intensity ground shaking. Liquefaction occurs when three general conditions exist: 1) shallow groundwater; 2) low density, fine, clean sandy soils; and 3) strong ground motion. Effects of liquefaction can include sand boils, settlement, and bearing capacity failures below structural foundations. Soils that are most susceptible to liquefaction are clean, loose, saturated, and uniformly graded fine-grained sands that lie below the groundwater table within approximately 50 feet below ground surface. Lateral spreading is a form of seismic ground failure due to liquefaction in a subsurface layer.

The Project site is not located within an area identified as being potentially susceptible to liquefaction (Appendix D). The soils onsite are primarily comprised of clay, clayey sand, silty sands and fine to coarse gravel. Additionally, water was not encountered during soil borings which reached a maximum depth of 26.5± feet. The California Water Data Library shows that the depth of historic groundwater at the site is greater than 40 feet below existing grades. Due to the absence of low-density sandy soils and relatively deep groundwater, the liquefaction potential at the site is very low (Appendix D).

Furthermore, structures built in the City are required to be built in compliance with the CBC, as included in Orange Municipal Code Chapter 15.04 (and herein as PPP GEO-1), which implements specific requirements for seismic safety, excavation, foundations, retaining walls and site demolition.

Compliance with the CBC, as included as PPP GEO-1, would require specific engineering design recommendations be incorporated into grading plans and building specifications as a condition of construction permit approval to ensure that structures would withstand the effects of seismic ground movement, including liquefaction and settlement. Compliance with the requirements of the CBC and the Orange Municipal Code for structural safety, included as PPP GEO-1, would reduce hazards from seismic-related ground failure to a less than significant level.

Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact. a) iv) Landslides and other slope failures are secondary seismic effects of earthquakes. Areas that are most susceptible to earthquake-induced landslides are steep slopes underlain by loose, weak soils, and areas on or adjacent to existing landslide deposits.
422
71 As described above, the Project site is located in a seismically active region subject to strong ground shaking. However, the site is generally flat and does not contain any hills or any other areas that could be subject to landslides. The Geotechnical and Infiltration Evaluation states that site elevations range from 271 feet above sea level (amsl) in the northeastern corner to about 263 feet amsl in the southwest corner (Appendix D). In addition, the Project site is not adjacent to any hills or cliffs that could be subject to landslides. Therefore, the Project would not cause potential substantial adverse effects related to slope instability or seismically induced landslides and no impacts would occur.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact. b) Construction. Construction of the Project has the potential to contribute to soil erosion and the loss of topsoil. Grading and excavation activities that would be required for the Project would expose and loosen topsoil, which could be eroded by wind or water. However, the Project would be required to comply with Orange Municipal Code Title 7, Chapter 7.01 which establishes water quality and stormwater discharge standards. This includes installation of best management practices (BMPs) in compliance with the Orange County MS4 Permit to minimize soil erosion. Additionally, the Construction General Permit (CGP; Order No. 2022-0057-DWQ) issued by the State Water Resources Control Board (SWRCB), regulates construction activities to minimize water pollution, including sediment. The proposed Project would be subject to the National Pollution Discharge Elimination System (NPDES) permitting regulations, including implementation of a Stormwater Pollution Prevention Plan (SWPPP) and associated BMPs during grading and construction, which would be required during construction permitting of the Project, as detailed in Section 10, Hydrology and Water Quality, and included as PPP WQ-1. Adherence to the BMPs in the SWPPP would reduce, prevent, or minimize soil erosion from Project-related grading and construction activities, and impacts related to construction would be less than significant.

Operation. After completion, the Project site would be developed with residences, recreation open space, parking, and landscape improvements, and would not contain exposed soil. The proposed Project includes installation of landscaping, such that during operation of the proposed Project substantial areas of loose topsoil that could erode would not exist. In addition, as described in Section 5.10, Hydrology and Water Quality, the onsite drainage features that would be installed by the proposed Project have been designed to slow, filter, and slowly discharge stormwater, which would also reduce the potential for stormwater to erode topsoil during Project operations. Furthermore, implementation of the proposed Project requires City approval of a site-specific Water Quality Management Plan (WQMP) (included as PPP WQ-2), which would ensure that appropriate operational BMPs would be implemented to minimize or eliminate the potential for soil erosion or loss of topsoil to occur. As a result, potential operational impacts related to soil erosion or loss of topsoil would be less than significant.

Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact. c) The Project site is flat and does not contain nor is adjacent to any slope or hillside area. As previously stated, the Project site is not within a landslide hazard area (Appendix D). The Project would not create slopes. Thus, on or offsite landslides would not occur from implementation of the Project. 423
72 Lateral spreading, a phenomenon associated with seismically induced soil liquefaction, is the horizontal displacement of soils due to a reduction in soil cohesion. It is typically exemplified by the formation of vertical cracks on the surface of liquefied soils and usually takes place on gently sloping ground or level ground near drainages or stream channels. Due to the absence of low-density sandy soils and relatively deep groundwater, the potential for lateral spreading is low (Appendix D). Also, as described previously, compliance with the CBC, as included as PPP GEO-1, would require specific engineering design recommendations be incorporated into grading plans and building specifications as a condition of construction permit approval to ensure that Project structures would withstand the effects of related to ground movement, including lateral spreading. Thus, impacts related to lateral spreading would be less than significant.

Differential settlement or subsidence could occur if buildings or other improvements are built on lowstrength foundation materials or if improvements are constructed on different types of subsurface materials (e.g., a boundary between native material and fill). Although differential settlement generally occurs slowly enough that its effects are not dangerous to inhabitants, it can cause building damage over time. Soils susceptible to seismically induced settlement typically include dry loose sands. As previously described, the Project site does not contain such soil types; therefore, risk of settlement or subsidence at the Project site is low (Appendix D). Thus, with compliance with the CBC, included as PPP GEO-1, and compliance with the recommendations of the Geotechnical and Infiltration Evaluation (Appendix D), potential impacts related to settlement or subsidence would be less than significant.

Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact. d) Expansive soils contain certain types of clay minerals that shrink or swell as moisture content changes.

Shrinking or swelling can shift, crack, or break structures built on such soils. Arid or semiarid areas with seasonal changes of soil moisture experiences, such as Southern California, have a higher potential of expansive soils than areas with higher rainfall and more constant soil moisture.

Near-surface soils within the Project site consist of clay, clayey sand, silty sands and fine to coarse gravel. These soils possess a medium to high expansion potential; therefore, the Project includes installation of post-tensioned slab foundation systems for the residential structures to accommodate the soil expansion potential in compliance with the CBC (Appendix D). Compliance with the CBC, as included as PPP GEO-1, would require specific engineering design recommendations for the grading plans and building specifications as a condition of construction permit approval to ensure that structures would withstand the effects of related to ground movement, including expansive soils. Engineering design recommendations would be reviewed and approved by the City’s Building Official or designee prior to issuance of building permits. Thus, impacts would be less than significant.

Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact. e) The Project would connect to existing public wastewater infrastructure and would not require the use of septic tanks or alternative methods of wastewater disposal. Therefore, the Project would not result in any impacts related to this topic.

Significance Determination: No impact.
424
73 Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact. f) Sediments within the Project site were identified as Holocene and late Pleistocene young alluvial fan deposits (Appendix E). The paleontological record search revealed no fossil localities within or adjacent to the Project site. The closest fossil locality is located just over two miles northwest of the Project site, consisting of wild sheep remains in Pleistocene deposits. Between two and three miles to the northeast, proboscidean bones were found in Pleistocene terrace deposits, and a third locality, with Pleistocene rodent remains, is several miles away at the former El Toro marine base (Appendix E).

Holocene alluvium is generally considered to be geologically too young to contain significant nonrenewable paleontological resources (i.e., fossils) and is therefore typically assigned a low paleontological sensitivity. Older Pleistocene (greater than 11,700 years old) alluvial and terrace deposits in the Orange County region, however, often yield important Ice Age terrestrial vertebrate fossils such as extinct mammoths, mastodons, giant ground sloths, extinct species of horse, bison, and camel, sabertoothed cats, and others. Therefore, these Pleistocene sediments are accorded a high paleontological resource sensitivity.

Based upon these criteria, the Holocene to late Pleistocene-aged young alluvial fan deposits at the Project site have a low potential at/near the surface. The Geotechnical and Infiltration Evaluation (Appendix E) recommends over-excavation within the proposed building pad area to a depth of five feet below existing grade and to a depth of at least three feet below proposed building pad subgrade elevations, whichever is greater. The Paleontological Assessment determined that the Project grading and excavation would only reach artificial fill soils and Holocene alluvial fan deposits that have a low paleontological sensitivity. Therefore, potential impacts related to paleontological resources would be less than significant.

Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact.

Existing Plans, Programs, or Policies
PPP GEO-1: California Building Code. Prior to issuance of any construction permits, the project is required to demonstrate compliance with the California Building Code as included in the Orange Municipal Code Chapter 15.04 to preclude significant adverse effects associated with seismic hazards, including expansive and corrosive soils. California Building Code related and geologist and/or civil engineer specifications for the project are required to be incorporated into grading plans and specifications as a condition of construction permit approval.

PPP WQ-1: NPDES/SWPPP. Included in Section 5.10, Hydrology and Water Quality.

PPP WQ-2: WQMP. Included in Section 5.10, Hydrology and Water Quality.

Sources
Geotechnical and Infiltration Evaluation. 2024. Prepared by Geotek. (Appendix D). 425
74 Paleontological Assessment. 2025. Prepared by BFSA Environmental Services Company. (Appendix E).

City of Orange. 2010. Orange General Plan, Public Safety Element (Figure PS-1). [online]:
https://www.cityoforange.org/home/showpublisheddocument/214/637698172567530000.

Accessed April 2025.

USGS and CGS (U.S. Geological Survey and California Geological Survey). Quaternary Fault and Fold Database of the United States. [online]: https://www.usgs.gov/natural-hazards/earthquakehazards/faults. Accessed April 2025. 426
75 8. GREENHOUSE GAS EMISSIONS.

Would the project:

Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
(b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
The discussion below is based on the Air Quality, Energy, and Greenhouse Gas Impact Analysis, included as Appendix A.

Impact Analysis:
a) The City’s Guidance for Greenhouse Gas Emissions Analysis Memo states that the City utilizes the Tier 3 quantitative thresholds recommended in the SCAQMD’s Interim CEQA GHG Significance Threshold for Stationary Sources, Rules and Plans. The SCAQMD formed a working group to identify greenhouse gas emissions thresholds for land use projects that could be used by local lead agencies in the Basin in 2008. The working group developed several different options that are contained in the SCAQMD Draft Guidance Document – Interim CEQA Greenhouse Gas Significance Threshold, that could be applied by lead agencies, which includes the following tiered approach:
• Tier 1 consists of evaluating whether or not the project qualifies for any applicable exemption under CEQA.
• Tier 2 consists of determining whether the project is consistent with a greenhouse gas reduction plan. If a project is consistent with a qualifying local greenhouse gas reduction plan, it does not have significant greenhouse gas emissions.
• Tier 3 consists of screening values, which the lead agency can choose, but must be consistent with all projects within its jurisdiction. A project’s construction emissions are averaged over 30 years and are added to the project’s operational emissions. If a project’s emissions are below one of the following screening thresholds, then the project is less than significant:
o All land use types: 3,000 MTCO2e per year
o Based on land use type:
 Residential: 3,500 MTCO2e per year
 Commercial: 1,400 MTCO2e per year
 Mixed use: 3,000 MTCO2e per year
• Tier 4 has the following options:
o Option 1: Reduce business as usual emissions by a certain percentage; this percentage is currently undefined.
o Option 2: Early implementation of applicable AB 32 Scoping Plan measures. o Option 3, 2020 Target: For service populations (SP), including residents and employees,

4.8 MTCO2e /SP/year for projects and 6.6 MTCO2e /SP/year for plans. o Option 3, 2035 Target: 3.0 MTCO2e /SP/year for projects and 4.1 MTCO2e /SP/year for plans.

The SCAQMD’s interim thresholds used the Executive Order S-3-05-year 2050 goal as the basis for the Tier 3 screening level. Achieving the Executive Order’s objective would contribute to worldwide efforts to cap CO2 concentrations at 450 ppm, thus stabilizing global climate. 427
76 Based on the foregoing guidance, the City of Orange has elected to rely on compliance with a local air district threshold in the determination of significance of Project-related GHG emissions. Specifically, the City has selected the interim 3,000 MTCO2e/yr threshold recommended by SCAQMD staff for residential and commercial sector projects against which to compare Project-related GHG emissions.

The City understands that the 3,000 MTCO2e/yr threshold for residential/commercial uses was proposed by SCAQMD a decade ago and was adopted as an interim policy; however, no permanent, superseding policy or threshold has since been adopted. The 3,000 MTCO2e/yr threshold was developed and recommended by SCAQMD, an expert agency, based on substantial evidence as provided in the Draft Guidance Document – Interim CEQA Greenhouse Gas Significance Threshold (2008) document and subsequent Working Group meetings (latest of which occurred in 2010). SCAQMD has not withdrawn its support of the interim threshold and all documentation supporting the interim threshold remains on the SCAQMD website on a page that provides guidance to CEQA practitioners for air quality analysis (and where all SCAQMD significance thresholds for regional and local criteria pollutants and toxic air contaminants also are listed). Further, as stated by SCAQMD, this threshold “uses the Executive Order S-3-05 goal [80% below 1990 levels by 2050] as the basis for deriving the screening level” and, thus, remains valid for use in 2022. Lastly, this threshold has been used for hundreds, if not thousands of GHG analyses performed for projects located within the SCAQMD jurisdiction.

Thus, for purposes of analysis in this analysis, if Project-related GHG emissions do not exceed the 3,000 MTCO2e/yr threshold, then Project-related GHG emissions would clearly have a less than significant impact.

Construction
Demolition and construction activities associated with the Project would produce combustion emissions from various sources. GHGs would be emitted through the operation of construction equipment and from worker and builder supply vendor vehicles, each of which typically use fossil-based fuels to operate. The combustion of fossil-based fuels creates GHGs such as CO2, CH4, and N2O. Furthermore, CH4 is emitted during the fueling of heavy equipment. Exhaust emissions from on-site construction activities would vary daily as construction activity levels change.

The SCAQMD does not have an adopted threshold of significance for construction-related GHG emissions. However, lead agencies are required to quantify and disclose GHG emissions that would occur during construction. The SCAQMD then requires the construction GHG emissions to be amortized over the life of a project, defined by the SCAQMD as 30 years, added to the operational emissions, and compared to the applicable interim GHG significance threshold tier. Using CalEEMod version 2022.1, it is estimated that the Project would generate approximately 494 MT CO2e during construction of the Project. When annualized over the 30-year life of the Project, annual emissions would be 16 MT CO2e, as shown in Table GHG-1.
428
77 Table GHG-1: Project Construction Greenhouse Gas Emissions Construction Year (Phase) Annual GHG Emissions (MTCO2e) Year 1 (2026) 217
Year 2 (2027) 277
Total Emissions 494
Total Emissions Amortized Over 30 Years 16
Source: Appendix A.

Operation
Operational or long-term GHG emissions are typically generated from mobile sources, area sources, stationary sources, indirect emissions from sources associated with energy consumption, waste sources, and water sources. Mobile-source GHG emissions would include Project-generated vehicle trips to and from the site. Area-source emissions would be associated with activities such as landscaping and maintenance. Energy source emissions would be generated at off-site utility providers from electricity demand generated by the Project. Waste source emissions include those generated by land filling and other methods of disposal related to transporting and managing Project-generated waste. In addition, water source emissions associated with the Project are generated by water supply and conveyance, water treatment, water distribution, and wastewater treatment. Following guidance from the SCAQMD, GHG emissions were estimated using CalEEMod version 2022.1, shown in Table GHG-1.

As discussed above, a project would have less than significant GHG emissions if it would result in operational-related GHG emissions of less than 3,000 MT CO2e/yr. Based on the analysis results, the Project would result in approximately 896 MT CO2e/yr, is less than the SCAQMD threshold of 3,000 MT CO2e/yr. Therefore, construction and operation of the Project would not generate GHG emissions that would have a significant effect on the environment and impacts would be less than significant.

In addition, The City of Orange Guidance for Greenhouse Gas Emissions Analysis Memo requests project GHG analyses include comparison of project emissions to the City’s GHG inventory contained in the 2010 General Plan EIR. The GHG emissions inventory in the General Plan is from the year 2004 and totals 2,072,493 MTCO2e per year (City of Orange, 2010, pp. 5.15-21). Buildout of the General Plan (by 2030) was estimated to result in annual emissions of 3,159,568 MTCO2e. The proposed Project would result in a 0.04 percent increase and 0.03 percent increase compared to the 2004 levels and estimated 2030 levels, respectively, which is less than significant. 429
78 Table GHG-2: Total Project Greenhouse Gas Emissions
Activity Annual GHG Emissions (MTCO2e)
Mobile 629
Area 1
Energy 224
Water 7
Waste 18
Refrigeration <0.1
Project Operation Emissions 879
Project Construction Emissions 16
Total Project Emissions 896
2004 GHG Emissions Inventory 2,072,493
Percent Increase 0.04
Significance Threshold 3,000
Threshold Exceeded? No
Note: Numbers have been rounded.

Source: Appendix A
Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact. b) The proposed Project would redevelop the site with 71 residences that would comply with state programs that are designed to be energy efficient. The Project would not conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases. As described in the previous response, the Project would not exceed the GHG emissions threshold that is based on the Executive Order S-3-05 year 2050 goal. In addition, the project would comply with regulations imposed by the state and the SCAQMD that reduce GHG emissions, as described below:
• Global Warming Solutions Act of 2006 (AB 32) is applicable to the Project because many of the GHG reduction measures outlined in AB 32 (e.g., low carbon fuel standard, advanced clean car standards, and cap-and-trade) have been adopted and implementation activities are ongoing. The advanced clean car standards are regulations for car manufacturers; and cap-and-trade refers to a policy tool where emissions from a certain region or sector (e.g., electricity generation, petroleum refining, cement production) are limited to a certain amount and emissions reductions can be traded ultimately providing flexibility on how the emitter can comply. The Project would redevelop the Project site for new residences that would not conflict with automobile fuel regulations, car standards, or cap-and-trade. The Project would include solar infrastructure and electric vehicle plug in facilities as required by CalGreen/Title 24 regulations that are adopted by reference in Chapter 15.17 of the City of Orange Municipal Code. • Title 24 California Code of Regulations (Title 24 / California Energy Code) establishes energy efficiency requirements for new construction that address the energy efficiency of new (and altered) residences and related infrastructure, appliances, irrigation. Title 24 is adopted by reference in Chapter 15.54 of the City of Orange Municipal Code and provides for efficient energy and water consumption. The City’s administration of the requirements includes review of the energy conservation measures during the permitting process, which ensures that all requirements are met.
430
79 • Title 17 California Code of Regulations (Low Carbon Fuel Standard [LCFS]) requires low carbon content of fuel sold in California. Because the LCFS applies to any transportation fuel that is sold or supplied in California, all vehicles trips generated by the Project within the state would comply with LCFS.
• California Water Conservation in Landscaping Act of 2006 (AB 1881) provides requirements to ensure water efficient landscapes in new development and reduced water waste in existing landscapes. The Project is required to comply with AB 1881 landscaping requirements pursuant to the Title 24 regulations in Chapter 15.54 of the City of Orange Municipal Code, which would be verified by the City during the Project permitting process. 2022 CARB Scoping Plan
The 2022 CARB Scoping Plan Update sets the GHG emission reduction target for 2045 at 85 percent below 1990 levels, which was codified by SB 32. Table GHG-3 lists all GHG reduction policies applicable to residential developments. The following table also includes policies from Appendix D of the Scoping Plan, which provide GHG reduction policies for local governments to implement. The local action policies are focused on climate action planning and approval of new land use development projects. As shown below, the proposed Project would not conflict with any plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs within the 2022 Scoping Plan.

Table GHG-3: 2022 Scoping Plan Consistency Summary
Action Consistency
GHG Emissions Reductions Relative to the SB 32 Target
40% Below 1990 levels by 2030. Consistent. The Project would comply with Title 24, Part 6 building energy requirements along with other
local and State initiatives that aim to achieve the 40
percent below 1990 levels by 2030 goal.

Smart Growth/Vehicle Miles Traveled VMT
VMT per capita reduced 25% below 2019 levels
by 2030, and 30% below 2019 levels by 2045.

Consistent. The Project proposes the development
of a medium density residential community within a
mixed use area near transit, pedestrian facilities, and the freeway. As previously discussed in the air
quality section, the Project would be consistent with
the growth assumptions in the 2020 Connect SoCal,
so the Project would not interfere with the analysis
completed for the Connect SoCal report outlining
VMT reduction targets and measures.

Light-Duty Vehicle (LDV) Zero-Emission Vehicles (ZEVs)
100% of LDV sales are ZEV by 2035. Consistent. The proposed Project would be designed and constructed in accordance with Title 24 Part 6
and Part 11 requirements, which includes
constructing homes to allow for electric vehicle
charging.

New Residential and Commercial Buildings
All electric appliances beginning 2026
(residential) and 2029 (commercial),
Consistent. The Project would comply with Title 24,
Part 6 building energy requirements, which would
431
80 Action Consistency
contributing to 6 million heat pumps installed
statewide by 2030.
require all in-unit appliances for residential projects to be all-electric and Energy Star certified.

Construction Equipment
25% of energy demand electrified by 2030 and
75% electrified by 2045.

Consistent. The proposed Project would be required
to use construction equipment that is registered by
CARB and meet CARB’s standards. CARB sets its
standards to be in line with the goal of reducing
energy demand by 25 percent in 2030 and 75 percent
in 2045.

Transportation Electrification
Create a jurisdiction-specific ZEV ecosystem to
support deployment of ZEVs statewide (such as
permit streamlining, infrastructure siting,
consumer education, or preferential parking
policies).

Consistent. The proposed Project would be designed
and constructed in accordance with Title 24 Part 6
and Part 11 requirements, which includes
constructing homes to allow for electric vehicle
charging. Therefore, the proposed Project would not
interfere with the implementation of a ZEV
ecosystem within the City.

Local Action Policies - VMT Reduction
Increase public access to shared clean mobility
options (such as planning for and investing in
electric shuttles, bike share, car share, transit).

Consistent. The Project does not propose any
improvements to public sidewalks or streets.

However, the Project site is located in a developed
urban area with sidewalks available along all nearby
roadways. The proposed on-site roadway system
includes walkways throughout the Project site that
would connect to the off-site sidewalks. In addition,
the proposed residential units would allow for
charging of electric vehicles. The nearest bus stop is
the Tustin-East Village Way Stop (ZONE2), which is
approximately 98 feet (30 meters) west of the Project
boundary.

Amend zoning or development codes to enable
mixed-use, walkable, and compact infill
development (such as increasing allowable
density of the neighborhood).

Consistent. The proposed Project proposes a
General Plan Amendment to change the land use
designation from GC to MDR, and a Zone Change to
change the designation from C-TR to R3. These
changes would allow for the development of a
medium density residential community on an
underutilized parcel within a mixed use area of the
City.

Local Action Policies - Building Decarbonization
Adopt all-electric new construction reach codes. Consistent. The proposed Project would comply with Title 24 Parts 6 and 11, which includes electric
heat pumps installed during construction and electric
hookups for all appliances.

Adopt policies and incentive programs to reduce
electrical loads from equipment plugged into
outlets (such as purchasing Energy Star
equipment for municipal buildings, occupancy
Consistent. The proposed Project would be
constructed in accordance with Title 24 CALGreen
requirements, which includes installation of Energy
Star equipment and appliances in new buildings.
432
81 Action Consistency
sensors, smart power strips, equipment
controllers, etc.).

Facilitate deployment of renewable energy
production and distribution and energy storage.

Consistent. The proposed Project would be
constructed in accordance with the CALGreen
Building Energy Efficiency Standards (Title 24 Part
6), including solar, and meet all other requirements
related to energy efficiency standards.

Source: (California Air Resources Board, 2022, pp. 72-79) City of Orange General Plan Policies
The City’s Guidance for Greenhouse Gas Emissions Analysis Memo states that project-specific analysis should review consistency with related policies within Table NR-1 of the 2010 General Plan. Therefore, policies directly related to GHG reduction and energy efficiency for residential developments are discussed in Table GHG-4. As shown, the Project would not conflict with the General Plan policies.

Table GHG-4: General Plan GHG Policy Consistency Summary Policy Consistency
Circulation & Mobility 3.3: Transit-oriented
design within commercial, employment, medium
density residential, and mixed-use areas.

Consistent. The Project does not propose any
improvements to public streets. However, the
Project site is located in a developed urban area
with sidewalks available along all nearby
roadways. The proposed on-site roadway
system includes walkways throughout the
Project site that would connect to the off-site
sidewalks. In addition, the proposed residential
units would allow for charging of electric
vehicles. The nearest bus stop is the Tustin-East
Village Way Stop (ZONE2), which is
approximately 98 feet (30 meters) west of the
Project boundary.

Economic Development 3.4: Higher density
residential and mixed-use projects to provide
community-based workforce and market.

Consistent. The proposed Project proposes a
General Plan Amendment to change the land use
designation from GC to MDR, and a Zone
Change to change the designation from C-TR to
R3 to redevelop an underutilized and vacant
parcel. These changes would allow for the
development of a medium density residential
community on an underutilized parcel within a
mixed use area of the City.

Economic Development 5.4: Redevelop and
rehabilitate underutilized and vacant lands and
public rights-of-way.

Growth Management 2.4: Infill development
and mixed-use opportunities wherever possible
as developable space becomes more limited.

Infrastructure 2.6: Sustainable building and
site designs for new construction and renovation
projects.

Consistent. The Project would comply with
Title 24, Part 6 building energy requirements
along with other local and State initiatives that
aim to achieve the 40 percent below 1990 levels
by 2030 goal. These requirements include solar,
electric heat pumps installed during
Infrastructure 4.4: Integrated and costeffective design and technology features within new development.
433
82 Policy Consistency
construction, and electric hookups for all
appliances.

Natural Resources 2.1: Implement and enforce
regional air quality management plans.

Consistent. As discussed above in the air
quality section, the Project would not result in
substantial unplanned growth nor would it
exceed any of SCAQMD’s regional or local
construction and operational thresholds.

Therefore, the Project would be consistent with
the 2022 AQMP.

Natural Resources 2.2: Alternative
transportation modes, alternative technologies,
and bicycle- and pedestrian-friendly
neighborhoods.

Consistent. The proposed Project would be
designed and constructed in accordance with
Title 24 Part 6 and Part 11 requirements, which
includes constructing homes to allow for
electric vehicle charging. The Project includes
installation of bicycle racks and new sidewalks
that would provide bicycle- and pedestrianfriendly neighborhoods.

Natural Resources 2.3: Native and droughttolerant plants, proper soil preparation, and efficient irrigation systems for landscaping.

Consistent. The Project is required to comply
with AB 1881 landscaping requirements
pursuant to the Title 24 regulations in Chapter

15.54 of the City of Orange Municipal Code
Natural Resources 3.1: Evaluate the potential
effects of climate change on the City’s human
and natural systems and prepare strategies that
allow the City to appropriately respond and
adapt.

Consistent. As shown above in Table GHG-2,
the Project would not exceed SCAQMD’s GHG
threshold. Therefore, the Project would not
impede the City’s ability to reduce GHG
emissions.

Overall, implementation of the Project would not conflict with any applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases. Thus, impacts would not occur, and no mitigation measures are required.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact.

Existing Plans, Programs, or Policies
PPP E-1: CALGreen Compliance. As listed previously in Section 6, Energy.

Sources
Air Quality, Energy, and Greenhouse Gas Impact Analysis. 2025. Prepared by EPD Solutions, Inc. (Appendix A).

City of Orange. March 2020. Local Guidance Memo for Greenhouse Gas Emissions Analysis. [online]:
https://www.cityoforange.org/home/showpublisheddocument/5729/638767809268670000.

Accessed May 2025.
434
83 9. HAZARDS AND HAZARDOUS MATERIALS.

Would the project:

Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(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 reasonable 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 discussion below is based on the Phase I Environmental Site Assessment, 2024. Prepared by EDI Consultants, Inc. (included as Appendix F).

Impact Analysis:
a) A hazardous material is defined as any material that, due to its quantity, concentration, or physical or chemical characteristics, poses a significant present or potential hazard to human health and safety or to the environment if released. Hazardous materials include, but are not limited to, hazardous substances, hazardous wastes, and any material that regulatory agencies believe would be injurious to the health and safety of persons or harmful to the environment. Hazardous wastes require special handling and disposal because of their potential to damage public health and the environment.

Construction
Construction of the Project would involve limited routine transport, use, and disposal of hazardous materials. Fuels and solvents for construction would be stored and utilized pursuant to existing regulatory requirements. The use, storage, transport, and disposal of hazardous materials for construction of the facility would be carried out in accordance with federal and state regulations. No extremely hazardous substances (such as those governed under Title 40, Part 335 of the Code of Federal Regulations) would be used, stored, transported, or disposed of during Project construction. Construction specifications prepared for the Project would identify BMPs to ensure the lawful transport, use, storage, and disposal of hazardous materials. Thus, impacts related to construction would be less than significant.

Operation
Operation of the Project would include residential uses, which would involve use of hazardous materials including solvents, cleaning agents, paints, pesticides, batteries, fertilizers, and aerosol cans. These types 435
84 of materials are not acutely hazardous and would only be used and stored in limited quantities within the Project site. The normal routine use of these hazardous materials pursuant to existing regulations would not result in a significant hazard to people or the environment in the vicinity of the Project. Therefore, the Project would not result in a significant hazard to the public or to the environment through the routine transport, use, or disposal of hazardous waste, and impacts would be less than significant. No mitigation measures are required.

Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact. b) The Project would not create a significant hazard to the public or the environment through a reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment.

Construction
While the routine use of hazardous materials in accordance with applicable regulations during construction would not pose health risks or result in significant impacts, improper use, storage, transportation, and disposal of hazardous materials could result in accidental spills or releases. To avoid an impact related to an accidental release, the use of BMPs during construction are implemented as part of a SWPPP as required by the National Pollution Discharge Elimination System General Construction Permit. Implementation of a SWPPP (included as PPP WQ-1) would minimize potential adverse effects to workers, the public, and the environment. Construction contract specifications would include strict onsite handling rules and BMPs that include, but are not limited to:
• Establishing a dedicated area for fuel storage, refueling, and construction dewatering activities that includes secondary containment protection measures and spill control supplies; • Following manufacturers’ recommendations on the use, storage, and disposal of chemical products used in construction;
• Avoiding overtopping construction equipment fuel tanks; • Properly containing and removing grease and oils during routine maintenance of equipment; and • Properly disposing of discarded containers of fuels and other chemicals.

Historical Recognized Environmental Conditions
The Phase I Environmental Site Assessment (Phase I ESA) (Appendix F) identified one historical recognized environmental condition (HREC) related to the parcel adjacent to the Project site (but identified as within in the Phase I document). The property adjacent to the Project (2355 N. Tustin Street) is listed as having a former leaking underground storage (LUST) related to a previous carwash facility.

The Phase I ESA details that a remediation system was implemented to remove hazardous materials and that was confirmed through soils testing, and closure was granted by the OCHCA (OCHCA) in 2014, which is the local regulatory oversight agency (Appendix F). As the case is closed post remediation and the previous LUST site is adjacent and not within the Project area, potential impacts would be less than significant.

Operation
Operation of the proposed residences would involve use and storage of common hazardous materials such as paints, solvents, cleaning products, fuels, lubricants, adhesives, sealers, and pesticides/herbicides. Normal routine use of typical commercially used products pursuant to existing 436
85 regulations would not result in a significant hazard to the environment or people in the vicinity of the Project. Thus, impacts would be less than significant.

Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact. c) The closest schools to the Project site is St. Paul's Lutheran School, located at 901 E Heim Avenue approximately 0.7 mile from the Project site and Prime Academy located at 2190 N. Canal Street approximately 0.7 mile from the Project site. In addition, the Project would comply with all relevant and applicable federal, state, and local laws and regulations that pertain to the release of hazardous materials.

Construction
Heavy construction equipment (e.g., dozers, excavators, tractors) would be used for construction of the proposed Project. The equipment would be fueled and maintained by petroleum‐based substances such as diesel fuel, gasoline, oil, and hydraulic fluid, which are considered hazardous materials and may also generate hazardous emissions. The use of hazardous materials would be regulated by the Orange County Environmental Health Division. Additionally, construction-related emissions would be regulated by SCAQMD Rules 401 and 403. Therefore, potential construction-related impacts at the schools caused by hazardous emissions and materials would be less than significant.

Operation
As discussed previously, operation of the proposed residences would involve use and storage of common hazardous materials such as paints, solvents, cleaning products, fuels, lubricants, adhesives, sealers, and pesticides/herbicides. Normal routine use of typical commercially used products pursuant to existing regulations would not result in a significant hazard to the environment or people in the vicinity of the Project. In addition, as discussed in Section 3, Air Quality, operational emissions from the Project would not exceed established localized significance thresholds. Therefore, the use of hazardous materials and the generation of hazardous emissions through Project operation would not pose a significant hazard at nearby schools, and operational impacts would be less than significant.

Significance Determination: Less than significant.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant. d) Government Code Section 65962.5 defines hazardous materials sites as: hazardous waste facilities; hazardous waste discharges for which the State Water Quality Control Board has issued certain types of orders; public drinking water wells containing detectable levels of organic contaminants; underground storage tanks with reported unauthorized releases; and solid waste disposal facilities from which hazardous waste has migrated.

The Phase I ESA (Appendix F) included a review of federal, state, and local regulatory databases and determined that the Project site is not identified on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 as having substances that could create a significant hazard to the public or the environment. In addition, a search of the California Department of Toxic Substances Control EnviroStor database did not identify the Project site or any area within the project vicinity as a hazardous materials site. Therefore, the Project would not result in impacts related to hazardous materials sites complied pursuant to Government Code Section 65962.5. 437
86 Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact. e) The Project site is not located within an airport land use plan (ALUC 2008). Additionally, the Project is not within two miles of a public airport. The nearest airports are the John Wayne Airport, located approximately 10 miles south of the Project site in Santa Ana and the Fullerton Municipal Airport, located approximately 8.6 miles northwest of the Project site in the City of Fullerton. Therefore, the Project would not result in an airport related safety hazard for people working in the Project area and impacts would not occur from implementation of the Project.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact. f) The Project would not impair implementation of or physically interfere with adopted emergency response plans or emergency evacuation plans.

Construction
During construction, truck haul trips would transport construction debris and materials to and from Project site; however, these trips would not impact the roadway in a way that would impede emergency evacuations. The installation of driveways and connections to existing infrastructure systems that would be implemented during construction of the Project could require the temporary closure of portions of the roadway; however, construction activities would be required to ensure emergency access in accordance with Section 503 of the California Fire Code (Title 24, California Code of Regulations, Part 9), which would be ensured through the City’s permitting process. Additionally, the Project is not directly adjacent to roadways designated by the City as evacuation routes (Orange City Fire Department). Implementation of the Project through the City’s permitting process would ensure existing regulations are adhered to and would reduce potential construction related emergency access impacts to a less than significant level.

Therefore, impacts related to an emergency response or evacuation plan during construction would be less than significant.

Operation
Operation of the proposed residences would not impair or physically interfere with an adopted emergency response plan or emergency evacuation plan. The Project would be accessed from a 29-footwide driveway along the west side of the site, and a 22-foot-wide secondary driveway for emergency access would be located at the northwest corner of the Project site. Each of the proposed residences would be accessed from the 25-foot-wide driveway that would circle the site and have a fire access corner radii of a 50 foot outside radius and 55 foot inside radius compliant with the City of Orange Fire Master Plan access standards. The Project driveway and internal access would be required through the City’s permitting procedures to meet the City’s design standards to ensure adequate emergency access and evacuation. The Project is also required to provide fire suppression facilities (e.g., hydrants and sprinklers). The Fire Department and/or Public Works Department have reviewed the development plans as part of the permitting procedures to ensure adequate emergency access pursuant to the requirements in Section 503 of the California Fire Code (Title 24, California Code of Regulations, Part 9). As such, the Project would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan, and impacts would not occur. 438
87 Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact. g) The Project site is not in an area designated as a Fire Hazard Severity Zone (CAL FIRE 2025). In addition, the Project site is developed and surrounded by developed areas. Implementation of the Project would be required to adhere to the California Fire Code, as adopted by the City, and would be reviewed by the City’s Building and Safety Services Division during the permitting process to ensure that the Project meets the fire protection requirements. As a result, the proposed Project would not expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact.

Existing Plans, Programs, or Policies
None.

Sources
ALUC (Airport Land Use Commission). Amended 2008. Land Use Plan for John Wayne Airport (Figure 1). [online]: https://files.ocair.com/media/2021-02/JWA_AELUP-April-17- 2008.pdf?VersionId=cB0byJjdad9OuY5im7Oaj5aWaT1FS.vD. Accessed May 2025.

CAL FIRE (California Department of Forestry and Fire Protection). 2025. Fire Hazard Severity Zone Viewer [online]: https://osfm.fire.ca.gov/what-we-do/community-wildfire-preparedness-andmitigation/fire-hazard-severity-zones. Accessed May 2025.

California Department of Toxic Substances Control EnviroStor Database [online]:
https://www.envirostor.dtsc.ca.gov/public/. Accessed May 2025.

Orange City Fire Department. Evacuation Information. [online]: https://orangecityfire.org/evacuationinfo. Accessed May 2025.

Phase I Environmental Site Assessment Report. 2024. Prepared by EDI Consultants, Inc. (Appendix F). 439
88 10. HYDROLOGY AND WATER QUALITY.

Would the project:

Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(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) 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; 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?
(f) Potentially impact stormwater runoff from construction activities? (g) Potentially impact stormwater runoff from post-construction activities?
(h) Result in a potential for discharge of stormwater pollutants from areas of material storage, vehicle or equipment fueling, vehicle or equipment maintenance (including washing), waste handling, hazardous materials handling or storage, delivery areas, loading docks or other outdoor work areas?
(i) Result in the potential for discharge of stormwater to affect the beneficial uses of the receiving waters?
(j) Create the potential for significant changes in the flow velocity or volume of stormwater runoff to cause environmental harm? (k) Create significant increases in erosion of the project site or surrounding areas?
The discussion below is based on the Preliminary Hydrology Report prepared (included as Appendix G) and the Preliminary Water Quality Management Plan (WQMP) (included as Appendix H).

Impact Analysis:
a) The Santa Ana Regional Water Quality Control Board (RWQCB) would have jurisdiction over the groundwater quality and surface water discharges in the Project region.

Construction
Construction activities include demolition, site preparation, grading, paving, and installation of new landscaping that would expose and loosen sediment and would have the potential to degrade surface and receiving water quality via stormwater runoff. In addition, construction vehicles and equipment are prone to tracking soil from work areas to paved roadways, which could exacerbate sedimentation of receiving 440
89 waters. Pollutants of concern during construction activity generally include sediment, trash, petroleum products, concrete water, sanitary waste, and chemicals.

The Project would be required to comply with NPDES construction permit regulations and the City of Orange Local Implementation Plan (LIP), which require the preparation and implementation of a SWPPP, included as PPP WQ-1. As part of the SWPPP, erosion and sediment control measures would be included to minimize potential pollutants from entering stormwater during construction. These measures include the use of construction BMPs to ensure that impacts related to degradation of water quality would be less than significant. Erosion control BMPs used to prevent the degradation of water quality in the construction area may include the use of:
• silt fences;
• sediment/desilting basins;
• sediment traps;
• check dams;
• fiber rolls;
• gravel bag berms;
• sandbag barriers;
• straw bale barriers;
• street sweeping and vacuuming; and
• storm drain inlet protection.

Other BMPs that could be used to enhance erosion control include scheduling to avoid wet weather events, preserving existing vegetation, and placing cover material over exposed soil. BMPs would also include practices for proper handling of chemicals such as avoidance of fueling at the construction site and overtopping during fueling, and installation of containment pans. Implementation of BMPs in compliance with the City’s permitting requirements would reduce potential erosion and sedimentation impacts to below a level of significance during construction.

Operation
The new residential uses would introduce pollutants such as trash and debris, oil and grease from vehicles, and pesticides and sediments from landscaping. These pollutants could potentially discharge into surface waters and result in degradation of water quality. Thus, the proposed Project would be required to comply with existing regulations that limit the potential for pollutants to discharge from the site. The Project would install a new onsite drainage system to accommodate the proposed site plan.

Stormwater runoff would be captured by five sump curb inlet catch basins, one grate inlet, and an onsite area drain system that would route runoff to biofiltration treatment devices. Under Orange Municipal Code Section 7.01.060, the Project would be required to implement a Water Quality Management Plan (WQMP), included as PPP WQ-2, to ensure that the proposed drainage system controls pollutant discharge. Implementation of the WQMP would require use of Low Impact Development (LID) features, pollutant source control features, and pollutant treatment control features, which would provide that the Project would not violate any water quality standards, waste discharge requirements, or otherwise degrade water quality. A Preliminary WQMP has been prepared for the Project and is included as Appendix H. In addition, as detailed below, the Project would increase pervious area and implementation of the proposed drainage system would result in a decrease in stormflows from the site. Therefore, the proposed Project would both treat and reduce stormflows. Operational impacts related to water quality degradation would be less than significant.
441
90 Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact. b) The City’s Urban Water Management Plan (UWMP) describes that the City relies on 77 percent groundwater, 18 percent imported water, and 5 percent surface water. The main source of the City’s water supply is the Orange County Groundwater Basin. Groundwater from the Orange County Groundwater Basin is managed by the Orange County Water District (OCWD), which manages basin water supply through the Basin Production Percentage (BPP). The BPP is set based on groundwater conditions, availability of imported supplies, and precipitation. Additionally, the amount of groundwater pumped is limited by the OCWD and the Project would not directly pump water from the Project area, as water supplies would be provided by OCWD.

The proposed Project would result in an increase in pervious area; pre-development conditions contain approximately 92-percent impervious area while post-development conditions would contain approximately 87-percent impervious area (Appendix G). As a result, the proposed Project would not decrease groundwater supplies or interfere substantially with groundwater recharge; and the Project would not impede sustainable groundwater management of the basin. Thus, the proposed Project would have a less than significant impact.

Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact. c) i) As detailed in the Preliminary Hydrology Study (Appendix G) prepared for the Project, the site slopes in the westerly direction towards N. Tustin Street. Existing stormwater runoff is collected in valley gutters throughout the site. East of the existing building, runoff flows to a valley gutter and into an existing storm drain inlet. To the west of the existing building, runoff flows to valley gutters that route runoff into two existing storm drain catch basins in the easterly portion of the main entrance drive aisle.

Runoff in the main entrance drive aisle is routed via curb and gutter into two existing catch basins located just east of the public right-of-way of N. Tustin Street. In addition, currently offsite flows run onto the Project site at the southeast corner from the triangular shaped parcel to the east.

The Project site is located within the Santa Ana River Watershed per the Orange County Flood Control District Drainage System Map No. 15. Surface runoff from the site continues in the southerly direction in N. Tustin Street where it is conveyed into an existing catch basin and enters the existing underground storm drain system and continues to the Buckeye Storm Channel just south of Meats Avenue. Runoff converges with the Collins Storm Channel, Santa Ana River, and ultimately discharging to the Pacific Ocean.

Construction
Construction and demolition activities would disturb and expose soil, which could be moved by wind and water, resulting in erosion and sedimentation of stormwater runoff. However, the Project site does not include any slopes, which reduces the construction erosion potential. Implementation of a SWPPP through the use of construction BMPs, as required by the County of Orange MS4 Permit and City of Orange LIP, would ensure that Project impacts resulting in a degradation of water quality would be less than significant.
442
91 Operation
During Project operation, the pervious areas would be landscaped with groundcover that would inhibit erosion. There would be no substantial areas of bare or disturbed soil onsite subject to erosion. In addition, the Project is required to implement a WQMP (PPP WQ-2) that would provide operational BMPs to ensure that operation of the proposed residences would not result in erosion or siltation. With implementation of these regulations, impacts related to erosion or siltation onsite or off-site would be less than significant.

Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact. c) ii) The Project site does not include, and is not adjacent to, a natural stream or river. According to the Federal Emergency Management Agency (FEMA) Map 06059C0154J, the Project site is within Flood Zone X, an area with minimal flood hazard.

The Preliminary WQMP (Appendix H) prepared for the Project details that the site is currently 8 percent pervious and 92 percent impervious. The proposed Project would result in an increase in pervious area with 13 percent pervious and 87 percent impervious. Thus, the Project would not result in the addition of impervious surfaces that could result in flooding.

The proposed Project would install a new onsite drainage system to accommodate the proposed site plan.

Stormwater runoff would be captured by five sump curb inlet catch basins, one grate inlet, and an onsite area drain system that would route runoff to biofiltration treatment devices prior to discharge to the existing stormwater sump pump system. The sump pump system would discharge runoff into N. Tustin Street through a parkway drain, consistent with the current condition, but with an approximate seven percent decreased volume compared to the existing condition. Thus, buildout of the Project would not substantially alter the existing drainage pattern onsite.

The increase in pervious area and implementation of the proposed drainage system would result in a decrease in stormflows from the site. Table HYD-1 details that flows from a 25-year storm event would decrease by 7.2 percent. Therefore, impacts related to flooding as a result of surface runoff increase would be less than significant.

Table HYD-1: Comparison of Storm Flows with Project Implementation Q10 (cfs) Q25 (cfs) Q100 (cfs)
Existing Condition 8.040 9.728 12.526
Proposed Project Condition 7.439 9.023 11.676
Percent Decrease 7.5% 7.2% 6.8%
Source: Preliminary Hydrology Study (Appendix G)
Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact. c) iii) As described previously, the Project site would not substantially alter existing site drainage pattern and would reduce the impervious surfaces on the site compared to the existing conditions. The Project 443
92 proposes to install five sump curb inlet catch basins, one grate inlet, and an onsite area drain system that would route runoff to biofiltration treatment devices prior to discharge to the existing stormwater sump pump system. The proposed drainage plan meets guidelines for a 100-year, 24-hour storm event, as set by the County of Orange (Appendix G) and would decrease flows compared to the existing condition, as shown in Table HYD-1. In addition, the Project is required to implement a WQMP that would provide operational BMPs to ensure that operation of the proposed residences would reduce potential sources of pollution to stormwater. As such, the Project would not contribute runoff water that would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff. Impacts would be less than significant.

Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact. c) iv) The Project is within Flood Zone X, an area of minimal flood hazard (FEMA 2024). The Project would increase pervious surfaces and install a drainage system that would reduce stormflows, as detailed in Table HYD-1. In addition, the Project would be required to comply with the applicable construction standards in Orange Municipal Code Section 15.60.160. The City would review the Project permit applications to ensure the proposed development would not be subject to significant flood hazard. Thus, the proposed Project would not impede or redirect flood flows, and impacts would be less than significant.

Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact. d) The Project site is within Flood Zone X, an area of minimal flooding (FEMA 2024). Thus, the Project site is not located within a flood hazard area that could be inundated with flood flows and result in release of pollutants. Impacts related to flood hazards and pollutants would not occur from the Project.

Tsunamis are tidal waves generally caused by shallow earthquakes, sea floor landslides, rock falls, and exploding volcanic islands. The Project is over 15 miles from the ocean shoreline. Based on the distance of the Project site to the Pacific Ocean, the Project is not at risk of inundation from tsunami. Therefore, the Project would not risk release of pollutants from inundation from a tsunami. No impacts would occur.

Seiching is a phenomenon that occurs when seismic ground shaking induces standing waves within a closed body of water. Seiches may cause retention structures to fail and flood downstream properties.

The Project site is approximately 1.6 miles south of the Burris Basin. However, the likely spillway path is the Santa Ana River channel, which abuts the southern side of the Burris Basin. Therefore, the proposed Project would not risk release of pollutants from inundation from seiche. No impact would occur.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact. e) As described previously, the Project would result in an increase in pervious areas and a decrease in drainage. The Project would install a new onsite drainage system and stormwater runoff would be 444
93 captured by five sump curb inlet catch basins, one grate inlet, and an onsite area drain system that would route runoff to biofiltration treatment devices for filtration and treatment prior to discharge to the existing stormwater sump pump system. The sump pump system would discharge runoff into N. Tustin Street through a parkway drain. Therefore, the Project would not interfere with groundwater recharge and impacts related to groundwater recharge would not occur. As discussed further in Section 19, Utilities and Service Systems, water demands from the Project are a minimal percentage of the increase in water demands anticipated by the City of Orange 2020 UWMP. The 2020 UWMP determined that water supply and demands will be met, and the City would monitor groundwater withdrawals so as to not overdraft supplies. Therefore, the Project would not conflict with the OCWD groundwater management plan.

During construction and operation, the Project would be required to comply with regulations under the City’s LIP. Compliance with the LIP would be ensured through the City’s permitting process, as well as through post-construction BMP inspections and verifications. Therefore, impacts related to water quality control plans would be less than significant.

Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact. f) As described in the previous responses, construction of the Project would require demolition of the existing building, pavement, and infrastructure and excavation activities that could temporarily impact stormwater runoff during construction activities. However, pursuant to Orange Municipal Code Title 7, Chapter 7.01, implementation of BMPs, described within the SWPPP and Erosion and Sediment Control Plans, the site would address site specific pollutant and drainage issues related to construction of the Project. Thus, impacts related to stormwater runoff would be less than significant.

Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact. g) As described previously, the Preliminary Hydrology Study (Appendix G) prepared for the Project determined that the proposed Project would increase onsite pervious surfaces and would decrease runoff with the proposed catch basin and biofiltration treatment system. In addition, the Project is required to implement a WQMP biofiltration treatment system that would provide operational BMPs to ensure that operation of the proposed residences would not result in increased runoff. Table HYD-1 details that stormwater runoff from a 25-year storm event would be decrease by 7.2 percent. Therefore, the built Project would not result in increased stormwater runoff and impacts would be less than significant.

Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact. h) Construction of the proposed Project may include material storage, equipment fueling, equipment maintenance, waste handling, hazardous materials handling or storage, delivery areas, and other outdoor work areas. As described previously, the Project would be required to comply with NPDES construction permit regulations and the City of Orange LIP, which requires the preparation and implementation of a SWPPP, included as PPP WQ-1. As part of the SWPPP, control measures would be included to minimize potential pollutants from entering stormwater during construction. These measures include the use of 445
94 construction BMPs to ensure that impacts related to degradation of water quality would be less than significant.

Operation of the proposed residences would require limited transport, storage, use, and disposal of hazardous materials. Stormwater pollutants may also result from vehicles and trash. As described in Section 9, Hazards and Hazardous Materials, the Project would comply with state and federal regulations regarding the storage, handling, and cleaning of hazardous materials. Through the implementation of the BMPs (primarily the biofiltration treatment system) and others described within the Preliminary WQMP (Appendix H), the impacts related to release of pollutants would be less than significant.

Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact. i) As described previously, the Project would be required to comply with NPDES construction permit regulations and the City of Orange LIP, which requires the preparation and implementation of a SWPPP, included as PPP WQ-1. As part of the SWPPP, control measures would be included to minimize potential pollutants from entering stormwater during construction that could affect receiving waters. These measures include the use of construction BMPs to ensure that impacts related to degradation of water quality (including the beneficial uses of the receiving waters) would be less than significant.

During Project operation stormwater runoff would be routed to a biofiltration treatment system for treatment before stormwater is discharged into the public system (Appendix G). The Preliminary Water Quality Management Plan (Appendix H) determined that implementation of the proposed biofiltration treatment system would meet storm water quality treatment requirements in accordance with the State Water Resources Control Board NPDES MS4 permit. Therefore, the Project would not result in a discharge of stormwater that would affect the beneficial uses of the receiving waters. Impacts would be less than significant.

Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact. j) As described previously, the proposed drainage system was determined to be able to accommodate a 100-year, 24-hour storm event, as required per Orange County guidelines. Additionally, a comparison of pre- and post-construction hydraulics, as shown in Table HYD-1, found that the proposed Project would reduce stormflows and provide water quality treatment. Therefore, impacts related to volume of stormwater would be less than significant.

Significance Determination: Less than significant.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant. k) As previously discussed, construction and demolition activities would disturb and expose soil, which could be moved by wind and water, resulting in erosion and sedimentation of stormwater runoff.

However, the Project site does not include any slopes, which reduces erosion potential. A majority of soil disturbance would be related to removal of existing infrastructure and site grading. The use of 446
95 construction BMPs in a SWPPP (PPP WQ-1), as required by the State Water Resources Control Board NPDES MS4 permit and City of Orange LIP, would serve to ensure that Project impacts related to erosion of the Project site or surrounding areas would be less than significant.

In addition, the Project would install landscaping that would reduce the potential for erosion. As part of the permitting approval process, the proposed drainage and water quality design (WQMP) and engineering plans would be reviewed by the City’s Public Works Department to ensure that the sitespecific design limits the potential for erosion on the Project site. Overall, the proposed drainage system and adherence to the existing regulations would ensure that Project impacts related to erosion would be less than significant.

Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact.

Existing Plans, Programs, or Policies
PPP WQ-1: NPDES/SWPPP. Prior to issuance of any grading or demolition permits, the applicant shall provide the City evidence of compliance with the NPDES (National Pollutant Discharge Elimination System) requirement to obtain a construction permit from the State Water Resource Control Board (SWRCB). The permit requirement applies to grading and construction sites of one acre or larger.

The Project applicant/proponent shall comply by submitting a Notice of Intent (NOI) and by developing and implementing a Stormwater Pollution Prevention Plan (SWPPP) and a monitoring program and reporting plan for the construction site.

PPP WQ-2: WQMP. Prior to the approval of the Grading Plan and issuance of Grading Permits a completed Water Quality Management Plan (WQMP) shall be submitted to and approved by the City .

The WQMP shall identify all Post-Construction, Site Design. Source Control, and Treatment Control Best Management Practices (BMPs) that will be incorporated into the development project in order to minimize the adverse effects on receiving waters.

Sources
City of Orange. November 2021. 2020 Urban Water Management Plan. [online]:
https://www.cityoforange.org/home/showpublisheddocument/1540/637873464981170000 Accessed April 2025.

FEMA (Federal Emergency Management Agency). 2024. Flood Insurance Rate Map (FIRM) Map No. 06059C0154J.[online]: https://hazardsfema.maps.arcgis.com/apps/webappviewer/index.html?id=8b0adb51996444d4879338b5529aa9 cd. Accessed April 2025.

Preliminary Hydrology Study. 2025. Prepared by C & V Consulting, Inc. (Appendix G).

Preliminary Water Quality Management Plan (WQMP). 2025. Prepared by C & V Consulting, Inc. (Appendix H).
447
96 11. LAND USE/PLANNING. Would the project:

Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(a) Physically divide an established community?
(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?
Impact Analysis:
a) The Project site is fully developed and currently contains a vacant commercial retail structure. The Project site is located in a completely developed area with residential uses to the north and south of the site, commercial and office uses to the west, and a parcel with a billboard sign followed by the SR 55 freeway to the east. The Project would redevelop the site with 71 new residences, which would expand the established community of residential that is adjacent to the north and the south of the site. In addition, the Project would not change roadways or install any infrastructure that would result in physical division of a community. Conversely, the fire access provided by the Project would provide connection between the Project site and parcel to the north. Thus, no impacts related to physical division of an established community would occur.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact. b) The documents regulating land use for the Project site and immediate vicinity are the Orange General Plan and the Orange Municipal Code. The Project’s relationship to these planning documents is described below.

General Plan. The Project site has an existing General Plan land use designation of General Commercial (GC) that allows a maximum Floor Area Ratio (FAR) of 1.0. The GC designation provides for a wide range of retail and service commercial uses and professional offices. Regional shopping centers, midand high-rise office projects, corridor shopping districts, and neighborhood corner stores are all permitted uses.

The Project includes a General Plan Amendment to change the land use from GC to Medium Density Residential (MDR), which allows residential densities between 15 and 24 dwelling units per acre. The General Plan Land Use Element states that the Medium Density Residential designation provides for multi-family townhouses, condominiums, and apartments featuring some form of internal open space in areas with good access to major circulation routes, business districts, and public open space areas.

Medium Density residential uses are typically found adjacent to commercial districts and near major transportation corridors.

The proposed Project is consistent with the MDR land use designation as it would provide 16.76 dwelling units per acre, which is between 15 and 24 dwelling units per acre. Consistent with the General Plan Land Use Element description of the Medium Density Residential designation, the proposed Project would provide fee simple detached and duplex residences with internal open space in areas with good access to major circulation routes (N. Tustin Street and SR 55) and business districts (along N. Tustin 448
97 Street). Additionally, the Project would comply with the goals and policies of the Orange General Plan.

As shown in Table LU-1, the Project would be consistent with the land use designation, goals, and policies of the Orange General Plan. As such, no impact related to conflict with a General Plan policy or regulation adopted for the purpose of avoiding or mitigating an environmental effect would occur.

Table LU-1: City of Orange General Plan Project Consistency Policy Consistency
Policy LU-1.3: Provide a range of housing densities and types to meet the diverse needs and lifestyles of residents.

Consistent. The proposed Project would add to the City’s range of housing densities and types and would assist in meeting the City resident’s diverse needs and lifestyles.

Policy LU-1.4: Ensure that new development reflects
existing design standards, qualities, and features that are in context with nearby development.

Consistent. As shown in Table AES-1, the Project complies with development standards of the R-3 zone with
application of the SLO. Further, the Project would be in context with the nearby residential and commercial
development.

Policy LU-1.7: Provide a range of open space and park
amenities to meet the diverse needs of current and new
residents.

Consistent. The Project includes 6,031 square feet of
common open space and recreation area for the new
residents on the Project site.

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

Consistent. The Project would construct new residences
with a modern architecture that would be in context with the nearby residential and commercial development. As shown in Table AES-1, the Project would be consistent with the development standards for the R-3 zone with application of the SLO.

Policy LU-6.2: In areas where residential uses abut
commercial or industrial land uses, use buffering techniques to improve compatibility. Such techniques include the use of setbacks, screening, soundwalls with pedestrian access, and appearance standards.

Consistent. The proposed residential uses would be located adjacent to office and commercial land uses to the west. The Project includes walls, architecture, pedestrian access, and landscaping to provide a buffer between adjacent uses and enhance visual compatibility.

Policy LU-6.5: Reduce pollutant runoff from new
development and urban runoff to the maximum extent
practicable.

Consistent. As discussed in Section 10, Hydrology and
Water Quality, the Project would be required to incorporate water quality measures with LID site design during Project operations and treatment control BMPs during all
construction and grading activities to reduce runoff.

Policy LU-6.6: Enhance the walkability of both new and
current development
Consistent. The Project includes walkways throughout the Project site that would connect to the off-site sidewalks.

Policy LU-6.8: Maximize landscaping along streetscapes
and within development projects to enhance public health and environmental benefits.

Consistent. The proposed Project includes approximately 30,309 SF (16.4% of the site) of landscaping with 24-inch and 36-inch box trees, 15-gallon trees, various shrubs, and groundcover, as shown in Figure 18, Conceptual Landscape Plan.

Policy LU-6.9: Restrict development in areas where
exposure to hazards such as flood, erosion, liquefaction, dam failure, hazardous materials, and toxic gases cannot be mitigated to reduce risk to residents and liability to the City.

Not applicable. The Project site is not within a flood or inundation zone. Additionally, as discussed in Section 7, Geology and Soils, the Project site is not susceptible to liquefaction.

Policy LU-6.10: Mitigate adverse air, noise, circulation, and other environmental impacts caused by new
development adjacent to existing neighborhoods through
use of sound walls, landscaping buffers, speed limits, and other traffic control measures.

Consistent. The Project would result in less than significant impacts related to air quality and circulation as identified in each environmental topic section of this document. Impacts related to noise would be less than significant and impacts related to construction vibration would be less than
significant with the incorporation of Mitigation Measure NOI-1.

GOAL GM-1.0: Reduce traffic congestion within the City. Consistent. As discussed in Section 17, Transportation, the Project would generate fewer daily trips than the previous operation of the Best Buy store. In addition, the Project 449
98 Policy Consistency
would not exceed traffic screening criteria, and Project impacts would be less than significant.

Policy GM-1.2: Ensure completion of transportation
improvements as agreed upon by the City and developer
prior to completion of a development project.

Not applicable. The Project does not propose or require any transportation improvements. As discussed in Section 17, Transportation, the Project would generate fewer daily trips than the previous commercial site usage that was supported by the existing roadway system.

Policy GM-1.3: Ensure that new development pays its fair share of street improvement costs, including regional traffic mitigation. New revenues generated from Measure M, if
available, shall not be used to replace private developer funding which has been omitted for any project.

Consistent. The Project applicant would be required to pay applicable fees in accordance with City regulations.

Policy GM-1.5: Require new development projects to link issuance of building permits for the appropriate portion of the development plan to roadway improvements required to achieve the appropriate LOS. Monitor the implementation of this requirement for each new development project on an annual basis.

Not Applicable. As discussed in Section 17,
Transportation, the Project would generate fewer daily trips than the previous commercial uses on the site that were supported by the existing roadway system. In addition, the Project would generate a limited number of vehicle trips that would not require a LOS analysis, pursuant to the City’s traffic analysis guidelines.

Policy GM-1.7: Promote the expansion and development of alternative methods of transportation.

Consistent. The Project would include bike racks and
pedestrian access throughout the site, which would
encourage alternative transportation.

Policy GM-1.8: Encourage the development of housing
within close proximity to jobs and services.

Consistent. The Project would develop new housing within a commercial and office corridor that provides both jobs and services.

Policy GM-1.9: Ensure that new developments incorporate non-motorized and alternative transit amenities such as bike racks, bus benches and shelters, and pedestrian connections.

Consistent. The Project would install bike racks onsite and would provide pedestrian access throughout the site and connect to the existing offsite pedestrian network.

Policy GM-1.12: Promote traffic reduction strategies
through the measures adopted within the City’s
Transportation Demand Management (TDM) Ordinance.

Consistent. As discussed in Section 17, Transportation, the Project would reduce vehicular trips compared to the
previous commercial retail uses on the Project site. The residents would be able to utilize existing transit, sidewalks, and bicycle lanes from the Project that would provide
bicycle parking and sidewalk connections. Therefore, the Project is consistent with traffic reduction strategies, and the Project VMT impact would be less than significant.

Policy GM-2.4: Explore infill development or mixed-use
opportunities wherever possible as developable space
becomes more limited.

Consistent. The proposed Project consists of infill
development on a parcel that has been underutilized with a vacant structure.

GOAL NR-2.0: Protect air, water, and energy resources
from pollution and overuse.

Consistent. The Project would result in less than significant impacts related to air, water, and energy as identified in each environmental topic section of this document.

Policy NR-2.1: Cooperate with the South Coast Air Quality Management District (SCAQMD) and other regional
agencies to implement and enforce regional air quality
management plans.

Consistent. As detailed in Section 3, Air Quality, the
Project would be consistent with the SCAQMD AQMP and
would be required to implement the applicable SCAQMD
Rules during Project construction and operation.

Policy NR-2.2: Support alternative transportation modes, alternative technologies, and bicycle- and pedestrianfriendly neighborhoods to reduce emissions related to vehicular travel.

Consistent. The Project would install bike racks onsite and would provide pedestrian access throughout the site and connect to the existing offsite pedestrian network, which would encourage alternative transportation.

Policy NR-2.3: Reduce the amount of water used for
landscaping through the use of native and drought-tolerant plants, proper soil preparation, and efficient irrigation systems as parks and other City facilities are built or renovated.

Consistent. The Project would use drought-tolerant plants as listed in Figure 18, Conceptual Landscape Plan.

Development of the landscape and irrigation plan would be required to comply with regulations and standards under the City of Orange Water Efficient Landscape Guidelines and Landscape Standards and Specifications.
450
99 Policy Consistency
Policy NR-2.4: Encourage the production, distribution, and use of recycled and reclaimed water for landscaping
projects, while maintaining urban runoff water quality
objectives.

Not Applicable. No existing recycled water laterals exist within the Project vicinity. However, as discussed below, use of construction and operational BMPs would minimize stormwater pollutants, maintaining urban runoff quality.

Policy NR-2.5: Continue to work toward local and regional waste-reduction and diversion/ recycling goals and promote public education programs.

Consistent. The Project would be required to recycle 65 percent of construction waste and 75 percent of operational waste pursuant to the CalGreen Building Code and AB 341, respectively.

Policy NR-2.6: Encourage sustainable building and site
designs for new construction and renovation projects.

Consistent. The Project would be required to comply with the Building Energy Efficiency Standards pursuant to Title 24 that would increase energy efficiency through building designs.

Policy NR-2.11: Protect the ecological integrity and overall health of Orange’s watersheds.

Consistent. As required under the MS4 Permit, the Project would be required to implement BMPs through a SWPPP
and WQMP. As detailed in Section 10, Hydrology and
Water Quality, the Project would not adversely impact
stormwater flowing into the local watersheds and
groundwater.

Policy NR-2.12: Cooperate with water supply agencies to protect the quantity and quality of local groundwater
supplies.

Consistent. Use of construction and operational BMPs
would maintain stormwater quality, which may infiltrate into the local groundwater. In addition, the Project would be consistent with the projected water demands in the City’s UWMP.

Policy NR-2.13: Control surface runoff water discharges into the stormwater conveyance system to comply with the City’s National Pollutant Discharge Elimination System
(NPDES) Municipal Permit and other regional permits
issued by the Santa Ana Regional Water Quality Control
Board.

Consistent. As discussed in Section 10, Hydrology and
Water Quality, the Project would be required to incorporate water quality measures with LID site design and treatment control BMPs during all construction and grading activities to reduce runoff. The Project proposes to treat runoff onsite before stormwater is discharged.

Policy NR-2.14: Reduce pollutant runoff from new
development by requiring use of the most low development impact practices and effective Best Management Practices (BMPs) currently available.

Policy NR-2.15: Minimize the amount of impervious
surfaces and associated urban runoff pollutants in new
development and significant redevelopment throughout the community.

Consistent. The Project would provide 16.4 percent of
landscape cover onsite. As discussed above, the Project would also include design features and BMPs to reduce
runoff pollutants.

GOAL NR-3.0: Prepare for and adapt to the effects of
climate change and promote practices that decrease the
City’s contribution to climate change.

Consistent. The Project would be required to be developed per Title 24 requirements, which would implement energy efficient building standards. In addition, the Project would not result in significant GHG emissions.

Policy NR-4.3: Reduce the impact of urban development on important ecological and biological resources.

Consistent. The existing Project site is comprised of a building and a paved lot. No natural habitat exists on the Project site. Therefore, buildout of the Project would not adversely impact any ecological or biological resources.

GOAL PS-1.0: Protect residents and businesses from
seismic hazards and other geologic constraints.

Consistent. The Project would comply to all applicable
CBC regulations, minimizing potential building damage
Policy PS-1.1: Minimize the potential loss of life and and risk to human life from seismic hazards. damage to structures that may result from an earthquake.

Policy PS-2.4: Employ strategies and design features that will reduce the amount of impervious surface (i.e. paved area) within new development projects.

Consistent. The Project would provide 16.4 percent of
landscape cover onsite.

Policy PS-3.12: Prioritize infill development within the existing developed footprint to avoid future unfunded
emergency vehicle access infrastructure creating repair and Consistent. The Project consists of redevelopment of a
vacant commercial site for residential within an area already served by emergency vehicles. The Project is not adjacent 451
100
Policy Consistency
maintenance liabilities; and to reduce potential wildfire hazards originating from development adjacent to
environmentally sensitive open space areas.
to environmentally sensitive open space areas. The Project site plan would be reviewed and approved by the Fire
Department to ensure adequate access and fire suppression resources.

Policy N-1.2: Encourage new development projects to
provide sufficient spatial buffers to separate excessive noise generating land uses and noise-sensitive land uses.

Consistent. The Project site is surrounded by cement block walls and as detailed in Section 13, Noise, is adjacent to the north and the south sides by similar residential land uses.

Additionally, noise impacts were determined to be less than significant.

Policy N-1.3: Incorporate design features into residential and mixed-use projects that can be used to shield residents from excessive noise.

Consistent. The Project site is surrounded by cement block walls that would shield residents from excessive noise.

Also, as detailed in Section 13, Noise, the third floor of the residence on Lot 54 would include upgraded windows with a minimum STC rating of 31 to shield the residents of Lot 54 from roadway noise.

Policy N-1.4: Ensure that acceptable noise levels are
maintained near noise-sensitive uses.

Consistent. Noise impacts would be less than significant as discussed in Section 13, Noise. In addition, with compliance to Mitigation Measure NOI-1, vibration impacts would be less than significant.

Policy N-1.6: Require an acoustical study for proposed
developments in areas where the existing and projected
noise level exceeds or would exceed the maximum
allowable levels identified in Table N-3. The acoustical study shall be performed in accordance with the
requirements set forth within this Noise Element
Consistent. As detailed in Appendix I, a Noise and
Vibration Analysis has been completed for the Project and identifies potential noise impacts in accordance with the requirements of the Noise Element. Noise impacts would be less than significant as discussed in Section 13, Noise. In addition, with compliance to Mitigation Measure NOI-1,
vibration impacts would be less than significant.

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

Consistent. Project construction would comply with City mandates on allowed construction times as per Orange
Municipal Code Section 8.24.050.

Policy N-7.2: Require developers and contractors to employ noise minimizing techniques during construction and
maintenance operations.

Consistent. Construction noise operations would be less than significant with compliance with Municipal Code
Section 8.24.050 and Mitigation Measure NOI-1,
construction vibration impacts would be less than
significant.

Policy N-7.3: Limit the hours of construction and
maintenance operations located adjacent to noise-sensitive land uses.

Consistent. Project construction would comply with City mandates on allowed construction times as per Orange
Municipal Code Section 8.24.050. Additionally,
construction noise and vibration impacts would be less than significant with compliance to MM NOI-1.

GOAL CR-1.0: Identify and preserve potential and listed historic resources, including buildings, structures, objects, sites, districts, and archaeological resources citywide.

Consistent. As discussed in Section 5, Cultural Resources, a Cultural Resources Study was conducted, and no
historical or archaeological resources were found. No
impacts to historical resources would occur and potential impacts to archaeological resources would be less than
significant.

Policy CR-1.6: Promote the preservation of cultural and historical resources controlled by governmental agencies, including those related to City, school district, and other agencies.

Consistent. As discussed in Section 5, Cultural Resources, a Cultural Resources Study was conducted, and no
historical resources were found. No impacts to historical resources would occur and potential impacts to
archaeological resources would be less than significant.

GOAL CR-4.0: Identify and preserve archaeological and
cultural resources.

Consistent. A Cultural Resources Study was conducted
onsite, and no resources were found. As discussed in
Section 5, Cultural Resources, no impacts to historic
resources would occur and potential impacts to
archaeological resources would be less than significant.

Policy CR-4.1: Identify, designate, and protect historically and culturally significant archaeological resources or sites. 452
101
Policy Consistency
Policy INF-1.6: Require that new developments fund fairshare costs associated with City provision of water, sewer, and storm drain service and are consistent with City and service provider plans to complete needed improvements
and funding capacity for such improvements.

Consistent. The Project applicant would be required to pay applicable development impact fees in as required by City regulations.

Policy INF-3.6: Require that new developments fund fairshare costs associated with City provision of right-of-way maintenance services and are consistent with City and
service provider plans to complete needed improvements
and funding capacity for such improvements.

Consistent. The Project applicant would be required to pay applicable development impact fees in as required by City regulations.

Policy INF-4.2: Continue to require utilities to be placed underground for new development.

Consistent. The Project would include connections to
existing underground utilities. New above ground utilities would not be constructed as part of the Project.

GOAL ED-7.0: Encourage development and preservation
of affordable workforce housing to increase housing
opportunities and improve quality of life for workers in Orange.

Consistent. The Project would construct new housing for residents who are most likely employed. The Project would increase housing opportunities with recreation and open space that provide for quality of life within the City.

Policy ED-7.1: Identify and market sites appropriate for housing development for all income groups that will support adjacent commercial development.

Consistent. The Project would construct new housing that would support adjacent and nearby commercial
development.

Municipal Code. The Project site is zoned Limited Business Tustin Redevelopment Project Area (CTR), which is intended to provide for limited commercial uses for a wide variety of goods and services.

The Project includes a Zone Change to change the site zoning from C-TR to R3 (Multiple-Family Residential) with application of the Small Lot Subdivision Development Standards for fee simple duplex and detached residences. As previously shown in Table AES-1, the Project would comply with the development standards per Chapter 17.14, Residential Districts, of the Orange Municipal Code.

Therefore, no impact related to Municipal Code inconsistency would occur.

Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact.

Existing Plans, Programs, or Policies
None.

Sources
City of Orange General Plan. 2010. [online]: https://www.cityoforange.org/ourcity/departments/community-development/general-plan. Accessed April 2025. 453
102

12. MINERAL RESOURCES. Would the project:

Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(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) The Project site is designated Mineral Resource Zone 3 (MRZ-3) by the California Geological Survey, which is defined as an area containing mineral deposits whose significance cannot be evaluated from available data. As described previously, the Project site is fully paved with asphalt and surrounded by developed areas, which do not include mining. Additionally, the Orange General Plan EIR determined that no impacts would occur to mineral resources within the City. Thus, implementation of the Project would not result in the loss of availability of a known mineral resource that would be of value to the region or the residents of the state, and impacts would not occur.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact. b) As previously discussed, the Orange General Plan EIR determined that no impacts would occur to mineral resources within the City. Thus, no impacts related to the loss of availability of a locally important mineral resource recovery site, as delineated on a local general plan, specific plan, or other land use plan, would occur as a result of the Project.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact.

Existing Plans, Programs, or Policies
None.

Sources
City of Orange General Plan. 2010. [online]: https://www.cityoforange.org/ourcity/departments/community-development/general-plan. Accessed May 2025.

City of Orange General Plan Program EIR, 2010. Accessed May 2025:
https://www.cityoforange.org/home/showpublisheddocument/240/637698173340500000 CGS (California Geological Survey). 1994. Open File Report 94-15: Generalized Mineral Land Classification of Orange County, California. Plate 1. Accessed May 2025:
https://www.conservation.ca.gov/cgs/maps-data.
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103

13. NOISE. Would the project result in:

Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(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?
The discussion below is based on the Noise and Vibration Analysis prepared by Urban Crossroads in 2025, included as Appendix I.

Noise Terminology
Various noise descriptors are utilized in this analysis, and are summarized as follows:
• dB: Decibel, the standard unit of measurement for sound pressure level. • dBA: A-weighted decibel, an overall frequency-weighted sound level in decibels that approximates the frequency response of the human ear.
• Leq: The equivalent sound level, which is used to describe noise over a specified period of time, typically 1-hour, in terms of a single numerical value. The Leq of a time-varying signal and that of a steady signal are the same if they deliver the same acoustic energy over a given time. The Leq may also be referred to as the average sound level.
• Lmax: The instantaneous maximum noise level experienced during a given period of time. • Lmin: The instantaneous minimum noise level experienced during a given period of time. • CNEL: The Community Noise Equivalent Level, which, similar to the Ldn, is the average Aweighted noise level during a 24-hour day that is obtained after an addition of 5 dBA to measured noise levels between the hours of 7:00 pm to 10:00 pm and after an addition of 10 dBA to noise levels between the hours of 10:00 pm to 7:00 am to account for noise sensitivity in the evening and nighttime, respectively.
• Ambient Noise: The “ambient noise level” is the background noise level associated with a given environment at a specified time and is usually a composite of sound from many sources from many directions.

Noise Regulations
State Law
An interior CNEL of 45 dB is mandated by the State of California Noise Insulation Standards (CCR, Title 24, Part 6, Section T25-28) for residential dwellings and hotel and motel rooms. Conventional construction practices, with closed windows and fresh air supply systems or air conditioning normally suffice.
455
104
City of Orange General Plan Noise Element
The City’s General Plan Noise Element includes several polices to minimize the impacts of excessive noise levels and establishes noise level requirements for all land uses. The Noise Element contains the following policies related to the Project:

Policy 1.3: Incorporate design features into residential and mixed-use projects that can be used to shield residents from excessive noise.

Policy 1.4: Ensure that acceptable noise level are maintained near noise-sensitive uses.

Policy 3.1: Encourage noise-compatible land uses and incorporate noise-reducing design features within transit oriented, mixed-use development near rail corridors.

Policy 7.2: Require developers and contractors to employ noise minimizing techniques during construction and maintenance operations.

Policy 7.3: Limit the hours of construction and maintenance operations located adjacent to noisesensitive land uses.

The Noise Element provides specific noise level standards for all land use categories that are used to regulate traffic-related noise level impacts for noise-sensitive uses; both exterior and interior noise level standards are defined.

Within the Medium Density Residential Land Use designation, as proposed by the Project, the exterior noise standards of 65 dBA CNEL only apply to common outdoor recreation areas, as detailed in footnote 4 of the Noise Element Table N-3, included herein as Table N-1. Additionally, interior noise levels are not to exceed 45 dBA CNEL. Based on the City of Orange land use compatibility guidelines and noise standards, this noise study has been prepared to satisfy an exterior noise level of 65 dBA CNEL in common outdoor recreation areas and an interior noise level of less than 45 dBA CNEL. This approach is consistent with Table N-3 of the General Plan Noise Element, which is included below as Table N-1.

In addition, the City has stationary-source hourly average Leq exterior limits to control operational stationary source noise levels associated with development. These hourly and maximum performance standards (expressed in Leq) for non-transportation or stationary noise sources are designed to protect noise-sensitive land uses adjacent to stationary sources from excessive noise. According to Table N-4 of the General Plan Noise Element, acceptable stationary source exterior noise levels at the sensitive receiver are 55 dBA Leq during daytime (7:00 a.m. to 10:00 p.m.) hours and 45 dBA Leq during nighttime (10:00 p.m. to 7:00 a.m.) hours.
456
105
Table N-1: City of Orange General Plan Interior and Exterior Noise Standards Source: City of Orange General Plan Noise Element, Table N-3.

City of Orange Municipal Code
Municipal Code Section 8.24.040: This code section identifies exterior noise levels standards of 55 dBA Leq for the daytime hours (7:00 a.m. to 10:00 p.m.) and 50 dBA Leq during the nighttime (10:00 p.m. to 7:00 a.m.) hours. Per Section 8.24.040(B), for Medium Density Residential General Plan land use districts, exterior noise standards shall apply to common recreation areas only and shall not apply to private exterior space (such as a private yard, patio, or balcony). 457
106
Municipal Code Section 8.24.50: This code section states that noise sources associated with construction, repair, remodeling, or grading of any real property, provided said activities take place between the hours of 7:00 a.m. and 8:00 p.m. on any day except for Sunday or a Federal holiday.

Existing Ambient Noise
To assess the existing noise level environment, 24-hour noise level measurements were taken on Wednesday, March 19, 2025 at four locations on the Project site, as shown in Figure N-1. The noise measurements were summarized to provide the equivalent or the hourly energy average sound levels (Leq) to describe the existing ambient conditions. As detailed in Table N-2, the existing ambient noise on the ground at the Project site ranges from 55.3 to 63.4 dBA in the daytime and 56.3 to 65.3 dBA in the nighttime.

Table N-2: Ambient Noise Level Measurements
Location1 Description
Energy Average
Noise Level
(dBA Leq)
2 Daytime Nighttime
L1 Located at the site’s northern boundary near the
residence at 1800 E Heim Avenue

58.2 56.3
L2 Located at the site’s eastern boundary near the
residence at 2025 E. Denise Avenue

63.4 65.3
L3 Located at the site’s southern boundary near the
residence at 1931 E. Meats Avenue

57.5 58.6
L4 Located at the site’s southern boundary near the
residence at 2295 N. Tustin Street 55.3 57.1
Source: Appendix I 1 See Figure N-1 for the noise level measurement locations. 2 Energy (logarithmic) average levels. “Daytime” = 7:00 a.m. to 10:00 p.m.; “Nighttime” = 10:00 p.m. to 7:00 a.m.

Existing Sensitive Receptors
Sensitive receptors are generally defined as locations where people reside or where the presence of unwanted sound could otherwise adversely affect the use of the land. The City of Orange General Plan Noise Element defines noise-sensitive uses as residences, hospitals, convalescent and day care facilities, schools, and libraries. The nearest sensitive receptors to the Project site are the existing residences to the north and south of the site, as shown in Figure N-2 and described below:

R1: Location R1 represents the existing residence at 1800 E Heim Avenue, approximately 52 feet north of the Project site. Receiver R1 is placed at the building façade facing the Project site. A 24- hour noise measurement was taken near this location, L1 R2: Location R2 represents the existing residence at 2025 East Denise Avenue, approximately 236 feet east of the Project site. Receiver R3 is placed in the private outdoor living area (backyard) facing the Project site. A 24-hour noise measurement was taken near this location, L2. 458
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Figure N-1: Noise Measurement Locations
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Figure N-2: Sensitive Receiver Locations
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R3: Location R4 represents the existing residence at 1931 East Meats Avenue, approximately 5 feet south of the Project site. Receiver R3 is placed at the building façade facing the Project site. A 24- hour noise measurement was taken near this location, L3.

R4: Location R4 represents the existing residence at 2295 North Tustin Street, approximately 56 feet south of the Project site. Receiver R4 is placed at the building façade facing the Project site. A 24-hour noise measurement was taken near this location, L4.

Impact Analysis:
a) Potential for the Project to result in increases in ambient noise levels in excess of standards established in the general plan or noise ordinance, as described previously, were evaluated in the Noise and Vibration Analysis, which is included as Appendix I, and summarized below.

Construction
Noise generated by construction equipment would include a combination of trucks, power tools, trackers, bulldozers, excavators, graders, concrete mixers, and portable generators that when combined can reach high noise levels. Construction is expected to occur in the following stages: demolition, site preparation, grading, building construction, architectural coating, paving. To describe construction noise activities, the construction noise analysis was prepared using reference construction equipment noise levels from the Federal Highway Administration (FHWA), which published the Roadway Construction Noise Model (RCNM), which includes a national database of construction equipment reference noise levels. Table N3 provides the combined noise levels for the loudest construction activities expected for each stage of the proposed Project, assuming all equipment operates simultaneously.

Table N-3: Project Construction Reference Noise Levels
Construction
Stage
Reference
Construction
Equipment1
Reference
Noise Level @
50 Feet
(dBA Leq)
Composite
Reference Noise
Level
(dBA Leq)
2 Reference
Power Level
(dBA Lw)
3 Demolition
Concrete Saw 83
Excavator 77 86.1 117.7
Jack Hammer 82
Site
Preparation
Tractor 80
Front End Loader 75 82.9 114.5
Dozer 78
Grading
Tractor 80
Grader 81 84.2 115.9
Compactor (ground) 76
Building
Construction
Crane 73
Generator 78 82.1 113.7
Gradall 79
Paving
Paver 74
Dump Truck 72 77.8 109.5
Roller 73
Man Lift 68 76.2 107.8
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Construction
Stage
Reference
Construction
Equipment1
Reference
Noise Level @
50 Feet
(dBA Leq)
Composite
Reference Noise
Level
(dBA Leq)
2 Reference
Power Level
(dBA Lw)
3 Architectural
Coating
Compressor (air) 74
Generator (<25kVA) 70
Source: Appendix I 1 FHWA Road Construction Noise Model. 2 Represents the combined noise level for all equipment, assuming they operate at the same time, consistent with FTA Transit Noise and Vibration Impact Assessment guidance.
3 Sound power level represents the total amount of acoustical energy (noise level) produced by a sound source independent of distance or surroundings.

In addition to the typical construction activities listed above, the proposed Project includes concrete crushing as part of demolition of the existing building on the Project site. Table N-4 provides a summary of the reference average Leq concrete crushing noise level with multiple pieces of construction equipment operating simultaneously, and includes source noise levels for a hoe-ram or pavement breaker, which is a percussion hammer fitted to an excavator for breaking rock, and a concrete crushing activity including an impact hammer (hoe ram), front-end loader, and dump truck. As detailed in Table N-4 the combined noise level would be 84 dBA Leq at 50 feet.

Table N-4: Concrete Crushing Reference Noise Levels
Construction
Stage
Reference
Construction Activity1
Reference Noise
Level @ 50 Feet
(dBA Leq)
1 Combined
Noise Level
(dBA Leq)
2 Concrete
Crushing
Impact Hammer (hoe ram) 83
Front End Loader 75 84
Dump Truck 72
Source: Appendix I 1 FHWA's Roadway Construction Noise Model 2 Represents the combined noise level for all equipment assuming they operate at the same time consistent with FTA Transit Noise and Vibration Impact Assessment guidance for general construction noise assessment.

Orange Municipal Code Section 8.24.50(I) exempts construction noise if activities occur during the hours of 7:00 a.m. to 8:00 p.m., Monday through Saturday. No construction activity is permitted on Sundays and Federal holidays. Since the City does not have daytime construction noise level limits for activities that occur with the specified hours of the Orange Municipal Code, construction noise impacts were assessed using criteria from the Federal Transit Administration Transit Noise and Vibration Impact Assessment Manual (FTA Manual) that considers a daytime 8-hour average exterior construction noise level of 80 dBA Leq (8 hr.) the threshold for construction noise. Therefore, to evaluate whether the Project would generate potentially significant short-term noise levels at nearby noise-sensitive residential receiver locations, a daytime exterior construction noise level of 80 dBA Leq is used.

Using the reference construction equipment noise levels and the CadnaA noise prediction model, calculations of the Project construction noise level impacts by phase at the nearby sensitive receiver locations were completed. To account for the dynamic nature of construction activities, the CadnaA construction noise analysis evaluates the noise source activities as multiple moving point sources, or construction crews, within the limits of construction. Construction impacts are based on the loudest 462
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activity and the highest noise level calculated at each receiver location. As part of the construction noise analysis, the existing six to eight-foot-high cmu wall along the southern site boundary was modeled.

As shown in Table N-5, Project construction noise levels are expected to range from 67.5 to 75.2 dBA Leq at the closest nearby receiver locations, which does not exceed the 80.0 dBA Leq threshold. Thus, Project construction noise would be less than significant.

Table N-5: Project Construction Equipment Noise Levels at Receivers Receiver
Location
Construction Noise Levels (dBA Leq)
Demolition Site
Preparation Grading BuildingConstruction Paving ArchitecturalCoating Highest
Levels
R1 75.2 72.0 73.3 71.2 66.9 65.3 75.2
R2 67.5 64.3 65.6 63.5 59.2 57.6 67.5
R3 71.9 68.7 70.0 67.9 63.6 62.0 71.9
R4 71.3 68.1 69.4 67.3 63.0 61.4 71.3
Source: Appendix I
In addition to the typical construction activities listed above, the proposed Project includes concrete crushing as part of demolition of the existing building on the Project site. Figure N-3 shows the anticipated location of the crushing activity area in relation to the nearest receiver locations. Using the reference crushing construction equipment noise levels, calculations of the noise levels at the nearest sensitive receiver locations were completed. To assess the worst-case noise levels, the analysis relies on the highest noise levels when multiple pieces of equipment with the highest reference noise level are operating at the closest point from the edge of primary construction activity to each receiver location.

As shown on Figure N-3, the closest offsite receptor from the location of the crushing activity is approximately 174 feet. The concrete crushing construction noise levels are estimated to range from 63.0 to 73.2 dBA Leq at the nearest receiver locations, which would not exceed the 80 dBA Leq threshold.

Regarding increases in ambient noise from construction activities, based on the allowable noise levels in residential areas of the City and the exterior construction noise level of 80 dBA Leq an increase over the existing daytime ambient noise levels more than 20 dBA Leq from construction would be substantial.

To describe the temporary Project construction noise level contributions to the existing ambient noise environment, the Project construction noise levels were combined with the existing ambient noise levels measurements at the nearest off-site receiver locations. The difference between the combined Projectconstruction and ambient noise levels is used to describe the construction noise level contributions.

As indicated in Table N-6, the Project construction would result in temporary noise increases ranging from 5.5 to 17.1 dBA Leq during the daytime hours at the nearest receiver locations, which would not exceed the 20 dBA Leq construction noise increase threshold. Therefore, the temporary construction noise level increases would be less than significant.
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Figure N-3: Concrete Crushing Activities and Sensitive Receiver Locations 464
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Table N-6: Project Construction Noise Level Increases at Receivers Receiver
Location
Typical
Project
Construction
Noise Level
Measurement
Location
Reference
Ambient
Noise
Levels
Combined
Project
and
Ambient
Project
Increase
Increase
Criteria
Increase
Criteria
Exceeded?
R1 75.2 L1 58.2 75.3 17.1 20 No
R2 67.5 L2 63.4 68.9 5.5 20 No
R3 71.9 L3 57.5 72.1 14.6 20 No
R4 71.3 L4 55.3 71.4 16.1 20 No
Source: Appendix I
Operational
Onsite Exterior Noise. The existing ambient noise on the Project site is dominated by vehicle noise from SR-55 to the east of the Project site and N. Tustin Street to the west of the site. The Noise and Vibration analysis calculated the exterior noise levels throughout the Project site, including first through third floors and rooftop deck locations. As shown in Table N-7, the unabated exterior noise levels are estimated to range from 55.8 to 73.9 dBA CNEL in various areas throughout the proposed Project.

Table N-7: Project Exterior Noise Levels
Building Adjacent
Roadway
Unabated Exterior Noise Level
(dBA CNEL)
1st Floor 2nd Floor 3rd Floor Rooftop
Bldg. 1-2 Tustin St. 57.5 60.5 60.5 -
Bldg. 20, 50-51 SR-55 68.1 69.7 71.8 73.8
Bldg. 21 SR-55 67.4 68.9 70.7 -
Bldg. 46, 52-53 SR-55 69.1 71.3 73.9 72.0
Bldg. 54 SR-55 70.3 73.2 77.0 -
Bldg. 71 Tustin St. 55.8 58.7 58.7 -
Common Recreation Area Tustin St. 55.8 - - -
Source: Appendix I
As detailed previously, the General Plan Noise Element and municipal code exterior noise standards of 65 dBA CNEL only applies to common outdoor recreation areas in medium-density residential land use areas. As shown on Table N-7, the common outdoor use areas (e.g., recreation area) on the Project site would have exterior noise levels up to 55.8 dBA CNEL, which would not exceed the 65 dBA CNEL exterior noise standard. Thus, onsite exterior noise would not exceed the City’s criteria and impacts would be less than significant.

Interior Noise. To verify that the interior noise levels would comply with Title 24, Part 6, Section T25 28 45 dBA CNEL interior noise standard, future exterior noise levels were calculated at the first-, secondand third-floor building façade locations. Based on the site plans provided, the Project would provide air conditioning; thus, a “windows closed” condition was assumed for the purposes of the analysis.

The interior noise level is the difference between the predicted exterior noise level at the building façade and the noise reduction of the structure. Typical building construction provides a noise reduction of approximately 12 dBA with “windows open” and a minimum 25 dBA noise reduction with “windows closed.” To identify the noise reduction provided by the proposed building structures, noise reduction 465
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calculations were completed based on a sample of the interior rooms of residences located toward SR55 and interior habitable room(s) with a high number of exterior walls and openings (windows, doors, etc.) as detailed in the architectural floor plans for the Project. The floor plans for the Project were used to estimate the "windows closed" interior noise levels. The calculations were completed using standard windows with a minimum Sound Transmission Class (STC) rating of 27 that identify a noise reduction ranging from 30.4 to 33.0 dBA CNEL, as shown in Table N-8. In addition, the interior third-floor of the residence on Lot 54 (Plan 2) was evaluated with upgraded windows with a minimum STC rating of 31, as included by PDF-1, which determined that with upgraded windows the noise reduction would range from 32.0 to 32.7 dBA.

Table N-8: Noise Reduction Calculations
Plan Sample
Rooms1
Calculated Floor Plan Noise Reduction2
With STC 27
Windows
With STC 31
Windows
Plan 2
Den 31.5 32.1
Living 32.1 32.7
Bdrm. 1 31.3 32.0
Plan 3
Bdrm. 4 30.9 -
Kitchen 33.0 -
Bdrm. 3 31.9 -
Plan 4
Den 30.4 -
Kitchen 31.8 -
Bdrm. 2 31.0 -
Plan 5
Den 32.2 -
Living 31.3 -
Bdrm. 1 31.7 -
Minimum Noise
Reduction: 30.4 32.0
Source: Appendix I
The noise reduction data from Table N-8 was applied to each floor of the closest residences to the roadways, which is source of exterior noise at the site.

Table N-9 shows that the estimated interior noise levels using windows with a minimum STC rating of 27 at the first-floor building façade locations are expected to range from 55.8 to 70.3 dBA CNEL, and that the interior noise levels would range from 25.4 to 39.9 dBA CNEL with standard construction and windows in the closed position, which would not exceed the threshold of 45 dBA. 466
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Table N-9: First Floor Interior Noise Levels
Building Roadway
Noise
Level
at Façade
Required
Interior
Noise
Reduction
Calculated
Minimum
Noise
Reduction
Window
STC
Rating
Interior
Noise
Level
Exceed 45
dBA
Threshold?
Bldg. 1-5 Tustin St. 57.5 12.5 30.4 27 27.1 No
Bldg. 20, 50-51 SR-55 68.1 23.1 30.4 27 37.7 No
Bldg. 21 SR-55 67.4 22.4 30.4 27 37.0 No
Bldg. 46, 52-53 SR-55 69.1 24.1 30.4 27 38.7 No
Bldg. 54 SR-55 70.3 25.3 30.4 27 39.9 No
Bldg. 71 Tustin St. 55.8 10.8 30.4 27 25.4 No
Source: Appendix I
Table N-10 shows that the estimated interior noise levels with minimum STC windows rating of 27 at the second-floor building façade locations are expected to range from 58.7 to 73.2 dBA CNEL, and the interior noise levels would range from 28.3 to 42.8 dBA CNEL with standard construction and windows in the closed position, which would not exceed the threshold of 45 dBA.

Table N-10: Second Floor Interior Noise Levels
Building Roadway
Noise
Level
at Façade
Required
Interior
Noise
Reduction
Calculated
Minimum
Noise
Reduction
Window
STC
Rating
Interior
Noise
Level
Exceed 45
dBA
Threshold?
Bldg. 1-5 Tustin St. 60.5 15.5 30.4 27 30.1 No
Bldg. 20, 50-51 SR-55 69.7 24.7 30.4 27 39.3 No
Bldg. 21 SR-55 68.9 23.9 30.4 27 38.5 No
Bldg. 46, 52-53 SR-55 71.3 26.3 30.4 27 40.9 No
Bldg. 54 SR-55 73.2 28.2 30.4 27 42.8 No
Bldg. 71 Tustin St. 58.7 13.7 30.4 27 28.3 No
Source: Appendix I
Table N-11 shows that the future noise levels at the third-floor building façade locations are expected to range from 58.7 to 77.0 dBA CNEL, and that the interior noise levels would range up to 45.0 dBA CNEL for the residence on Lot 54 with upgraded construction using windows with a minimum STC rating of 31, as included by PDF-1, and windows in the closed position. The interior noise level analysis shows that the interior noise levels for all other interior locations of all residences would range from 28.3 to

43.5 dBA with standard construction and windows in the closed position, which would not exceed the threshold of 45 dBA.
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Table N-11: Third Floor Interior Noise Levels
Building Roadway
Noise
Level
at Façade
Required
Interior
Noise
Reduction
Calculated
Minimum
Noise
Reduction
Window
STC
Rating
Interior
Noise
Level
Exceed 45
dBA
Threshold?
Bldg. 1-5 Tustin St. 60.5 15.5 30.4 27 30.1 No
Bldg. 20, 50-51 SR-55 71.8 26.8 30.4 27 41.4 No
Bldg. 21 SR-55 70.7 25.7 30.4 27 40.3 No
Bldg. 46, 52-53 SR-55 73.9 28.9 30.4 27 43.5 No
Bldg. 54 SR-55 77.0 32.0 32.0 31 45.0 No
Bldg. 71 Tustin St. 58.7 13.7 30.4 27 28.3 No
Source: Appendix I
Overall, the interior noise level assessment demonstrates that with upgraded windows with a minimum STC rating of 31 for third-floor building façade of the residence on lot 54, as included by PDF-1, the 45 dBA CNEL interior noise standard would be met. For all other building façade locations, standard construction using windows with a minimum STC rating of 27 would meet the 45 dBA CNEL interior noise standard.

Project Traffic Noise. As detailed in Section 17, Transportation, the proposed Project would result in 511 daily trips, including 34 AM peak hour and 40 PM peak hour trips. The 40 PM peak hour trips is less than one vehicular trip per minute during the peak hour. The existing volumes on N. Tustin Street are 33,600 trips per day. The 511 daily trips equates to 1.5 percent increase in existing traffic volumes and a 0.1 dBA CNEL noise level increase at sensitive receivers along N. Tustin Street, which would not result in a perceptible noise level increase (i.e., less than 3 dBA CNEL). Therefore, impacts related to Project traffic noise would be less than significant.

Project Operational Noise. The proposed residences would generate noise from air conditioning units and from parking lot vehicle movements. At a uniform reference distance of 50 feet, typical residential air conditioning units would generate a reference noise level of 44.4 dBA Leq and parking lot vehicle movements would generate 31.4 dBA Leq (Appendix I). These noise levels were calculated at each of the sensitive receiver locations. Table N-12 shows the Project operational noise levels during the daytime hours of 7:00 a.m. to 10:00 p.m. would range from 33.6 to 47.6 dBA Leq at off-site receiver locations, which is less than the 55.0 dBA daytime noise level standard.

Table N-12: Daytime Project Operational Noise Levels
Noise Source
Operational Noise Levels by
Receiver Location (dBA Leq)
R1 R2 R3 R4
Air Conditioning Units 41.2 47.6 43.3 33.4
Parking Lot Vehicle Movements 7.7 15.7 25.9 20.6
Total (All Noise Sources) 41.2 47.6 43.4 33.6
Source: Appendix I
Table N-13 shows the Project operational noise levels during the nighttime hours of 10:00 p.m. to 7:00 a.m. at the existing off-site receiver locations, which are expected to range from 30.9 to 44.9 dBA Leq, 468
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and also less than the 45 dBA nighttime noise level standard. The differences between the daytime and nighttime noise levels are largely related to the estimated duration of noise activity Table N-13: Nighttime Project Operational Noise Levels
Noise Source
Operational Noise Levels by
Receiver Location (dBA Leq)
R1 R2 R3 R4
Roof-Top Air Conditioning Units 38.5 44.9 40.6 30.7
Parking Lot Vehicle Movements 3.8 11.7 21.9 16.6
Total (All Noise Sources) 38.5 44.9 40.7 30.9
Source: Appendix I
Project Operational Increases to Ambient Noise. To describe the Project operational noise level increases, the Project operational noise levels are combined with the existing ambient noise levels measurements for the nearby receiver locations. As indicated in Table N-14, the Project would generate daytime operational noise increases ranging from less than 0.1 to 0.2 dBA Leq at the nearest receiver locations. Table N-15 shows that the Project would generate nighttime operational noise level increases ranging from less than 0.1 to 0.1 dBA Leq at the nearest receiver locations. These Project-related operational noise level increases would not be audible and would not exceed the significance criteria of a readily perceptible increase of 5 dBA in areas below 65 dBA and an increase of 1.5 dBA in areas above 65 dBA. Therefore, Project-related operational noise level increases at the sensitive receiver locations would be less than significant.

Table N-14: Daytime Project Operational Noise Level Increases Receiver
Location
Total
Project
Operational
Noise Level
Measurement
Location
Reference
Ambient
Noise
Levels
Combined
Project
and
Ambient
Project
Increase
Increase
Criteria
Increase
Criteria
Exceeded?
R1 41.2 L1 58.2 58.3 0.1 5.0 No
R2 47.6 L2 63.4 63.5 0.1 5.0 No
R3 43.4 L3 57.5 57.7 0.2 5.0 No
R4 33.6 L4 55.3 55.3 0.0 5.0 No
Source: Appendix I
Table N-15: Nighttime Project Operational Noise Level Increases Receiver
Location
Total
Project
Operational
Noise Level
Measurement
Location
Reference
Ambient
Noise
Levels
Combined
Project
and
Ambient
Project
Increase
Increase
Criteria
Increase
Criteria
Exceeded?
R1 38.5 L1 56.3 56.4 0.1 5.0 No
R2 44.9 L2 65.3 65.3 0.0 1.5 No
R3 40.7 L3 58.6 58.7 0.1 5.0 No
R4 30.9 L4 57.1 57.1 0.0 5.0 No
Source: Appendix I
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Overall, construction and operational noise impacts would be less than significant, and no mitigation measures would be required.

Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact. b) Vibration refers to groundbourne noise and perceptible motions and has the potential to disturb people and damage buildings. Vibration levels calculated in root-mean-square (RMS), expressed in VdB, are best for characterizing human response to building vibration. Vibration levels calculated in peak particle velocity (PPV), expressed in inches per second, are best for characterizing potential for damage.

Construction
Construction activities for the proposed Project would include demolition, excavation, and grading activities, which have the potential to generate low levels of groundborne vibration. People living and working in close proximity to the Project site could be exposed to the generation of excessive groundborne vibration or groundborne noise levels related to construction activities. The results from vibration can range from no perceptible effects at the lowest vibration levels, to low rumbling sounds and perceptible vibrations at moderate levels, to slight structural damage at the highest levels. Ground vibration levels associated with various types of construction equipment are summarized in Table N-16.

Table N-16: Vibration Source Amplitudes for Construction Equipment Equipment PPV (in/sec)
at 25 feet
Small bulldozer 0.003
Jackhammer 0.035
Loaded Trucks 0.076
Large bulldozer 0.089
Hoe Ram 0.089
Vibratory Roller 0.210
Source: Appendix I
Because the City Orange does not have numeric vibration level thresholds, the Caltrans Transportation and Construction Vibration Guidance Manual vibration damage thresholds were used to assess potential temporary construction-related impacts at adjacent receptors. Caltrans guidelines show that a vibration level of up to 0.3 in/sec in PPV is considered safe for older residential structures and would not result in any construction vibration damage. Thus, the construction building vibration damage criterion is 0.3 in/sec in PPV.

Based on the construction vibration assessment methodology published by the FTA and Caltrans, Table N-17 identifies the expected Project-related vibration levels at the closest receiver locations. At distances ranging from 5 to 236 feet from Project construction activities, construction vibration velocity levels are estimated to range from 0.01 to 2.35 PPV (in/sec). The Project construction vibration levels would exceed the vibration threshold of 0.30 PPV (in/sec) at the closest residence which is approximately 5- feet from the construction boundary (Receiver R3). This vibration level at the closest sensitive receiver 470
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would not be sustained during the entire construction period and would only occur during the times that heavy construction equipment is operating adjacent to the Project site perimeter at the sensitive receiver.

Construction at the Project site would be restricted to the daytime hours, consistent with City of Orange requirements, eliminating potential vibration impacts during the sensitive evening and nighttime hours.

Table N-17: Project Construction Vibration Levels - Unmitigated Location
Distance
to
Const.

Activity
(Feet)1
Typical Construction Vibration Levels
PPV (in/sec) Thresholds
PPV
(in/sec)
Thresholds
Small Exceeded?
bulldozer
JackhammerLoaded
Trucks
Large
bulldozer
Vibratory
Roller
Highest
Vibration
Level
R1 52' 0.00 0.01 0.03 0.03 0.07 0.07 0.30 No
R2 236' 0.00 0.00 0.00 0.00 0.01 0.01 0.30 No
R3 5' 0.03 0.39 0.85 1.00 2.35 2.35 0.30 Yes
R4 56' 0.00 0.01 0.02 0.03 0.06 0.06 0.30 No
Source: Appendix I 1 Distance from receiver building facade to Project construction boundary (Project site boundary). "PPV" = Peak Particle Velocity
As the Project construction vibration levels would exceed the vibration thresholds at the closest residence which is approximately 5-feet from the construction boundary (Receiver R3), Mitigation Measure NOI1 is included which requires implementation of a 20-foot equipment buffer zone to restrict the use of heavy construction equipment (greater than 80,000 pounds), vibratory rollers, large loaded trucks, and large bulldozers within 20 feet of occupied sensitive receivers (which would be Receiver R3). As detailed in Table N-18, with implementation of the 20-foot equipment buffer zone shown in Figure N-4, construction equipment vibration would be reduced to 0.29 PPV (in/sec), which would be below the 0.30 PPV (in/sec) threshold and therefore would be less than significant.

Table N-18: Project Construction Vibration Levels - Mitigated Location
Distance
to
Const.

Activity
(Feet)1
Typical Construction Vibration Levels
PPV (in/sec) Thresholds
PPV
(in/sec)
Thresholds
Small Exceeded?
bulldozer
JackhammerLoaded
Trucks
Large
bulldozer
Vibratory
Roller
Highest
Vibration
Level
R1 52' 0.00 0.01 0.03 0.03 0.07 0.07 0.30 No
R2 236' 0.00 0.00 0.00 0.00 0.01 0.01 0.30 No
R3 20' 0.00 0.05 0.11 0.12 0.29 0.29 0.30 No
R4 56' 0.00 0.01 0.02 0.03 0.06 0.06 0.30 No
Source: Appendix I 1 Distance from receiver building facade to Project construction boundary (Project site boundary). "PPV" = Peak Particle Velocity
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Figure N-4: Noise and Vibration Measures
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As detailed previously, Project construction would include concrete crushing activities. Using the vibration source level of the construction equipment list provided in Table N-16, which includes source levels for a hoe ram or breaker representing a percussion hammer fitted to an excavator for breaking rock. Table N-19 details that the concrete crushing construction equipment vibration with the highest reference vibration activity at distances ranging from 187 to 563 feet from the concrete crushing activities, as shown on Figure N-3, construction vibration levels are estimated to be less than 0.01 PPV (in/sec) and would remain below the 0.30 PPV (in/sec) threshold for vibration at all receiver locations.

Therefore, potential vibration impacts would be less than significant from the Project concrete crushing construction activities.

Table N-19: Concrete Crushing Vibration Impacts at Nearest Receptor Location
Distance
to
Const.

Activity
(Feet)
Typical Construction Vibration Levels
PPV (in/sec) Thresholds
PPV
(in/sec)
Thresholds
Small Exceeded?
bulldozer
JackhammerLoaded
Trucks
Large
bulldozer
Hoe
Ram
Highest
Vibration
Level
R1 187' 0.00 0.00 0.00 0.00 0.00 0.00 0.30 No
R2 563' 0.00 0.00 0.00 0.00 0.00 0.00 0.30 No
R3 292' 0.00 0.00 0.00 0.00 0.00 0.00 0.30 No
R4 174' 0.00 0.00 0.00 0.00 0.00 0.00 0.30 No
Source: Appendix I
"PPV" = Peak Particle Velocity
Operational Impacts
Operation of the proposed residences would include heavy trucks for residents moving in and out of the units and garbage trucks for solid waste disposal. Truck vibration levels are dependent on vehicle characteristics, load, speed, and pavement conditions. However, as shown on Table N-16, vibration levels from loaded trucks generate 0.076 inch per second PPV. Truck movements on site would be travelling at very low speed, so it is expected that truck vibration at nearby sensitive receptors would be less than 0.076 inch per second PPV, which is less than the threshold of 0.3 inch per second PPV.

Therefore, operational vibration impacts would be less than significant.

Significance Determination: Less than significant impact with mitigation incorporated.

Mitigation Measures:

MM NOI-1: The City of Orange (City) Director of Community Development, or designee, shall verify prior to issuance of demolition or grading permits, that the construction plans require that the construction contractor restrict the use of heavy construction equipment (i.e., greater than 80,000 pounds), vibratory rollers, large loaded trucks, and large dozers within 20 feet of any off-site receiver location. Instead, smaller, rubber-tired bulldozers (less than 80,000 pounds) shall be used within this area during Project construction to reduce vibration levels.

Significance Determination After Mitigation: Less than significant impact. c) The Project site is neither located within an airport land use plan, nor within two miles of a public airport. The nearest airports are the John Wayne Airport, located approximately 10 miles south of the Project site in Santa Ana, and the Fullerton Municipal Airport, located approximately 8.6 miles northwest in the City of Fullerton. Therefore, the Project would not expose people residing or working 473
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in the Project site to excessive noise levels related to a public airport or public use airport. Thus, no impacts would occur.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact.

Existing Plans, Programs, or Policies
None.

Sources
Noise and Vibration Impact Analysis. 2025. Prepared by Urban Crossroads. (Appendix I). 474
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14. POPULATION AND HOUSING. Would the project:

Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(a) Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
(b) Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere? Impact Analysis:
a) The Project site is currently developed with a vacant retail commercial building that was developed in 2007.

The California Department of Finance data from January 2025 states that there are 139,724 residents and 48,301 housing units within the City. Of these housing units, 96.8 percent of them were occupied. The different types of housing units in the City consist of 55.4 percent single-family detached residences,

10.9 percent single-family attached residences, 10.1 percent residences within buildings containing between 2 and 4 units, 21.1 percent in buildings containing 5 or more units, and 2.5 percent consist of mobile homes. The California Department of Finance data identifies the City’s 2025 average household size as 2.84 persons per household. However, the City’s 2021-2029 Housing Element Update identifies a 3.18 average persons per household.

The Southern California Association of Governments (SCAG) Connect SoCal 2024 demographics and growth forecasts project that the City’s households will grow to 49,400 by 2035 and to 50,300 by the year 2050. This is an increase of 2,135 households between 2024 and 2050. However, the City’s 2021- 2029 Housing Element Update details that the City has a much larger Regional Housing Needs Allocation (RHNA) of 3,936 units. Of the RHNA units, 677 (17.2%) would be for moderate income households and 1,588 units (40.4%) would be for above moderate income households.

Construction
Construction of the Project would provide short-term jobs over an approximately 14-month period.

Many of the construction jobs would be temporary and would be specific to the project. This workforce would include a variety of craftspeople, such as cement finishers, iron workers, welders, carpenters, electricians, painters, and laborers. It is anticipated that the Project-related construction labor force would already be located in the Project vicinity, travel from one construction project to another as needed, and workers would not be expected to relocate their places of residence as a consequence of working on the Project. Therefore, the Project would not be expected to induce substantial population growth or demand for housing through increased construction employment.

Operation
The Project would redevelop the site with 71 attached and detached residences. Based on the City’s 2021-2029 Housing Element Update estimate of 3.18 average persons per household, the 71 residences that would be developed on the Project site would result in approximately 226 residents at full capacity.

This would equate to an increase of 0.2 percent of the City’s existing population and 0.1 percent of the City’s existing housing units. This also equates to 3.3 percent of the SCAG projected increase in 475
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households between 2024 and 2050, and 1.8 percent of the City’s RHNA allocation. Further, the Project would equate to 3.1 percent of the City’s moderate and above moderate income household RHNA allocations. This is not considered a substantial increase due to the limited number of residents and residential units that would result from the Project, which is located within an urban area.

In addition, indirect growth is related to the expansion of infrastructure, such as water, sewer, drainage, or street systems that would serve areas beyond the proposed development. The Project would be served by the existing infrastructure that currently serves the site and that the new residences would connect to.

Therefore, the Project would not result in inducement of substantial population growth, either directly or indirectly, and impacts would be less than significant.

Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact. b) No housing currently exists on the Project site and the site is currently developed with a vacant retail commercial building. Construction of the Project would not require the removal or displacement of existing housing, and therefore, would not require construction of replacement housing elsewhere. Thus, no impacts would occur.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact.

Existing Plans, Programs, or Policies
None.

Sources
City of Orange Municipal Code. 2022. [online]:
https://library.qcode.us/lib/orange_ca/pub/municipal_code/item/title_10- chapter_10_83?view=all. Accessed May 2025.

City of Orange General Plan. 2010. [online]: https://www.cityoforange.org/391/General-Plan.

Accessed May 2025.

City of Orange 2021‐2029 Housing Element Update Accessed April 2025:
https://www.cityoforange.org/home/showpublisheddocument/4968/638351489094930000 Connect SoCal 2024 Demographics and Growth Forecast Technical Report. Accessed April 2025:
https://www.scag.ca.gov/sites/default/files/2024-05/23-2987-tr-demographics-growth-forecastfinal-040424.pdf State of California, Department of Finance, E-5 Population and Housing Estimates for Cities, Counties and the State — January 1, 2021-2025. Sacramento, California, May 2025. Accessed April 2025: https://dof.ca.gov/forecasting/demographics/estimates/e-5-population-and-housingestimates-for-cities-counties-and-the-state-2020-2025/ 476
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15. PUBLIC SERVICES. Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(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?
ii) Police Protection?
iii) Schools?
iv) Parks?
v) Other public facilities?
Impact Analysis:
(a) i) Fire protection and other related services in the City of Orange are provided by the Orange City Fire Department, which consists of eight stations. The Fire Chief and management staff of the City of Orange monitor service needs to evaluate adequacy of service and annual budget changes. Staffing ratios and response times are not used to determine service adequacy.

There are three City fire stations within 3.5 miles of the Project site, which are listed below. • Station 1: 1176 E. Chapman Avenue; 3.3 miles from the Project site • Station 2: 2900 E. Collins Avenue; 2.6 miles from the Project site • Station 3: 1910 N. Shaffer Street; 1.4 miles from the Project site The closest fire station to the Project site is Station No. 3, located at 1910 N. Shaffer Street, which is located approximately 1.4 roadway miles from the Project site. The Orange City Fire Department 2024 Annual Report states that the average response time is 5 minutes and 28 seconds and that the Fire Department has 40 suppression personnel and 24 administrative staff members on duty daily. The City’s 2025-2026 Annual Budget and 5 Year Capital Improvement Plan identifies that the Fire Department has 115 sworn fire staff and 27 non-sworn staff, which totals 1.22 sworn fire staff per 1,000 residents.

As the existing retail building on the Project site is vacant no people are on the site, operation of the proposed Project may result in an incremental increase in demand for fire protection and emergency medical services, as new residents would be on site. However, as detailed in Section 14, Population and Housing, the proposed 71 residences would result in approximately 226 residents at full capacity. If equating the sworn Fire Department staff to the number of residents, the proposed Project would result in the need for 0.28 of an additional sworn staff person, which would not require construction of new or expansion of existing Fire Department facilities. Also, the Project would be required to adhere to the California Fire Code, as included in the Orange Municipal Code and ensured through the City’s permitting process.

Orange City CouncilMay 26, 2026

Orange City Council
May 26, 2026