Agenda packet — Orange City Council, May 26, 2026 (part 3 of 10)

As there are currently three fire stations within 3.5 miles of the site, with the closest one 1.4 miles from the site, and due to the limited number of new residents on the site, the increase in fire service demands from the Project would be minimal and would not require construction of a new or physically altered fire station that could cause environmental impacts. Therefore, the Project would not result in the need 477
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for new or expanded fire service facilities and impacts related to fire services 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. (a) ii) The Project site is located within the service area of the Orange Police Department. The Police Department headquarters are located at 1107 North Batavia Street, approximately 3.2 miles southwest of the Project site. The City of Orange Police Department 2024 Annual Report details that the Police Department had 95,570 calls for service in 2024 with a 4-minute average response time for emergency calls; and the dispatch received 49,276 emergency (911) calls of which 99.18 percent were answered within 10 sections. The City’s 2025-2026 Annual Budget and 5 Year Capital Improvement Plan identifies that the Police Department has 165 sworn full-time officers and 78 non-sworn staff, which includes staffing for the dispatch center.

The Orange Police Department does not use officer-to-population ratio or standard response time metrics to evaluate service adequacy. Factors used to evaluate police service needs include demographics, services calls, crime trends, and population. However, as the existing retail building on the Project site is vacant and no people are currently on the site, the proposed Project may result in an incremental increase in demand for police services, as new residents would be on site. As detailed in Section 14, Population and Housing, the proposed 71 residences would result in approximately 226 residents at full capacity. The existing 165 sworn full-time officers equate to 1.18 officers per 1,000 City residents. The addition of 226 residents at full capacity of the proposed Project would equate to a potential need for

0.27 of an additional sworn officer, which would not require construction of new or expanded Police Department facilities.

The proposed 71 residences are adjacent to existing residential and commercial areas and are anticipated to generate a typical range of police service calls, such as theft, domestic disturbances, and vandalism.

To ensure adequate services are provided and to minimize the demands on police services, security and design measures which employ defensible concepts would be utilized in Project development and construction plans. These measures incorporate the concepts of Crime Prevention Through Environmental Design (CPTED), which involve the placement, and orientation of structures, access and visibility of common areas, placement of doors, windows, addressing, lighting and landscaping. CPTED promotes public safety, physical security, and allows residents the ability to monitor activity. In addition, the Project would comply with the requirements established in Chapter 15.52 of the Municipal Code (Building Security Ordinance #6-22). Conditions related to CPTED and the City of Orange Building Security Standards would be included in the Project. While the Project would result in new residents on the site that could create the need for police services, the limited and incremental increase would not result in the need for new or expanded police facilities, and impacts related to police services 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. (a) iii) The Project consists of development of 71 residences that would likely house students that would attend public schools. The Project site is located within the Orange Unified School District boundaries. 478
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The District’s school site locator mapping identifies that students residing on the Project site would attend the following schools:
• Serrano Elementary School, located at 17741 Serrano Avenue • Cerro Villa Middle School, located at 17852 Serrano Avenue • Villa Park High School, located at 18042 Taft Avenue
As the proposed Project provides detached and paired residences, the generation rate for single-family residences was used to estimate the number of students that would reside on the Project site. As shown in Table PS-1, based on the Orange Unified School District student generation rates, the proposed Project would result in 11 elementary students, three middle school students, and seven high school students, which would total 21 students at Project buildout.

Table PS-1: Project Student Generation
School Type Single-Family Rate Total Students
Elementary School (K–5) 0.1490 11
Middle School (6–8) 0.0470 3
High School (9–12) 0.0956 7
Total Students 0.2916 21
Source: Orange Unified School District Residential Commercial/Industrial Development School Fee Justification Study, 2025.

The School District’s 2025 Residential Commercial/Industrial Development School Fee Justification Study identifies that 4,408 elementary school seats, 751 middle school seats and 160 high school seats are available to house students generated from future residential units. Thus, the 21 students that would be generated from the Project would be accommodated by existing facilities.

Additionally, pursuant to Government Code Section 65995 et seq., the need for additional school facilities is addressed through compliance with school impact fee assessment. SB 50 (Chapter 407 of Statutes of 1998) sets forth a state school facilities construction program that includes restrictions on a local jurisdiction’s ability to condition a project on mitigation of a project’s impacts on school facilities in excess of fees set forth in the Government Code. The Project would be required to contribute fees to the Orange Unified School District in accordance with the Leroy F. Greene School Facilities Act of 1998 (Senate Bill 50). Pursuant to Senate Bill 50, payment of school impact fees constitutes complete mitigation under CEQA for Project‐related impacts to school services.

Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact. (a) iv) The proposed Project would add new residents to the City who would increase the demand for park facilities. As detailed in Section 14, Population and Housing, the Project would result in approximately 226 residents at full capacity. According to the City of Orange General Plan Natural Resources Element the City’s park objective is to provide 3 acres of parkland per 1,000 residents and the City has approximately 251 acres of parkland. At a rate of 3 acres of parkland per 1,000 residents the Project’s estimated 226 residents would require 0.678-acre (29,534 square feet) of parkland. However, the proposed 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 479
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paseo areas that provide for onsite open space and recreation. In addition, the City requires in-lieu fees for new residential projects to improve current park facilities and to acquire additional land for the construction of new parks. Therefore, due to the limited residents onsite, provision of onsite facilities, and payment of in-lieu fees the Project would not generate an increase in use of the existing parks such that substantial physical deterioration of facilities would occur or be accelerated that could cause construction of new or altered facilities. Thus, impacts related to parks 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. (a) v) The proposed Project would place limited and incremental additional demands on other public facilities. These facilities range from the City’s library to streets, storm drains, and other public facilities such as City Hall, etc. However, the Project site is located within an urban and developed area of the City that is already served by public facilities. Thus, redevelopment of the site with 71 residences that would house approximately 226 residents at full capacity would have a less than significant impact on other public facilities.

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/391/General-Plan.

Accessed February 24, 2023.

Orange City Fire Department 2024 Annual Report. Accessed September 2025:
https://static1.squarespace.com/static/62c47583a67bd82b35d529e7/t/68407c0e69e12e18e7409 97f/1749056543367/2024+Annual+Report_Final+%28website%29.pdf Orange City Fire Department. Evacuation Information. [online]: https://orangecityfire.org/evacuationinfo. Accessed May 2025.

City of Orange Police Department 2024 Annual Report. Accessed September 2025:
https://www.cityoforange.org/home/showdocument?id=4318&t=638163205533964554 Orange Unified School District School Locator and Maps. Accessed October 2025:
https://www.orangeusd.org/our-schools/school-locator-maps Orange Unified School District Residential Commercial/Industrial Development School Fee Justification Study, March 26, 2025. Accessed October 2025:
https://www.orangeusd.org/departments/facilities-planning/developer-fees 480
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16. RECREATION. Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(a) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? (b) Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment?
Impact Analysis:
a) The City of Orange has approximately 251 acres of parkland and provides recreational services for the City. The closest parks to the Project site include Eisenhower Park and Lake that is 0.8 mile north of the Project site, Shaffer Park that is 1.5 miles southwest of the Project site, and Olive Park that is 1.7 miles from the Project site. As detailed previously, the Project would result in approximately 226 residents at full capacity and 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 that provide for onsite open space and recreation. Due to the limited residents onsite and provision of onsite recreation facilities, the Project would not generate an increase in use of the existing parks such that substantial physical deterioration of facilities would occur or be accelerated. Therefore, impacts related to physical deterioration of a recreation facilities 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) As detailed previously, the Project would result in approximately 226 residents at full capacity and 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 that provide for onsite open space and recreation. The impacts of development of these recreational amenities are considered part of the impacts of the Project as a whole and are analyzed throughout the various sections of this document. For example, activities such as excavation, grading, and construction, as required for the recreational components of this Project, are analyzed in the Air Quality, Greenhouse Gas Emissions, Noise, and Transportation sections.

In addition, while the Project would contribute park development fees pursuant existing City requirements to be used towards the future expansion or maintenance parks and recreational facilities, these fees are standard with every residential development, and the Project would not require the construction or expansion of other recreational facilities that might have an adverse physical effect on the environment. As a result, 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. 481
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Existing Plans, Programs, or Policies
None.

Sources
City of Orange General Plan. 2010. [online]: https://www.cityoforange.org/391/General-Plan.

Accessed October 2025.

City of Orange Park Locations Mapping. Accessed October 2025: https://www.cityoforange.org/ourcity/departments/community-services/parks-and-permits/park-locations 482
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17. TRANSPORTATION. Would the project:

Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(a) Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities?
(b) Would the project conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b)?
(c) Substantially increase hazards due to a geometric design feature (e. g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?
(d) Result in inadequate emergency access?
The discussion below is based on the Level of Service (LOS) Screening Analysis prepared by EPD Solutions in 2025 (included as Appendix J) and the VMT Screening Memo prepared by EPD Solutions in 2025 (included as Appendix K).

Impact Analysis:
a) The proposed 71-unit residential Project on a developed site that is adjacent to existing roadway, transit, bicycle, and pedestrian infrastructure would not result in a conflict with any related program, plan, ordinance or policies related to the circulation system, as detailed below.

Roadway
As per the City of Orange Guidelines for TIA Section 1, a roadway analysis is not required if a project meets any of the following criteria:

1. The project generates less than 100 peak hour trips.

2. The project generates less than 1,600 average daily trips (ADT) on the Arterial Highway System.

3. The project would not add 51 or more peak hour trips to any intersection.

4. The project would not result in variations from the standards and guidelines.

5. A City Traffic Engineer determines the project does not have unique characteristics that warrant evaluation.

Construction. Construction activities associated with the Project would generate vehicular trips from construction workers traveling to and from the Project site and delivery and hauling of construction supplies to, and debris and recyclable solid waste from, the Project site. The CalEEMod modeling completed for the Project (Appendix A) shows that hauling during the demolition and grading phases of construction would generate the most vehicular trips. The demolition phase is anticipated to last for 20 work days and involves approximately 81.5 haul trips that would occur throughout the day and 30 roundtrip worker trips; and the grading phase would require of 115 haul trips that would also occur throughout the day and 30 round-trip worker trips per day for 8 days (as indicated on Table 3, Construction Schedule).

These levels of construction traffic would not exceed the City of Orange threshold for evaluation of roadways, and it would not conflict with a circulation system program, plan, ordinance or policy. In addition, the construction related trips would generally travel from SR 55 to N. Tustin Street, which provides direct access to the Project site. Direct access from the freeway and arterial streets to the site 483
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would provide for efficient construction trips on existing roadway facilities. Impacts would be less than significant.

Operation. The trip generation for the proposed Project was estimated in accordance with the Institute of Transportation Engineers (ITE) Trip Generation Manual, 11th Edition (2021). The ITE Land Use Code 863 (Electronics Superstore) was applied to represent the former Best Buy store. Although no trip credit was applied for the existing 45,676 square foot Best Buy retail store building on the Project site, the number of trips previously generated from the site was included to provide an informational comparison.

As shown in Table T-1, the Best Buy store is estimated to have previously generated 1,875 daily trips, 16 AM peak hour trips, and 194 PM peak hour trips.

Table T-1: Former Best Buy Store Trip Generation
AM Peak Hour PM Peak Hour
Land Use Units Daily In Out Total In Out Total
Trip Rates
863 Electronics Superstore¹
1000 Sq.

Ft. GFA 41.05 0.25 0.09 0.34 2.13 2.13 4.25
Project Trip Generation
1 Vacant Ex-Best Buy¹ 45.676
1000 Sq.

Ft. GFA 1,875 12 4 16 97 97 194
Pass By (Daily 0%, AM 0%, PM 40%) 0 0 0 0 -39 -39 -78
Total Electronics Superstore Trip Generation 1,875 12 4 16 58 58 116 Total Former Best Buy Trip Generation 1,875 12 4 16 97 97 194 ¹Institute of Transportation Engineers, Trip Generation Manual, 11th Edition, 2021. Land Use Code 863 - Electronics Superstore (Average Rate)
Source: Appendix J
The trips generated by the proposed 71 residences were estimated using ITE Land Use Code 215, SingleFamily Attached Housing. As shown in Table T-2, the proposed Project is expected to generate a total of 511 daily trips, including 34 AM peak hour and 40 PM peak hour trips. This is less than the City’s threshold to require roadway analysis, which is 100 peak hour trips, 1,600 daily trips, or 51 peak hour trips.

Table T-2: Proposed Project Trip Generation
AM Peak Hour PM Peak Hour
Land Use Units Daily In Out Total In Out Total
Trip Rates
215 Single-Family Attached Housing¹ Dwelling Units 7.20 0.15 0.33 0.48 0.32 0.25 0.57 Project Trip Generation
Single-Family Attached Housing¹ 71 Dwelling Units 511 11 23 34 23 17 40 Total Project Trip Generation 511 11 23 34 23 17 40
¹Institute of Transportation Engineers, Trip Generation Manual, 11th Edition, 2021. Land Use Code 215 - Single-Family Attached Housing (Average Rate)
Source: Appendix J
Operation of 71 residences would result in a limited number peak hour trips that would have direct access to and from the freeway and arterial streets to the site, which would provide for efficient operational trips 484
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on existing roadway facilities. Access to the proposed Project would be provided by a 29-foot wide accessway 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 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. In addition, the Project provides for a balance of land uses by providing additional housing in an area with commercial, retail, and service uses. Likewise, the Project supports a reduction in miles traveled by providing residences in areas with employment. Thus, the Project would not result in an impact related to roadway circulation programs, plan, ordinance, or policy.

Transit
Public transportation is provided to the City by the Orange County Transportation Authority (OCTA).

There are several existing bus routes along N. Tustin Avenue, including Routes 42, 46, 50, 71, and 167.

OCTA buses are equipped with wheelchair lifts, tie-downs and folding seats to accommodate most wheelchair configurations and are equipped with bicycle racks. The closest OCTA bus stop is located across from the Project site on N. Tustin Avenue.

The existing bus services would provide efficient transportation to and from the site for residents and visitors and has the potential to reduce vehicle miles traveled. In addition, because the Project is located near existing bus routes and within an existing mixed-use area, the Project is consistent with providing new residential in areas served by transit, which is consistent with regionwide policies related to addressing the circulation system. Overall, impacts related to transit services would not occur as a result of the implementation of the proposed Project.

Bicycle
While there is no existing bicycle lane located on N. Tustin Street, the Project does not involve changes to the existing bicycle lanes. The Project includes installation of bicycle racks on the Project site for use to encourage bicycle transportation. As a result, the Project would not result in conflict related to bicycle circulation or policies related to bicycle facilities.

Pedestrian facilities
Sidewalks currently exist on both sides of N. Tustin Street. The proposed Project would provide for pedestrian circulation by constructing new onsite sidewalks and pathways that would provide pedestrian access to the onsite open space areas and connect to the existing sidewalks on N. Tustin Street. The Project would provide onsite pedestrian circulation to facilitate use of the existing offsite sidewalks; and therefore, potential impacts related to pedestrian facilities or a conflict with any program, plan, ordinance, or policy related to provision of pedestrian facilities would not occur.

Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact. b) In response to Senate Bill (SB) 743, Section 15064.3 was added to the CEQA Guidelines, which became effective on July 1, 2020. CEQA Guidelines Section 15064.3 - Determining the Significance of Transportation Impacts states that Vehicle Miles Traveled (VMT) is the most appropriate measure of transportation impacts and provides lead agencies with the discretion to choose the most appropriate methodology and thresholds for evaluating VMT.
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The City of Orange adopted VMT impact guidelines on July 14, 2020 to identify projects that would be considered potential VMT impacts. If a project meets one of the following criteria, then impacts would be considered less than significant and no further analysis of VMT would be required.

1. The project is located within a Transit Priority Area (TPA).

2. The project is located in a low VMT generating area.

3. The project is considered a local-serving land use.

4. The project is generating less than 110 daily vehicle trips.

Project applicability to each criterion is described below.

Screening Criteria 1 - Transit Priority Area Screening: According to the City’s Guidelines, projects located in a TPA, with a FAR of more than 0.75 that do not provide more than required parking and is consistent with the Sustainable Communities Strategy (SCS) may be presumed to have a less than significant impact. The current transit services were reviewed to identify whether the Project is located within a TPA, which includes a corridor with fixed route bus service with service intervals no longer than 15 minutes during peak commute hours. (Pub. Resources Code, § 21155).

As detailed previously, public transportation in the City is provided by OCTA that operates several existing bus routes along N. Tustin Avenue, including Routes 42, 46, 50, 71, and 167. The closest OCTA bus stop is located across from the Project site on N. Tustin Avenue. The current frequency of OCTA Route 50 along N. Tustin Avenue at the Project site is 15 minutes during peak hours, which became effective in November 2025. Therefore, the Project site is currently located within a TPA.

However, the proposed Project does not satisfy all of the other required TPA screening criteria, as detailed below:
• Floor Area Ratio (FAR): The proposed Project includes 57 three-bedroom residences and 14 fourbedroom residences that would be between 2,008 and 2,117 square feet on the 4.235 gross acre site and would result in a FAR of 0.79, which would exceed a FAR of 0.75. • Parking: The City of Orange requires a total of 174 parking stalls for the proposed Project. The Project provides a total of 179 parking stalls, which is 5 more parking stalls than required by the City. Therefore, the Project does not meet this screening criteria. • SCS Consistency: The Project is consistent with the SCS because the Project would develop 71 townhome residences, which would generate 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.

Compared to SCAG growth projections, the proposed 71 residences equates to 3.3 percent of the projected increase in households in the City between 2024 and 2050 and thus, is consistent with the SCS.

Further, the City’s 2021-2029 Housing Element Update details that the City has a 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. The proposed 71 residences equates to

1.8 percent of the City’s total RHNA allocation, and 3.1 percent of the City’s moderate and above moderate income household RHNA allocations. Thus, the Project's generation of housing is consistent with growth projections in the SCS.
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In addition, vehicle trips included in the SCS is 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. The former Best Buy store generated approximately 1,875 daily vehicle trips and the proposed 71 residential units under the proposed Project would generate approximately 511 daily vehicle trips. Thus, the proposed Project would not result in growth in vehicle trips or related emissions and would not conflict with the SCS.
• Affordable Housing Displacement: The Project site does not include existing residential units, and the proposed Project does not result in the displacement of any affordable housing.

Therefore, while the Project is in a TPA, it does not meet all the requirements for Screening Criteria 1.

The Project would not meet Screening Criteria 1 because it includes five more parking stalls than required by the City.

Screening Criteria 2 - Low VMT Area Screening: The City’s Guidelines utilize the “NOCC+” tool to identify low VMT-generating areas for screening purposes. Under these guidelines, projects located within areas that generate VMT below the City of Orange General Plan Buildout VMT per service population (hereafter referred to as VMT/SP) may be presumed to have a less-than-significant VMT impact and may be screened from detailed VMT analysis.

However, the land use assumptions within the NOCC+ tool and screening maps available for the Project site are inconsistent with the proposed Project, as the historical use of the site was not residential.

Additionally, a preliminary review of the OCTAM model shows the Project is not located in a low VMT area. Therefore, the Project does not meet Screening Criteria 2 for low VMT areas.

Screening Criteria 3 – Low VMT Project Type: According to the City’s guidelines, projects proposing local-serving uses, such as community-oriented facilities, are generally presumed to have a less-thansignificant impact on VMT. Local-serving uses include K-12 schools, daycare centers, local parks, student housing, and community institutions like libraries and fire stations. Additionally, projects generating fewer than 110 average daily vehicle trips are typically not expected to substantially increase citywide or regional VMT.

The proposed residential Project (71 dwelling units) is expected to generate a total of 511 daily trips, including 34 AM peak hour and 40 PM peak hour trips. As the Project is neither a local-serving use, as defined by the City, nor does it generate fewer than 110 average daily trips, it does not meet Screening Criteria 3 for project type screening.

As the proposed Project does not meet the VMT screening criteria, as detailed above, a VMT analysis is required to identify the potential of the Project to result in an impact.

VMT Impact Thresholds
Per the City’s guidelines, a project would result in a significant project-generated VMT impact if either of the following conditions are satisfied:
• The baseline project-generated VMT per service population exceeds the City of Orange General Plan Buildout VMT per service population, or
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• The cumulative project-generated VMT per service population exceeds the City of Orange General Plan Buildout VMT per service population (SP). The City’s VMT/SP threshold of 31.3 VMT/SP under Cumulative Year (2050) was identified by the NOCC+ Tool.

Also, the project’s effect on VMT would be considered significant if it results in either of the following conditions being satisfied:
• The baseline link-level boundary Citywide VMT per service population increases under the plus project condition compared to the no project condition; or • The cumulative link-level boundary Citywide VMT per service population increases under the plus project condition compared to the no project condition.

The cumulative “no project” shall reflect the adopted Regional Transportation plan/Sustainable Communities Strategy (RTP/SCS); as such, if a project is consistent with the SCAG RTP/SCS (Connect SoCal), then the cumulative impacts (project effect on VMT) shall be considered less than significant subject to consideration of other substantial evidence.

Project-Generated VMT
The proposed Project would develop 71 residential units on a 4.235-acre site, which would result in a residential density of 16.76 units per acre. The California Air Pollution Control Officers Association (CAPCOA) Handbook for Analyzing Greenhouse Gas (GHG) Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity (October 2024) provides for a reduction in VMT calculations pursuant to Measure T-1: Increase Residential Density.

The CAPCOA Measure T-1: Increase Residential Density accounts for the VMT reduction achieved by a project that has a higher density of dwelling units compared to the average residential density within an area. Increased densities have been shown to affect the distance people travel and may result in greater options for the mode of travel they choose. Increasing residential density can result in shorter and fewer trips by single-occupancy vehicles. As defined by CAPCOA Measure T-1, “An acre in this context is defined as an acre of developed land, not including streets, school sites, parks, and other undevelopable land.” Based on this, the net acreage of the Project site is 3.146 acres, which would result in a proposed residential density of 22.57 units per net acre.

The equation for the reduction in VMT is based on the residential density of the Project and the residential density of a typical development, or the residential density in the relevant TAZ1 .
• Using the residential density of TAZ 573 where the Project is located under existing conditions of

13.27 DU/ac (338 households in the 26.9 residential acre [25.47 net acre] TAZ), the Projectgenerated VMT would be reduced by 15.4%.

The Project’s VMT analysis results, applying the 15.5% reduction of total VMT, for the Project using OCTAM are shown in Table T-3, OCTAM VMT Analysis of Project. As shown in Table T-3, the Project’s VMT/SP would be 27.7 in the Baseline (2025) Condition and 29.1 in the Cumulative (2050) Condition, which is 11.7 percent and 7.1 percent below the threshold of 31.3. Therefore, impacts related to Projectgenerated VMT would be less than significant. No mitigation measures are required. 1 Per the CAPCOA Handbook, Increase Residential Density (T1), p. 71, the formula for VMT reduction is A = ((B - C) / C) × D, where A (0–30.0%) represents the percentage reduction in GHG emissions from project VMT in the study area, B (du/acre) is the residential density of the project development (dwelling units per acre), C is the residential density of a typical development (9.1 du/acre); however, the residential density of the relevant Transportation Analysis Zone (TAZ) should be used instead of this typical value, and D (-0.22) is the elasticity of VMT with respect to residential density. 488
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Table T-3: OCTAM VMT Analysis of Project
Factor Base Year 2019 Baseline 2025 Cumulative 2050
Project TAZ 573 Zone Total OD VMT 7,659 7,753 8,146
CAPCOA Measure T-1 Reduction -15.4% -15.4% -15.4%
Project TAZ 573 Zone Total OD VMT with
CAPCOA Measure T-1 Reduction 6,479 6,558 6,890
TAZ 573 Population 237 237 237
TAZ 573 Service Population 237 237 237
Project VMT/SP 27.3 27.7 29.1
Threshold General Plan Buildout VMT/SP 31.3
Project VMT/SP Percentage Below Threshold - 11.7% 7.1%
Impact? - No No
Source: Appendix K
Project Effect On VMT
According to the City’s Guidelines, if a project causes the link-level boundary Citywide VMT per service population within the City to be higher than the No Project scenario under baseline or cumulative conditions, the project’s effect on VMT would be considered significant. Thus, a boundary method analysis was conducted to evaluate the Project’s effect on VMT. The daily VMT within the City is calculated by the sum of total link-based VMT of all the roadways within the City. The roadways selected to calculate daily VMT are shown in Figure T-1.

To calculate the daily VMT/SP, the total daily VMT within the City is divided by the total service population of the City. The total service population within the City is calculated by the sum of total population and employees of all the TAZs within the City. The Project’s effect on VMT results are shown in Table T-4. The citywide No Project VMT/SP for the City of Orange is 14.117 for Base Year (2019) and 14.514 for Cumulative Year (2050). Therefore, the City’s threshold of significance for Project Baseline (2025) was interpolated to be 14.197 VMT/SP. As shown in Table T-4, the Orange Citywide Boundary VMT/SP is 0.02% lower with the Project added under Project Baseline (2025) Conditions and 0.03% lower with the Project added under Cumulative (2050) Conditions. Therefore, the Project’s effect on VMT would be less than significant. No mitigation measures are required. 489
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Figure T-1: Roadways Selected to Calculate Daily VMT
Table T-4: Project Effects on VMT
Factor Base Year 2019 Baseline 2025 Cumulative Year 2050 Citywide Boundary VMT With Project 4,435,908 4,504,990 4,792,829 Citywide Population With Project 143,228 143,822 146,298 Citywide Employment With Project 129,924 131,703 139,118 Citywide Enrollment With Project 41,140 41,871 44,917
Citywide Service Population With Project 314,292 317,397 330,333 With Project Citywide Boundary VMT/SP 14.114 14.194 14.509 Citywide Boundary VMT No Project 4,433,377 4,502,607 4,791,066 Citywide Population No Project 142,991 143,585 146,061
Citywide Employment No Project 129,924 131,703 139,118
Citywide Enrollment No Project 41,140 41,871 44,917
Citywide Service Population No Project 314,055 317,160 330,096 No Project Citywide Boundary VMT/SP 14.117 14.197 14,514 Percent Below Threshold -0.02% 0.03%
Impact No No
Source: Appendix K
Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impact. 490
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c) The Project includes development of residences, open space, recreation, and circulation and parking.

The Project includes only residential uses and does not include any incompatible uses, such as farm equipment.

The proposed Project site would be accessed from N. Tustin Street through a 29-foot wide accessway along the west side of the site and a 22-foot-wide secondary driveway/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 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. Pedestrian circulation would be provided by an onsite sidewalk that would connect the proposed residential areas to the existing sidewalk along N. Tustin Street. The Project would not increase any hazards related to a design feature. The City’s construction permitting process includes review of Project plans to ensure that no potentially hazardous transportation design features would be introduced by the Project. As a result, impacts related to vehicular circulation design features 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 proposed construction activities and residential uses would not result in inadequate emergency access.

Construction
The proposed construction activities, including equipment and supply staging and storage, would occur within the Project site, and therefore would not require roadway lane closures that could restrict access of emergency vehicles to the Project site or adjacent areas. The installation of a new driveway and connections to existing infrastructure systems that would be implemented during construction of the proposed Project would not require closure of N. Tustin Street. Any temporary lane closures needed for utility connections or driveway access construction would be implemented consistent with the recommendations of the California Joint Utility Traffic Control Manual (Caltrans 2014), as required by construction permits. Thus, implementation of the Project through the City’s permitting process would ensure existing regulations are adhered to and that potential construction related emergency access impacts would not occur.

Operation
Operation of the Project would not result in inadequate emergency access. The Project driveway and internal access have been designed to meet City of Orange Fire Master Plan access standards that would be ensured through the City’s permitting procedures. The Project provides a 29-foot-wide accessway along the west side of the site and a 22-foot-wide secondary driveway/emergency access 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 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. As a result, impacts related to inadequate emergency access would not occur.

Significance Determination: Less than significant impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: Less than significant impacts. 491
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Existing Plans, Programs, or Policies
None.

Sources
Level of Service (LOS) Screening Analysis. 2025. Prepared by EPD Solutions, Inc. (Appendix J).

Vehicle Miles Traveled (VMT) Screening Analysis. 2026. Prepared by EPD Solutions, Inc. (Appendix K).
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18. TRIBAL CULTURAL RESOURCES.

Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American Tribe, and that is:

Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(a) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k).
(b) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1.

In applying the criteria set forth in subdivision (c) of Public Resources Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American Tribe.

The discussion below is based on the Cultural Resources Study prepared by BFSA Environmental Services in April 2025 (included as Appendix C) and tribal consultation pursuant to SB 18 and AB 52, as detailed below.

SB 18
As the Project includes a General Plan Amendment to change the land use designation of the Project site, the Project is required to comply with Senate Bill (SB) 18 (California Government Code Section 65352.3), which sets forth requirements for local governments to consult with California Native American tribes identified by the Native American Heritage Commission (NAHC) to aid in the protection of tribal cultural resources. The intent of SB 18 is to provide California Native American tribes an opportunity to participate in local land use decisions at an early stage of planning to protect or mitigate impacts on tribal cultural resources.

AB 52
The Project is required to comply with AB 52 regarding tribal consultation. Chapter 532, Statutes of 2014 (i.e., AB 52), requires that Lead Agencies evaluate a project’s potential to impact “tribal cultural resources (TCRs).” Such resources include sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are eligible for inclusion in the California Register or included in a local register of historical resources (PRC Section 21074). AB 52 also gives Lead Agencies the discretion to determine, supported by substantial evidence, whether a resource falling outside the definition stated above nonetheless qualifies as a “tribal cultural resource.” Tribal Consultation
A record search of the NAHC Sacred Lands File (SLF) was completed for the proposed Project on March 27, 2025; the results of which were negative. The NAHC provided a list of 11 tribes who may have knowledge of cultural resources in the Project area. The City also has a list of 4 tribes that have previously requested AB 52 notifications, three of which were also listed by the NAHC.

In compliance with the SB 18 and AB 52 requirements, the City sent letters on August 27, 2025 to the following 12 tribes:
• Cahuilla Band of Indians
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• Gabrieleno Band of Mission Indians – Kizh Nation
• Gabrieleno/Tongva San Gabriel Band of Mission Indians • Gabrielino Tongva Indians of California Tribal Council • Juaneno Band of Mission Indians Acjachemen Nation – Belardes • Juaneno Band of Mission Indians Acjachemen Nation – 84A • Pala Band of Mission Indians
• Santa Rosa Band of Cahuilla
• Soboba Band of Luiseno Indians
• Torres Martinez Desert Cahuilla Indians
• Gabrielino/Tongva Nation
• Gabrielino/Tongva Tribe
In response, the Gabrieleno Band of Mission Indians – Kizh Nation, Juaneno Band of Mission IndiansAcjachemen Nation – Banda, and the Juaneno Band of Mission Indians ~ Acjachemen Nation - Belardes submitted requests for consultation, as detailed below. • The Gabrieleno Band of Mission Indians - Kizh Nation submitted a request to consult on August 28, 2025. The Gabrieleno Band of Mission Indians – Kizh Nation submitted information via email on September 24, 2025 stating that the entire City area is within the Tribe’s Ancestral Tribal Territory and provided proposed mitigation measures that include tribe monitoring of all ground disturbing activity. In response to a City request on October 13, 2025, the tribe responded on October 14, 2025 providing a map showing the tribe’s ancestral territory that identifies the Santa Ana River, Kizh village settlements, including Pasbengna and Hotuukgna. The email provides general references to habitation sites, lithic scatters, shell middens, and bedrock mortars throughout the Orange area. The City responded in a letter sent on November 3, 2025 detailing the history of ground disturbance and existence of artificial fill on the Project site and stating that although the site is within tribal ancestral regional territory, evidence that the area has the potential to contain tribal cultural resources was not identified. The letter further stated that impacts related to tribal cultural resources are anticipated to be less than significant; however, due to requests by consulting tribes to monitor ground disturbing activities, the mitigation measures provided by the tribe, as modified by the City, requiring tribal monitoring are being included in the CEQA document for the Project. The tribe responded on November 10, 2025 asserting that the site is within their ancestral territory and provided recommended revisions to the mitigation measures that were sent by the City in the November 3, 2025 letter. The City responded in a letter on November 17, 2025 stating that the City agrees with the requested revisions to the mitigation measures proposed by Kizh Nation and they will be included in the CEQA document for the Project. The letter also stated that the City considers that a mutual agreement has been reached and that consultation is concluded. • The Juaneno Band of Mission Indians-Acjachemen Nation – Banda submitted a request to consult on August 27, 2025. The City and the tribe had a consultation call in which the tribe stated that the site is in their ancestral territory and requested tribal monitoring. The City emailed a follow up on October 9, 2025 asking if the tribe is willing to have another tribe monitor the site. The tribe responded in email on the same day stating that they request their monitor be on the site. The City responded in a letter on November 3, 2025 detailing the history of ground disturbance and existence of artificial fill on the Project site and stating that although the site is within tribal ancestral regional territory, evidence that the area has the potential to contain tribal cultural resources was not identified. The letter further stated that impacts related to tribal cultural resources are anticipated to be less than significant; however, due to requests by consulting tribes 494
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to monitor ground disturbing activities, mitigation measures requiring tribal monitoring are being included in the CEQA document for the Project. The City sent a follow up letter to the tribe on November 17, 2025 describing that the previous mitigation measures that were provided to the tribe in the City’s November 3, 2025 letter have been modified, and that mitigation requiring monitoring would be implemented and the City considers the consultation closed. The tribe responded to the City on November 18, 2025 agreeing to the mitigation measures and concluding the consultation.
• The Juaneno Band of Mission Indians Acjachemen Nation - Belardes submitted a request to consult on September 24, 2025. The Juaneno Band of Mission Indians Acjachemen Nation – Belardes emailed the City on September 24, 2025 stating that the Project is located within their territory and requested the site record for the prehistoric resource (CA-ORA-646) that is located almost one mile from the Project site. The City responded on September 25, 2025 via email providing the requested site record and listing available times to consult on the Project. The City and the Tribe had a consultation call on October 7, 2025, in which the Tribe stated that the area is sensitive and requested that mitigation measures including native monitoring by representatives of the Juaneno Band of Mission Indians Acjachemen Nation – Belardes, and that an inadvertent discovery plan be put in place to minimize the potential impacts on buried cultural resources. The Tribe followed up via email on October 8, 2025 and provided recommended mitigation language. In response to the City’s request for substantial evidence that the Project site has the potential to contain the tribe’s resources, the tribe provided a 2006 resolution from the County of Orange recognizing the Juaneno Band of Mission Indians Acjachemen Nation as the Indigenous people of Orange County. The City responded in a letter on November 3, 2025 detailing the history of ground disturbance and existence of artificial fill on the Project site and stating that although the site is within tribal ancestral regional territory, evidence that the area has the potential to contain tribal cultural resources was not identified. The letter further stated that impacts related to tribal cultural resources are anticipated to be less than significant; however, due to requests by consulting tribes to monitor ground disturbing activities, the mitigation measures provided by the tribe, as modified by the City, requiring tribal monitoring are being included in the CEQA document for the Project. The City sent a follow up letter to the tribe on November 17, 2025 describing that the previous mitigation measures that were provided to the tribe in the City’s November 3, 2025 letter have been modified, and that mitigation requiring monitoring would be implemented and the City considers the consultation closed. The tribe responded to the City on November 19, 2025 agreeing to the mitigation measures and concluding the consultation.
• The Pala Band of Mission Indians responded on September 24, 2025 stating that the Tribe has consulted their maps and determined that the Project is not within the boundaries of the recognized Pala Indian Reservation and beyond the boundaries of its Traditional Use Area (TUA) and defers to tribes in closer proximity to the Project area.

The City responded to the three consulting tribes on November 17, 2025 by emailing a letter that describes the substantial history of ground disturbance on the site, the existence of onsite fill soils, and that although the site is within tribal ancestral regional territory, evidence that the Project site or surrounding area have the potential to contain tribal cultural resources was not provided. The letter further stated that although impacts related to tribal cultural resources are anticipated to be less than significant, due to requests by consulting tribes (who have detailed ancestral, lineal, and/or cultural affiliation to the Project region) to monitor ground disturbing activities, mitigation measures with 495
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protection activities that are consistent with those requested by the tribe would be included in the CEQA documentation for the proposed Project.

Impact Analysis:
a) The Project site is comprised of a fully disturbed parcel that has been used for urban uses since as early as 1928 and is currently developed with a Best Buy retail store and associated parking area that was constructed in 2007. Based on a records search of the California Historic Resources Information System and field survey, the Project site does not contain any known historic resources (Appendix C).

In addition, a Sacred Lands File search from the Native American Heritage Commission indicated negative results for the presence of sacred sites. Therefore, the proposed redevelopment of the site for residential uses would not result in impacts to resources that are listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k). No impacts would occur.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact. b) As described previously in Section 5, Cultural Resources, no archaeological resources were identified within the Project site as part of the records search with SCCIC (Appendix C) and the site has been previously disturbed various times. It is detailed through review of historic aerials photographs and record searches that the Project site has had a long history of ground disturbance. The site was used as an agricultural grove from as early as 1928 through at least 1966. By 1972 the groves were removed and the entire site and surrounding areas were developed. A commercial structure (bowling alley) with parking was developed on the site that was later demolished around 2005. Then in 2007 the existing Best Buy retail store, parking, and landscaping were developed onsite.

The geotechnical report prepared in 2005 for development of the existing Best Buy structure (SoCal Geo 2005) identified that the site contained fill soils extended to depths of 3 to 5.5 feet and recommended excavation and recompaction of a minimum of 3 feet of the onsite soils. Likewise, the Geotechnical and Infiltration Evaluation (Appendix D) prepared for the proposed Project identifies that the onsite soils consist of 3 to 5.5 feet of artificial fill. The proposed Project grading activities would remove and recompact the upper 5 feet of soil.

Due to the disturbed nature of the site from the previous agricultural uses (1928 to 1966) and the ground disturbing developments occurring in 1972 for the bowling alley and 2007 for the existing Best Buy store, presence of artificial fill, and limited excavation depths, there is a limited potential for the inadvertent discovery of tribal cultural resources. Further, the Sacred Lands File (SLF) search results for the Project were negative for any recorded Native American sacred sites or locations of religious or ceremonial importance within the Project vicinity. Thus, potential impacts related to tribal cultural resources are anticipated to be less than significant.

The information provided by consulting tribes during the AB 52 and SB 18 tribal consultation process for the Project describes that the site is within tribal ancestral regional territory; however, evidence that the Project site or surrounding area have the potential to contain tribal cultural resources was not provided. Although impacts related to tribal cultural resources are anticipated to be less than significant, 496
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due to requests by consulting tribes (who have detailed ancestral, lineal, and/or cultural affiliation to the Project region) to monitor ground disturbing activities, the Mitigation Measures TCR-1 through TCR-3 are included to address potential impacts to unknown tribal cultural resources. Mitigation Measure TCR1 requires onsite monitoring by a Native American monitor. Mitigation Measure TCR-2 requires that upon discovery of a TCR, consulting tribes would be notified and all construction activities in the immediate vicinity would cease until proper assessment and recovery of the resource has been completed. Mitigation Measure TCR-3 requires that upon discovery of Native American human remains, the procedures outlined in Public Resource Code 5097.9 and California Health and Safety Code Section 7050.5 shall be carried out. As described previously and included as PPP CUL-1, California Health and Safety Code, Section 7050.5 requires that if human remains are discovered in the project site, disturbance of the site shall halt and remain halted until the coroner has conducted an investigation. If the coroner determines that the remains are those of a Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission. Therefore, implementation of Mitigation Measures TCR-1 through TCR-3 and existing regulations potential impacts to tribal cultural resources would be less than significant.

Significance Determination: Less than significant with mitigation incorporated.

Existing Plans, Programs, or Policies
PPP CUL-1: Human Remains. California Health and Safety Code Section 7050.5. Listed previously in Section 5, Cultural Resources.

Mitigation Measures:

MM TCR-1: Native American Monitoring.

A. The Project plans, specifications, and grading permits shall state that the Project applicant shall retain a Native American Monitor. The monitor shall be retained prior to the commencement of any “ground-disturbing activity” for the subject Project at all Project locations (i.e., both on-site and any off-site locations that are included in the project description and/or required in connection with the Project, such as public improvement work). “Ground-disturbing activity” shall include, but is not limited to, demolition, pavement removal, potholing, auguring, grubbing, tree removal, boring, grading, excavation, drilling, and trenching.

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

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

MM TCR-2: Unanticipated Discovery of Tribal Cultural Resource Objects.

A. Upon discovery of any TCRs, the monitoring tribe shall notify the City and Project Applicant and all construction activities in the immediate vicinity of the discovery shall cease (i.e., not less than the surrounding 50 feet) and shall not resume until the discovered TCR has been fully assessed by the tribal monitor and/or tribal archaeologist. The monitoring tribe shall recover and retain all discovered TCRs in the form and/or manner the monitoring tribe deems appropriate.

MM TCR-3: Unanticipated Discovery of Human Remains and Associated Funerary or Ceremonial Objects.

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

B. If Native American human remains and/or grave goods are discovered or recognized on the Project site, then Public Resource Code 5097.9 as well as Health and Safety Code Section 7050.5 shall be followed.

C. Human remains and grave/burial goods shall be treated alike per California Public Resources Code section 5097.98(d)(1) and (2).

D. Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human remains and/or burial goods.

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

Significance Determination After Mitigation: Less than significant impact.

Sources
Cultural Resources Study. 2025. Prepared by BFSA Environmental Services. (Appendix C).

Geotechnical and Infiltration Evaluation. 2024. Prepared by Geotek. (Appendix D).

Geotechnical Investigation. 2005. (SoCal Geo 2005). Prepared by Southern California Geotechnical, March 29, 2005.
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19. UTILITIES/SERVICE SYSTEMS. Would the project:

Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(a) Require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunication facilities, the construction or relocation of which could cause significant environmental effects? (b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years?
(c) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
(d) Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
(e) Comply with federal, state, and local management and reduction statutes and regulations related to solid wastes?
Impact Analysis:
a) The Project would include construction and operation of 71 residences that involves water, wastewater, drainage, and electrical infrastructure, as described below.

Water
The City’s Water Division of the Public Works Department supplies potable water for residents and businesses. The Project would install new onsite water lines, which connect to the existing 12-inch diameter water main located in N. Tustin Avenue. No expansion or relocation of the existing offsite water pipelines that serve the Project site would be required.

The new onsite water system would convey water supplies to the proposed residences and landscaping through plumbing and landscaping fixtures that are compliant with the CalGreen Plumbing Code for efficient use of water, which would be verified during the development review and permitting process.

Installation of the new water distribution lines would only serve the Project and would not provide new water supplies to any offsite areas. Thus, impacts related to water utility systems would be less than significant.

Wastewater
The Orange County Sanitation District (OCSD) treats wastewater from the City. Local sewer lines are owned and maintained by the City while the District owns, operates, and maintains the large trunk sewers of the regional wastewater conveyance system. The Project includes installation of a new sewer lines on the site that would connect to the City’s existing 12-inch sewer line within E. Heim Avenue. The existing off-site sewer lines would accommodate the proposed Project and would not require expansion to serve the Project. Thus, impacts related to wastewater utility systems would be less than significant.

Stormwater
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 499
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area drain system that would route runoff to biofiltration treatment devices prior to discharge to the existing stormwater sump pump system. As discussed in Section 10, Hydrology and Water Quality, the Project would result in an increase in pervious surfaces because the Project site is currently fully developed with a Best Buy retail store building and impervious parking areas with limited landscaping.

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 a site with 13 percent pervious and 87 percent impervious area. 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 (in Section 10, Hydrology and Water Quality) details that flows from a 25-year storm event would decrease by 7.2 percent and flows from a 100-year storm would decrease by 6.8 percent. Due to the reduction in stormwater runoff, the Project would not result in an expansion of existing off-site storm water drainage facilities. Therefore, the Project would not require or result in the construction of new off-site storm water drainage facilities or expansion of existing off-site facilities. Impacts related to stormwater infrastructure would not occur.

Electric Power
The Project would connect to the existing Southern California Edison electrical distribution facilities that are adjacent to the Project site and would not require the construction of new electrical facilities.

Natural Gas
The Project would not connect to existing facilities nor require the use of natural gas.

The impacts of development of the utility infrastructure are considered part of the impacts of the Project as a whole and are analyzed throughout the various sections of this IS/MND. For example, activities such as excavation and equipment installation as required for the new residences are analyzed in the Air Quality, Greenhouse Gas Emissions, and Noise sections of this IS/MND. As detailed throughout this IS/MND, installation of onsite utility infrastructure would not result in an adverse physical effect on the environment. 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. b) The City receives imported water from the Municipal Water District of Orange County, local groundwater from the Orange County Groundwater Basin, and local surface water from the Serrano Water District. The City has prepared the 2020 Urban Water Management Plan (UWMP) in order to assess long-term water supply sources, demands, reliability, and conservation strategies. Table UT-1 shows the water supply characterization for the City, taking into account increased supply as a result of passive water savings from conservation requirements.

Table UT-1: City of Orange Projected Water Supply Projections (acre-feet) Source 2025 2030 2035 2040 2045
OC Groundwater Basin 23,148 23,913 23,928 23,910 23,865 Imported/Purchased 2,885 3,020 3,023 3,019 3,012
Surface water 1,200 1,200 1,200 1,200 1,200
Total 27,233 28,133 28,151 28,130 28,077
Source: Orange 2020 UWMP.
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Water use projections in the UWMP are estimated based on expected land use development, which is the existing 45,676 square foot Best Buy retail store. Thus, water usage of the existing building has been accounted for within the 2020 UWMP.

The UWMP identifies a regional water use target of 159 gallons per capita per day, and an actual gallons per capita per day of 109 in 2020. Based on the target of 159 gallons per capita per day, the anticipated residential population of 226 persons at full capacity would result in a water demand of 35,934 gallons of water per day or 40.25 acre-foot per year. This equates to 4.8 percent of the increase in anticipated water demand between 2025 and 2045, not including the reduction of water from removing the existing Best Buy store that is included in the estimated water demand. Overall, the proposed Project would redevelop a site with a current water demand and would not result in a substantial increase in water demand. The Water Service Reliability and Drought Risk Assessment section of the UWMP concludes that supply and demand are forecasted to be balanced through 2045, under normal years, single-dry years, and multiple-dry year scenarios. Therefore, impacts related to water supplies from the Project 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 receives wastewater treatment service from the Orange County Sanitation District (OCSD). Two wastewater treatment plants handle wastewater flow from the City of Orange:

Reclamation Plant No. 1 in Fountain Valley, which has a treatment capacity of 174 million gallons per day (gpd), with a typical daily flow of 116 million gpd (OC San, 2025) and Treatment Plant No. 2 in Huntington Beach had a typical daily flow of 68 million. The two facilities have a combined design capacity of 332 million gallons per day (mgd) (EPA 2021). The facilities treated an average daily wastewater flow of 184 mgd (OC San, 2025), leaving a remaining capacity of 148 mgd.

The Orange General Plan EIR uses a wastewater generation rate of 104 gallons per person per day. Based on this factor, and an estimated residential population of 226 persons, the Project would generate approximately 23,504 gallons per day (gpd) of wastewater or 0.0235 mgd per day. Therefore, the Project’s wastewater generation would be within the current capacity for both wastewater treatment plants and no new or expanded offsite facilities are required. Impacts related to wastewater generation 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) In 2024 the majority of solid waste from the City were disposed in the following landfills: Prima Deshecha Landfill in San Juan Capistrano, the Olinda Alpha Sanitary Landfill in Brea, and the Frank R.

Bowerman Landfill in Irvine. Information regarding these landfills is detailed on Table UT-2. As detailed, the landfills have a daily permitted capacity of between 4,000 and 11,500 tons per day, and in August 2025 had a minimum additional capacity of between 686 and 2,548 tons per day. 501
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Table UT-2: Landfill Capacity
Name Max Daily
Permitted (tpd)
Peak Daily
Tonnage (tpd)1
Available Daily
Disposal (tpd) 1
Permitted
Through
Prima Deshecha Landfill 4,000 3,314 686 12/31/2102
Olinda Alpha Sanitary Landfill 8,000 3,841 4,159 12/31/2036 Frank R. Bowerman Landfill 11,500 8,952 2,548 12/31/2053 1 August 2025
Source: CalRecycle 2025
Construction
The Project would generate solid waste from construction and demolition debris during the short-term construction period. The demolition phase of construction involves removal and crushing of asphalt and the existing building. Based on the area of paved land and the average thickness and size and type of existing building, demolition would result in approximately 6,520 tons of debris. Solid waste would be disposed of in accordance with local solid waste disposal requirements. Additionally, Section 5.408.1 of the existing CalGreen Building Standards Code requires demolition and construction activities to recycle or reuse a minimum of 65 percent of the nonhazardous construction and demolition waste. Thus, the demolition and construction solid waste that would be disposed of at the landfill would be approximately 35 percent of the waste generated, or 2,282 tons of debris. As described in the Air Quality Analysis (Appendix A), demolition is expected to take 20 days. As such, this would equate to approximately 114.1 tons of solid waste per day. The three landfills have additional capacity of between approximately 686 and 4,159 tons per day, which would meet the construction-related landfill needs.

Operation
The CalEEMod modeling for the Project (included as Appendix A) identifies that the proposed 71 residences would generate approximately 59.2 tons of solid waste per year. However, at least 75 percent of the solid waste would be required to be recycled pursuant to AB 341, which would reduce the volume of landfilled solid waste to approximately 14.8 tons per year or 0.29 tons per week.

As described above, the supporting landfill facilities have additional capacity of between approximately 686 and 4,159 tons per day. Thus, the landfills would be able to accommodate the addition of 0.29 tons of waste per week from operation of the Project. Implementation of the Project would result in less than significant impacts on landfill capacity.

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 result in new development that would generate an increased amount of solid waste.

Pursuant to Section 5.408.1 of the California Green Building Standards Code, all construction would be required to recycle or reuse a minimum of 65 percent of the nonhazardous construction and demolition waste. AB 341 requires diversion of a minimum of 75 percent of operational solid waste, which would be implemented by provision of bind for separation of green waste, recycling, and landfill materials and through the solid waste hauler and disposal services provided throughout the City. Implementation of the Project would be required to be consistent with all mandatory federal, state and City regulations related to solid waste, which would be ensured through the City’s development review and permitting process. Therefore, the proposed Project would comply with all solid waste statutes and regulations; and impacts would not occur.
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Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact.

Existing Plans, Programs, or Policies
None.

Sources:

Air Quality, Energy, and Greenhouse Gas Impact Analysis. October 2025. Prepared by EPD Solutions. (Appendix A).

CalRecycle. 2025a. SWIS Facility/Site Inspection Details – Frank R. Bowerman Sanitary LF (30-AB0360). [online]:
https://www2.calrecycle.ca.gov/SolidWaste/SiteInspection/Details/349346?siteID=2103.

October 2025.

CalRecycle. 2025b. SWIS Facility/Site Inspection Details – Olinda Alpha Landfill (30-AB-0035). [online]: https://www2.calrecycle.ca.gov/SolidWaste/SiteInspection/Details/349413. Accessed October 2025.

CalRecycle. 2025c. SWIS Facility/Site Inspection Details – Prima Deschecha Landfill (30-AB-0019). [online]: https://www2.calrecycle.ca.gov/SolidWaste/SiteInspection/Details/348618. Accessed October 2025.

City of Orange. November 2021. 2020 Urban Water Management Plan Final. [online]:
https://www.mwdoc.com/your-water/water-supply/urban-water-management-plan/. Accessed October 2025.

EPA (U.S. Environmental Protection Agency). June 2021. Joint EPA and State NPDES Permit No.

CA0110604: Orange County Sanitation District Reclamation Plant No. 1 and Treatment Plant No. 2. [online]: https://www.epa.gov/npdes-permits/ca0110604-orange-county-sanitationdistrict-reclamation-plant-no-1-treatment-plant-no. Accessed October 2025.

OC San (Orange County Sanitation District). March 2021. An OC San Virtual Tour. [online]:
https://storymaps.arcgis.com/stories/146df09c1bc64dcb8ae95babf494ae39. Accessed October 2025.

OC San (Orange County Sanitation District). Regional Sewer Service Facts and Key Statistics https://www.ocsan.gov/regional-sewerservice/#:~:text=2024%2D25%20Average%20Daily%20Flow,Total%20184%20MGD.

Accessed October 2025.
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20. WILDFIRE. If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:

Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(a) Substantially impair an adopted emergency response plan or emergency evacuation plan?
(b) Due to slope prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
(c) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
(d) Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?
Impact Analysis:
a) The Project site is not within a fire hazard zone (CAL FIRE 2025). Additionally, the Project site is not within an evacuation plan area, nor does it abut any generalized evacuation routes (Orange City Fire Department). Therefore, construction activities would not interfere with emergency response or evacuation plans to the Project vicinity.

The Project site would include a 25-foot-wide fire lane and have 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 for emergency vehicle access during Project operation. Furthermore, development plans would be reviewed by the City to ensure adequate levels of emergency service to the Project site. Therefore, potential impacts related to an emergency response or evacuation would not occur.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact. b) The Project site is currently developed and within an urbanized area of the City of Orange. The Project site is not adjacent to any wildland areas, and as determined by the CAL FIRE Hazard Severity Zone map, is not within a fire hazard zone. In addition, implementation of the Project would be required to adhere to the California Fire Code, as adopted by the Orange Municipal Code, and would be reviewed by the City’s Building and Safety Services during the permitting process to ensure that the Project plans meet the fire protection requirements. The Project site does not include any slopes or prevailing winds that would exacerbate fire risks. Thus, no impacts related to other factors that would expose Project occupants to pollutant concentrations from a wildfire would occur from the Project.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact. 504
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c) As described previously, the Project site is developed and within an urbanized area that is not within a wildfire hazard zone. The Project does not include any associated infrastructure that would exacerbate fire risks. Therefore, impacts related to infrastructure that could exacerbate fire risks would not occur.

Significance Determination: No impact.

Mitigation Measures: No mitigation measures are required.

Significance Determination After Mitigation: No impact. d) As described previously, the Project site is developed and within an urban area that is not within a wildfire hazard zone. In addition, the Project site is flat and surrounded by flat areas. There are no slope or hillsides that would become unstable as a result of the Project. Therefore, impacts related to flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes would not occur from 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
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.

Orange City Fire Department. Evacuation Information: https://orangecityfire.org/evacuation-info.

Accessed May 2025.
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21. MANDATORY FINDINGS OF SIGNIFICANCE. Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
(a) Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below selfsustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory?
(b) Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects?) (c) Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly?
Impact Analysis:
a) As described in Section 4, Biological Resources, the Project site is located within an urban area and is fully disturbed and developed. The parcel contains a 45,676 square foot retail store building, surface parking lot, and non-native ornamental landscaping. The site is surrounded on three sides by cmu walls, and the surrounding area contains residential, freeway signage, 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 the site. Likewise, the site contains no wetlands, riparian areas, or water bodies. Due to the existing developed urban nature of the site and surrounding area, the proposed residential development would not reduce habitat for wildlife species or threaten to eliminate or restrict range of a plant or animal community. However, the Project site contains ornamental trees that may be utilized by nesting birds and raptors. Therefore, Mitigation Measure BIO1 has been included to conduct pre-construction surveys if vegetation is required to be removed during nesting bird season. With implementation of MM BIO-1, potential impacts related to nesting birds would be reduced to a less than significant level.

As described in Section 5, Cultural Resources, the Project site does not contain any buildings or structures that meet any of the California Register of Historical Resources (California Register) criteria or qualify as “historical resources” as defined by CEQA. 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. In addition, 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 that could be important examples of the major periods of California history or prehistory. Thus, impacts would be less than significant.

However, as described in Section 18, Tribal Cultural Resources, although impacts related to tribal cultural resources are anticipated to be less than significant, due to requests by consulting tribes (who have detailed ancestral, lineal, and/or cultural affiliation to the Project region) to monitor ground 506
155
disturbing activities, Mitigation Measure TCR-1 through TCR-3 have been included to ensure that any inadvertent discovery of potential tribal cultural resources during ground-disturbing activities would be less than significant.

Significance Determination: Less than significant with mitigation incorporated.

Mitigation Measures: MM BIO-1 and MM TCR-1 through TCR-3, as listed previously.

Significance Determination After Mitigation: Less than significant impact. b) Cumulative impacts are defined as two or more individual effects that, when considered together, are considerable or that compound or increase other environmental impacts. The cumulative impact from several projects is the change in the environment that results from the incremental impact of the development when added to the impacts of other closely related past, present, and reasonably foreseeable or probable future developments. Cumulative impacts can result from individually minor, but collectively significant, developments taking place over a period. CEQA Guidelines Section 15130 (a) and (b), states:
(a) Cumulative impacts shall be discussed when the project’s incremental effect is cumulatively considerable.
(b) The discussion of cumulative impacts shall reflect the severity of the impacts and their likelihood of occurrence, but the discussion need not provide as great detail as is provided of the effects attributable to the project. The discussion should be guided by the standards of practicality and reasonableness.

The Project site is currently developed with a warehouse and office building. The Project would redevelop the site with a vacant 45,676 square foot Best Buy retail store building, surface parking lot, and non-native ornamental landscaping. As previously described, the proposed Project would result in 1,364 fewer daily vehicle trips than the previously operating Best Buy retails store, and the 511 daily trips, including 34 AM peak hour and 40 PM peak hour trips generated by the Project less than the City’s threshold to require roadway analysis, which is 100 peak hour trips, 1,600 daily trips, or 51 peak hour trips. Likewise, the Project would result in a less than significant impact related to VMT. Due to the Project’s limited vehicle trips within a mixed use area containing, transit and pedestrian facilities.

Cumulative impacts related to traffic would be less than significant.

As discussed in Section 3, Air Quality, SCAQMD’s CEQA Air Quality Handbook methodology describes that any projects that result in daily emissions that exceed any of these thresholds would have both an individually (project-level) and cumulatively significant air quality impact. If estimated emissions are less than the thresholds, impacts would be considered less than significant. As shown in Table AQ-2, CalEEMod results indicate that construction emissions generated by the Project would not exceed SCAQMD regional thresholds. Operational emissions associated with the Project were modeled using CalEEMod and are presented in Tables AQ-3 and AQ-4. As shown, the Project would result in long-term regional emissions of the criteria pollutants that would be below the SCAQMD’s applicable thresholds. Therefore, the Project would not result in a cumulatively considerable net increase of any criteria pollutant impacts, and operational impacts would be less than significant.

As discussed in Section 8, Greenhouse Gas Emissions, global climate change occurs as the result of global emissions of GHGs. An individual development project does not have the potential to result in direct and significant global climate change effects in the absence of cumulative sources of GHGs. The Project’s total annual GHG emissions at buildout would not exceed the City’s adopted GHG emissions 507
156
threshold of 3,000 MTCO2e per year. As shown on Table GHG-2, the Project would result in approximately 896 MTCO2e per year. Therefore, the Project would not result in cumulative impacts related to GHG emissions.

As detailed previously, the potential impacts related to implementation of the Project would be less than significant or reduced to a less than significant level with implementation of mitigation measures. The cumulative effect of the Project taken into consideration with other development projects in the area would be limited. As detailed in Section 10, Hydrology and Water Quality, the Project would increase pervious surfaces and the proposed area drain system would route runoff to biofiltration treatment devices prior to discharge to the existing stormwater sump pump system, improving the site over the existing condition; and thus, cumulatively related impacts would not occur.

Also, as detailed in Section 14, Population and Housing, the proposed residences 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 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. Therefore, this increase in population and related demand to public services, recreation, and utilities would be less than cumulatively considerable.

Overall, impacts to environmental resources or issue areas would not be cumulatively considerable; and cumulative 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 Project proposes redevelopment of the site with 71 new residences, open space, parking, and related amenities. As described previously, the Project site is within an urban area and surrounded by consistent land uses that include residential, commercial, and roadways. The Project would result in new residences on the site that would not involve any activities that would result in a substantial negative affect on persons in the vicinity. All resource topics associated with human beings and the Project have been analyzed in accordance with CEQA and the CEQA Guidelines and were found to pose no impacts or less-than-significant impacts with implementation of existing plans, programs, or policies, or mitigation measures. Upon implementation of mitigation measures, including Mitigation Measure NOI1 to reduce construction vibration at adjacent residences to below thresholds, the Project would not have the potential to result in substantial adverse impacts on human beings either directly or indirectly.

Significance Determination: Less than significant with mitigation incorporated.

Mitigation Measures: MM NOI-1, as listed previously.

Significance Determination After Mitigation: Less than significant impact.

Existing Plans, Programs, or Policies
As listed in previous responses.
508
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REFERENCES
Air Quality, Energy, and Greenhouse Gas Impact Analysis. October 2025. Prepared by EPD Solutions. (Appendix A).

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.

California Department of Conservation 2025. Important Farmland Finder. [online]:
https://maps.conservation.ca.gov/DLRP/CIFF/. Accessed April 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 Finance Population and Housing Estimates for Cities, Counties, and the State — January 1, 2024 and 2025; May 2025: https://dof.ca.gov/forecasting/demographics/estimatese1/ California Department of Toxic Substances Control EnviroStor Database [online]:
https://www.envirostor.dtsc.ca.gov/public/. Accessed May 2025.

CalRecycle. 2025a. SWIS Facility/Site Inspection Details – Frank R. Bowerman Sanitary LF (30-AB0360). [online]:
https://www2.calrecycle.ca.gov/SolidWaste/SiteInspection/Details/349346?siteID=2103.

Accessed October 2025.

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.

City of Orange 2025-2026 Annual Budget & 5 Year Capital Improvement Plan. Accessed September 2025:
https://www.cityoforange.org/home/showpublisheddocument/6362/638936996141570000 City of Orange Municipal Code. 2025. [online]:
https://library.qcode.us/lib/orange_ca/pub/municipal_code/item/title_12- chapter_12_28?view=all#title_12-chapter_12_28-12_28_020. Accessed May 2025. 509
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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 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.

City of Orange. Master Street Tree Plan. [online]:
https://www.cityoforange.org/home/showpublisheddocument/336/637699043683430000.

Accessed May 2025.

City of Orange. November 2021. 2020 Urban Water Management Plan Final. [online]:
https://www.mwdoc.com/your-water/water-supply/urban-water-management-plan/. Accessed October 2025.

City of Orange Park Locations Mapping. Accessed October 2025: https://www.cityoforange.org/ourcity/departments/community-services/parks-and-permits/park-locations City of Orange Police Department 2024 Annual Report. Accessed September 2025:
https://www.cityoforange.org/home/showdocument?id=4318&t=638163205533964554 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 Cultural Resources Study. 2025. Prepared by BFSA Environmental Services. (Appendix C).

EPA (U.S. Environmental Protection Agency). June 2021. Joint EPA and State NPDES Permit No.

Geotechnical and Infiltration Evaluation. 2024. Prepared by Geotek. (Appendix D).

Geotechnical Investigation. 2005. (SoCal Geo 2005). Prepared by Southern California Geotechnical, March 29, 2005.

Level of Service (LOS) Screening Analysis. 2025. Prepared by EPD Solutions, Inc. (Appendix J).

Noise and Vibration Impact Analysis. 2025. Prepared by Urban Crossroads. (Appendix I).

OCSAN (Orange County Sanitation District). March 2021. An OC San Virtual Tour. [online]:
https://storymaps.arcgis.com/stories/146df09c1bc64dcb8ae95babf494ae39. Accessed 2025. 510
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OC San (Orange County Sanitation District). Regional Sewer Service Facts and Key Statistics https://www.ocsan.gov/regional-sewerservice/#:~:text=2024%2D25%20Average%20Daily%20Flow,Total%20184%20MGD.

Accessed October 2025.

Orange Unified School District School Locator and Maps. Accessed October 2025:
https://www.orangeusd.org/our-schools/school-locator-maps Orange Unified School District Residential Commercial/Industrial Development School Fee Justification Study, March 26, 2025. Accessed October 2025:
https://www.orangeusd.org/departments/facilities-planning/developer-fees Paleontological Assessment. 2025. Prepared by BFSA Environmental Services Company. (Appendix E).

Phase I Environmental Site Assessment Report. 2024. Prepared by EDI Consultants, Inc. (Appendix F).

Preliminary Hydrology Report. 2025. Prepared by C&V Consulting, Inc. (Appendix G).

Preliminary Water Quality Management Plan (WQMP). 2025. Prepared by C&V Consulting, Inc. (Appendix H).

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-housing-estimatesfor-cities-counties-and-the-state-2020-2025/ Tree Survey and Arborist Report. June 2025. Prepared by CalPacific Sciences. (Appendix B) USFWS (United States Fish and Wildlife Service). 2022. National Wetlands Inventory. [online]:
https://fwsprimary.wim.usgs.gov/wetlands/apps/wetlands-mapper/. Accessed May 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 May 2025.

Vehicle Miles Traveled (VMT) Screening Analysis. 2026. Prepared by EPD Solutions, Inc. (Appendix K).
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North Tustin Street Residential Project
Response to Comments on the Public Review IS/MND MND NO. ENV25-0001 City of Orange 2-1
Final IS/MND
March 2026
CHAPTER 2

RESPONSE TO COMMENTS ON THE PUBLIC REVIEW
IS/MND
This chapter of the Final Initial Study/Mitigated Negative Declaration (IS/MND) contains responses to the comments that the City of Orange (Lead Agency) received during public review of the Initial Study/Mitigated Negative Declaration (IS/MND) (SCH No. 2026020142) for the North Tustin Street Residential Project during the public review period, which began February 5, 2026, and closed February 25, 2026. This document has been prepared in accordance with the California Environmental Quality Act (CEQA) as amended (Public Resources Code Section 21000 et seq.) and the Guidelines for Implementation of the California Environmental Quality Act (State CEQA Guidelines) (Cal. Code Regs., tit. 14, § 15000 et seq.) and represents the independent judgment of the Lead Agency. This document, together with the IS/MND and the Mitigation Monitoring and Reporting Program (MMRP) comprise the Final MND. The following public comments were submitted to the City of Orange during the public review period:

1. California Department of Transportation (Caltrans), received February 25, 2026 (5 pages)

2. Pala Band of Mission Indians, received February 6, 2026 (1 page)

3. Francine Lopez, received February 18, 2026 (1 page)

4. Leslie Manderscheid, received February 23, 2026 (1 page)

5. Adrienne J. Gladson, AICP, received February 23, 2026 (3 pages)

6. Lisa Ackerman Baldwin, received February 24, 2026 (1 page)

7. Coco Palms HOA Board of Directors, received February 25, 2026 (1 page)

8. Doug Hamilton, received February 25, 2026 (1 page)
The public comments and responses to comments are included in the public record and are available to the Lead Agency decision-makers for their review and consideration prior to making their decision whether to approve the proposed Project. Pursuant to State CEQA Guidelines Section 15074(b), Consideration and Adoption of a Negative Declaration or Mitigated Negative Declaration, none of the comments provide substantial evidence that the Project will have significant environmental effects which would require preparation of an Environmental Impact Report. Further, none of the information in the letters or responses constitute the type of significant new information that requires recirculation of the North Tustin Street Residential Project IS/MND for further public review under State CEQA Guidelines Section 15073.5, Recirculation of a Negative Declaration Prior to Adoption. None of this new material indicates that the Project would result in a significant new environmental impact not previously disclosed in the IS/MND.

Additionally, none of this information indicates that there would be a substantial increase in the severity of a previously identified environmental impact that will not be mitigated, or that there would be any of the other circumstances requiring recirculation described in State CEQA Guidelines Section 15073.5.

Although State CEQA Guidelines Section 15088 does not require a Lead Agency to prepare written responses to comments received on a Draft IS/MND, the City of Orange has elected to prepare the following written responses with the intent of providing a comprehensive and meaningful evaluation of the proposed Project. The number designations in the responses are correlated to the bracketed and identified portions of each comment letter. 513
North Tustin Street Residential Project
Response to Comments on the Public Review IS/MND MND NO. ENV25-0001 City of Orange 2-2
Final IS/MND
March 2026
Letter 1: Caltrans District 12, Received February 25, 2026 (1 of 5 pages) 514
North Tustin Street Residential Project
Response to Comments on the Public Review IS/MND MND NO. ENV25-0001 City of Orange 2-3
Final IS/MND
March 2026
Letter 1: Caltrans District 12, Received February 25, 2026 (2 of 5 pages) 515
North Tustin Street Residential Project
Response to Comments on the Public Review IS/MND MND NO. ENV25-0001 City of Orange 2-4
Final IS/MND
March 2026
Letter 1: Caltrans District 12, Received February 25, 2026 (3 of 5 pages) 516
North Tustin Street Residential Project
Response to Comments on the Public Review IS/MND MND NO. ENV25-0001 City of Orange 2-5
Final IS/MND
March 2026
Letter 1: Caltrans District 12, Received February 25, 2026 (4 of 5 pages) 517
North Tustin Street Residential Project
Response to Comments on the Public Review IS/MND MND NO. ENV25-0001 City of Orange 2-6
Final IS/MND
March 2026
Letter 1: Caltrans District 12, Received February 25, 2026 (5 of 5 pages) 518
North Tustin Street Residential Project
Response to Comments on the Public Review IS/MND MND NO. ENV25-0001 City of Orange 2-7
Final IS/MND
March 2026
RESPONSE TO COMMENT LETTER 1: Caltrans District 12
Comment 1-1: This comment provides an introduction and summary of the proposed Project and its location and states that regional access to the Project site is provided by State Route (SR) 55.

The comment states that Caltrans recognizes there is a strong link between transportation and land use. Development can have a significant impact on traffic and congestion on State transportation facilities. In particular, the pattern of land use can affect both local vehicle miles traveled (VMT) and the number of trips. Caltrans supports collaboration with local agencies to work towards a safe, functional, interconnected, multi-modal transportation network integrated through applicable “smart growth” type land use planning and policies.

Response to Comment 1-1: The comment is introductory and informational in nature and does not contain any comments related to the IS/MND or information requiring changes to the IS/MND.

The IS/MND describes the number of vehicle trips that would be generated by the Project on page 132, which would reduce trips compared to the previous commercial retail use, and would result in a less than significant impact related to VMT, as detailed on page 136 of the IS/MND. The Project would benefit from being located adjacent to an existing functional, interconnected, and multi-modal transportation network. As detailed on page 133 of the IS/MND, OCTA bus routes currently operate along N. Tustin Street and sidewalks are currently located on both sides of N.

Tustin Street. The Project would install onsite bicycle parking and sidewalks that would connect to existing offsite pedestrian facilities; and thus, is consistent with the comment. Further, the Project provides for “smart growth” by implementing redevelopment of a currently underutilized site that is adjacent to existing residential within a mixed-use commercial corridor.

Comment 1-2: This comment states that Caltrans supports local developments that are consistent with State planning priorities intended to promote equity, strengthen the economy, protect the environment, and promote public and health safety. This can be achieved by promoting smart growth principles in projects which provide a diversity of housing choices and destinations accessible by active transportation (i.e. bicycle and pedestrian) and transit users. The comment also states that Caltrans supports the City’s progress in meeting its Regional Housing Needs Assessment (RHNA) allocation and encourages the City to promote the development of housing units for a variety of income levels.

Response to Comment 1-2: The comment is informational in nature and does not contain any comments related to the IS/MND evaluation or information requiring changes to the IS/MND. As described in the previous response, the Project is consistent with smart growth principles by implementing redevelopment of a currently underutilized site that is adjacent to existing residential within a mixed-use commercial corridor that would result in less than significant VMT impacts and is accessible/adjacent to pedestrian infrastructure and transit services. In addition, the IS/MND details in Section 14, Population and Housing, that the Project would provide an additional diversity of housing choices, as single-family attached residences consist of 10.9 percent of the City’s housing units and residences within buildings containing between 2 and 4 units consist of

10.1 percent of the City’s housing units. Also, the residences provided by the Project would equate to 3.1 percent of the City’s moderate and above moderate income household Regional Housing Needs Allocation (RHNA) allocations.
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Final IS/MND
March 2026
Comment 1-3: This comment states that Caltrans promotes the design of Complete Streets that include high-quality pedestrian, bicycle, and transit facilities that are safe and comfortable for users of all ages and abilities. Improvements may include providing secure bicycle parking, pedestrianoriented LED lighting, wayfinding signage, and comfortable connections to nearby active transportation and/or transit facilities. Complete Streets improvements also promote regional connectivity, improve air quality, reduce congestion, promote improved first-/last-mile connections, and increase safety for all modes of transportation. Continue to incorporate Complete Streets in project development.

Response to Comment 1-3: The comment is informational in nature and does not contain any comments related to the IS/MND evaluation or information requiring changes to the IS/MND. The Project does not include any roadway improvements. As detailed on page 16 of the IS/MND, the Project would be accessed from a 29-foot-wide driveway along the west side of the site at an existing driveway location. However, as detailed previously the Project would install onsite pedestrian facilities that would connect to the offsite sidewalks, and the Project site is currently served by transit. Further, the Project includes installation of bicycle parking and pedestrianoriented LED lighting on the site. Thus, the Project is consistent with the principles described by the comment.

Comment 1-4: This comment states that the Project is located near several bike lanes, including but not limited to the Class II bike lane on Meats Ave south of the Project location, and to consider referencing existing bike lanes and states that most existing or planned bicycle facilities in Orange County are included on OCTA’s Orange County Bikeways Map (online link:
https://www.octa.net/getting-around/active/oc-bike/bikeways-planning/overview).

Response to Comment 1-4: The IS/MND describes on page 133 that there is no existing bicycle lane located on N. Tustin Street. The closest bike lane to the Project site is the Class II bike lane on Meats Avenue (referenced by the comment) that is 0.4-mile south of the Project site, and travels to the east across SR 55. The OCTA Orange County Bikeways Map referred to by the comment does not identify any additional existing or planned bike lanes in the vicinity of the Project site.

The comment does not contain any comments related to the IS/MND evaluation of Project impacts.

Comment 1-5: This comment states that the Project is located near several existing and planned bicycle facilities. With these features in mind, Caltrans supports the inclusion of secure and functional short-term bike parking. Short-term bike parking at public locations should be placed in visible areas that are close to main destinations and should be installed at least 24 inches away from walls and other objects (e.g. trash cans, plants, etc.). The comment also provides guidance on bicycle parking best practices and refers to the “Essentials of Bike Parking” guidance created by the Association of Pedestrian and Bicycle Professionals (link to online PDF:
https://www.apbp.org/Publications).

Response to Comment 1-5: The comment is informational in nature and does not contain any comments related to the IS/MND evaluation or information requiring changes to the IS/MND. As described in the previous response, there is no existing bicycle lane located on N. Tustin Street.

The closest bike lane to the Project site is the Class II bike lane on Meats Avenue that is 0.4-mile 520
North Tustin Street Residential Project
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Final IS/MND
March 2026
south of the Project site, and travels to the east across SR 55. The Project includes installation of bicycle racks near the Project site entrance and open space area, as shown on Figure 18, Conceptual Landscape Plan. Thus, the Project is consistent with the comment that short-term bike parking should be provided in public locations of the site.

Comment 1-6: This comment states that any work performed within Caltrans right-of-way will require discretionary review and approval by Caltrans and an encroachment permit will be required for any work within the Caltrans right-of-way prior to construction. The comment provides direction as to how to request review by Caltrans for construction in a state roadway right-of-way, and the requisite plans that are required to be submitted.

Response to Comment 1-6: The comment is informational in nature and does not contain any comments related to the IS/MND evaluation or information requiring changes to the IS/MND. The Project does not include any roadway improvements; and would not encroach into a Caltrans rightof-way. Thus, no encroachment permit or discretionary review by Caltrans would be required. As detailed on page 16 of the IS/MND, the Project would be accessed from a 29-foot-wide driveway along the west side of the site at an existing driveway location, and no work within a Caltrans right-of-way would occur.

Comment 1-7: This comment states that Caltrans’ mission is to improve lives and communities through transportation. Please continue to coordinate with Caltrans for any future developments that could potentially impact State transportation facilities.

Response to Comment 1-7: The comment is conclusionary in nature and does not contain any comments related to the IS/MND evaluation or information requiring changes to the IS/MND. The City of Orange will continue to coordinate with Caltrans regarding future proposed Projects near State transportation facilities.
521
North Tustin Street Residential Project
Response to Comments on the Public Review IS/MND MND NO. ENV25-0001 City of Orange 2-10
Final IS/MND
March 2026
Letter 2: Pala Band of Mission Indians, Received February 6, 2026 (1 page) 522
North Tustin Street Residential Project
Response to Comments on the Public Review IS/MND MND NO. ENV25-0001 City of Orange 2-11
Final IS/MND
March 2026
RESPONSE TO COMMENT LETTER 2: Pala Band of Mission Indians Comment 2-1: This comment states that the Pala Band of Mission Indians Tribal Historic Preservation Office has received the notification of the Project and have consulted maps and determined that the Project is not within the boundaries of the recognized Pala Indian Reservation, and beyond the boundaries of the territory that the tribe considers its Traditional Use Area (TUA).

It is, however, situated in close proximity to the Reservation and information generated would likely be useful in better understanding regional culture and history. Therefore, the Tribe requests to be kept in the information loop as the Project progresses and defers to Tribes who are in closer proximity to the Project area.

Response to Comment 2-1: The comment is introductory and informational in nature and does not contain any comments related to the IS/MND or information requiring changes to the IS/MND.

The Tribe will be kept on the notification list for the Project. Thus, no further response is warranted. 523
North Tustin Street Residential Project
Response to Comments on the Public Review IS/MND MND NO. ENV25-0001 City of Orange 2-12
Final IS/MND
March 2026
Letter 3: Francine Lopez, Received February 18, 2026 (1 page) 524
North Tustin Street Residential Project
Response to Comments on the Public Review IS/MND MND NO. ENV25-0001 City of Orange 2-13
Final IS/MND
March 2026
RESPONSE TO COMMENT LETTER 3: Francine Lopez
Comment 3-1: This comment states that the commenter disagrees with the Project to build multifamily units and would deeply despise having 71 additional units in this area. The comment states that there is lots of traffic, collisions, unhoused individuals, and car thefts and break-ins in our community and that adding more people and cars coming in and out of this area will increase crowding and congestion in this area. The comment states that local stores are already barely stocked, since there are already many multi-family communities in this surrounding area. The comment states that the Project would not be helpful to the community and that more shopping stores and restaurants if anything is needed; and a Costco would be a more acceptable idea for the property or entertainment venue.

Response to Comment 3-1: The comment asserts disagreement with the Project and does not raise a specific issue with the adequacy of the IS/MND evaluation. As detailed on page 132 of the IS/MND the proposed Project is expected to generate a total of 511 daily trips, including 34 AM peak hour and 40 PM peak hour trips. This is less than the City’s threshold to require roadway analysis due to potential roadway effects, which is 100 peak hour trips or 1,600 daily trips.

In addition, operation of the currently vacant Best Buy store is estimated to have previously generated 1,875 daily trips, 16 AM peak hour trips, and 194 PM peak hour trips. Thus, in comparison to the previous retail commercial operation, the proposed Project would result in a reduction of 1,364 daily vehicle trips, including a reduction of 154 PM peak hour trips. Thus, in comparison to the previous uses on the Project site the proposed Project would result in a reduction in traffic and related people coming in and out of the area.

Regarding the potential for collisions, page 139 of the IS/MND describes that the Project would be accessed from N. Tustin Street through a 29-foot wide accessway along the west side of the site and that each of the proposed residences would be accessed from the 25-foot-wide driveway that would circle the site and have 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. Pedestrian circulation would be provided by an onsite sidewalk that would connect the proposed residential areas to the existing sidewalk along N. Tustin Street. The Project would not increase any hazards. The City’s construction permitting process includes review of Project plans to ensure that no potentially hazardous transportation design features would be introduced by the Project.

Regarding the potential for unhoused individuals, car thefts, and break-ins in the community, the IS/MND describes on page 126 that design measures which employ defensible security concepts would be utilized in Project development and construction plans. These measures incorporate the concepts of Crime Prevention Through Environmental Design (CPTED), which involve the placement, and orientation of structures, access and visibility of common areas, placement of doors, windows, addressing, lighting and landscaping. CPTED promotes public safety, physical security, and allows residents the ability to monitor activity. In addition, the Project would comply with the requirements established in Chapter 15.52 of the Municipal Code (Building Security Ordinance #6-22). Conditions related to CPTED and the City of Orange Building Security Standards would be included in the Project. Further, operation of the Project includes a homeowners association that would maintain the security measures implemented as part of the Project. These measures would reduce the potential for security risks related to unhoused individuals, car thefts, and break-ins.
525
North Tustin Street Residential Project
Response to Comments on the Public Review IS/MND MND NO. ENV25-0001 City of Orange 2-14
Final IS/MND
March 2026
The commentor’s preference in land use on the site is not related to a potential environmental impact; however, it should be noted that the Project site is located within a mixed-use corridor along N. Tustin Street, which includes a wide variety of retail and restaurant uses. Therefore, no further response is required or provided.

Comment 3-2: This comment states that the community doesn’t need more pollution and congestion and that many of our neighbors have health issues due to living near the highway and would like the commenter’s opinion to be considered.

Response to Comment 3-2: As described in the previous response, the Project would generate a limited number of vehicle trips that include 511 daily trips, including 34 AM peak hour and 40 PM peak hour trips. This is less than the City’s threshold to require roadway analysis related to congestion, which is 100 peak hour trips or 1,600 daily trips to identify a potential roadway effect.

Thus, the Project would not result in a traffic congestion effect. In addition, in comparison to the previous retail commercial operation, the proposed Project would result in a reduction of 1,364 daily vehicle trips, including a reduction of 154 PM peak hour trips. Thus, in comparison to the previous uses on the Project site the proposed Project would result in a reduction in traffic and related emissions. Conversely, a new retail commercial or entertainment use that would build out the site under the existing General Commercial (GC) land use designation that allows a maximum Floor Area Ratio (FAR) of 1.0 would generate increased traffic and vehicular emissions compared to the proposed Project.

As detailed in, Section 3, Air Quality, of the IS/MND, the emissions generated from the Project would not exceed SCAQMD thresholds related to both Project level and cumulative impacts, including adjacent freeway traffic emissions. The IS/MND pages 55 through 58 detail that the Project would not generate air quality emissions above SCAQMD significance thresholds during construction or operations. Thus, air quality emissions impacts would be less than significant. The comment does not raise a specific issue with the adequacy of the IS/MND evaluation or raise any other CEQA issue, and no further response is required or provided. 526
North Tustin Street Residential Project
Response to Comments on the Public Review IS/MND MND NO. ENV25-0001 City of Orange 2-15
Final IS/MND
March 2026
Letter 4: Leslie Manderscheid, Received February 23, 2026 (1 page) 527
North Tustin Street Residential Project
Response to Comments on the Public Review IS/MND MND NO. ENV25-0001 City of Orange 2-16
Final IS/MND
March 2026
RESPONSE TO COMMENT LETTER 4: Leslie Manderscheid
Comment 4-1: This comment states that the commenter found a number of errors in the narratives and inadequate documentation for the CEQA analyses, and states that the Project Description does not indicate the purpose and need of the Project. This should be included in the narrative.

Response to Comment 4-1: As substantiated by the responses below, the CEQA documentation for the Project does not contain errors in the narratives or inadequate CEQA analysis that would result in an increase in potential impacts. The first two paragraphs of the Project Description on page 15 of the IS/MND provide a detailed description of the purpose of the Project, which includes demolishing the existing vacant retail commercial structure and improvements on the Project site and constructing 71 paired and detached residences, open space/recreation, and parking. It further details that the Project includes a General Plan Amendment, a Zone Change, a Vesting Tentative Tract Map, and Administrative Design Review.

Under CEQA a project description is not required to identify a project “need”. For evaluation of potential environmental impacts, CEQA Guidelines Section 15124 states that a project description must contain: (1) the project’s precise location and boundaries; (2) a statement of the project’s objectives and underlying purpose; (3) a general description of the project’s technical, economic, and environmental characteristics; and (4) a statement briefly describing the intended uses (Tiburon Open Space Committee v. County of Marin (2022) 78 Cal.App.5th 700, 724, fn. 16, 738, and CEQA Guidelines, § 15124(a)-(d).). Pursuant to CEQA Guidelines Section 15124, the Project Description “should not supply extensive detail beyond that needed for the evaluation and review of the environmental impact.” The details of the proposed Project are identified by the Project Applicant’s application for the Project, which are detailed in the Public Review Draft IS/MND.

Therefore, the Public Review Draft IS/MND accurately represents the whole of the action and evaluates the potential environmental impacts pursuant to CEQA. Section 3.0, Project Description, of the Public Review Draft IS/MND provides a sufficient description of the Project pursuant to the requested entitlements to meet CEQA’s informational requirements under CEQA Guidelines Section 15124. The comment does not contain any information requiring changes to the IS/MND.

Comment 4-2: This comment states that Figures 8 and 16 (pages 23 & 39) appear to have inconsistent south side boundaries along the site entrance at Tustin Street as compared to Figures 17 (Wall Plan) and 18 (Conceptual Landscaping Plan) (pages 41 & 43).

Response to Comment 4-2: The conceptual plan figures in the IS/MND are not inconsistent; they identify different attributes. Figure 8, Conceptual Site Plan, and Figure 16, Open Space Plan, identify the property line as indicated in the site plan keynotes on Figure 8. Figure 17, Wall Plan, and Figure 18, Conceptual Landscaping Plan, show the limit of work, as indicated on the figures; and Figure 18 also depicts the property line in keynote 16. No changes to the IS/MND are required.

However, in response to the comment Figure 18, Conceptual Landscaping Plan, on page 43 of the IS/MND has been replaced with the updated Figure 18, provided herein in Chapter 3, Revisions to the Public Review IS/MND, wherein the arrow for keynote 16 has been modified to correctly point to the property line, as identified in the legend.
528
North Tustin Street Residential Project
Response to Comments on the Public Review IS/MND MND NO. ENV25-0001 City of Orange 2-17
Final IS/MND
March 2026
Comment 4-3: This comment states that Checklist of Environmental Impact Issues should be listed in the Table of Contents as beginning on page 45.

Response to Comment 4-3: The Checklist of Environmental Impact Issues is correctly listed in the Table of Contents as beginning on page 47. This sub header is listed at the top of page 47. Page 45 provides a list of the Environmental Factors Potentially Affected and is the IS/MND determination signature page. No changes to the IS/MND are required. This comment does not raise a specific issue with the adequacy of the IS/MND evaluation or raise any other CEQA issue.

Therefore, no further response is required or provided.

Comment 4-4: The comment states that the environmental impact issues analysis should include not only potential impacts caused by the construction and implementation of the Project, but also consider potential impacts of current external conditions, such as existing lighting at or near the site.

Response to Comment 4-4: The IS/MND evaluates potential impacts of the Project on current external conditions for each resource topic area. Potential impacts related to lighting at or near the site are described on pages 50 and 51 of the IS/MND and states that the Project site is located within a developed urban area, and 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. It also describes that the Project lighting 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. The Project plans include a schematic lighting plan for the Project, as part of the landscape set, which provides a photometric lighting plan that shows no exterior light spill from the Project, compliant with the City’s requirements. 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.

Comment 4-5: The comment states that the front page of the MMRP Appendix indicates an incorrect name of the MMRP, noting it as the Mitigation Monitoring Reporting “Plan” instead of “Program.”
Response to Comment 4-5: Appendix L of the IS/MND provides the Mitigation Monitoring and Reporting Program (MMRP) for the Project, which includes an introduction that refers to the MMRP as both a monitoring program and plan. In response to the comment, the sub header and second and third paragraphs have been revised as shown below and in Chapter 3, Revisions to the Public Review IS/MND, in strikeout/double underline. This comment does not raise a specific issue with the adequacy of the IS/MND evaluation or raise any other CEQA issue. Therefore, no further response is required or provided.

Mitigation Monitoring and Reporting Program Plan
The California Environmental Quality Act (CEQA) requires that when a public agency completes an environmental document which includes measures to mitigate or avoid significant environmental effects, the public agency must adopt a reporting or monitoring plan. This 529
North Tustin Street Residential Project
Response to Comments on the Public Review IS/MND MND NO. ENV25-0001 City of Orange 2-18
Final IS/MND
March 2026
requirement ensures that environmental impacts found to be potentially significant will be mitigated. The reporting or monitoring plan must be designed to ensure compliance during project implementation (Public Resources Code Section 21081.6).

In compliance with Public Resources Code Section 21081.6, the attached Mitigation Monitoring and Reporting Program (MMRP) checklist has been prepared for the North Tustin Street Residential Project. The table identifies Project Design Features (PDFs); Plans, Programs, and Policies (PPPs); and Mitigation Measures (MMs) required by the City to mitigate or avoid significant adverse impacts associated with the implementation of the Project. This Mitigation Monitoring and Reporting MMRP checklist is intended to provide verification that all applicable mitigation measures relative to significant environmental impacts are monitored and reported.

Monitoring will include: 1) verification that each mitigation measure has been implemented; 2) recordation of the actions taken to implement each mitigation measure; and 3) retention of records in the City’s North Tustin Street Residential project file.

This Mitigation Monitoring and Reporting Program (MMRP) delineates responsibilities for monitoring the Project but also allows the City flexibility and discretion in determining how best to monitor implementation. Monitoring procedures will vary according to the type of mitigation measure. Adequate monitoring consists of demonstrating that monitoring procedures took place and that mitigation measures were implemented. This includes the review of all monitoring reports, enforcement actions, and document disposition, unless otherwise noted in the Mitigation Monitoring and Reporting MMRP checklist. If an adopted mitigation measure is not being properly implemented, the designated monitoring personnel shall require corrective actions to ensure adequate implementation.

Comment 4-6: The comment states that Aesthetics (page 3) analysis should include existing/current exterior lighting.

Response to Comment 4-6: Refer to previous Response to Comment 3-4, which describes the IS/MND evaluation regarding existing exterior lighting and that a photometric lighting plan has been submitted to detail compliance with municipal code lighting regulations.

Comment 4-7: The comment states that the Hydrology and Water Quality (page 7) incorrectly indicates the applicant shall provide evidence of obtaining a “construction permit” from the State Water Resources Control Board (SWRCB). The SWRCB does not issue a construction permit. The City issues the construction permit.

Response to Comment 4-7: The Hydrology and Water Quality Section of the MMRP correctly states on page 7 that 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 SWRCB. The SWRCB Construction General Permit requires projects that disturb one or more acres of soil to obtain coverage under the General Permit for Discharges of Stormwater Associated with Construction Activity, which is done through the SWRCB permitting system. This comment does not raise a specific issue with the adequacy of the IS/MND evaluation or raise any other CEQA issue.

Therefore, no further response is required or provided. 530
North Tustin Street Residential Project
Response to Comments on the Public Review IS/MND MND NO. ENV25-0001 City of Orange 2-19
Final IS/MND
March 2026
Comment 4-8: The comment states that due to the very close proximity of State Route 55, the applicant needs to consult with Caltrans District 12 for an evaluation of potential impacts during construction from all construction and demolition vehicles.

Response to Comment 4-8: Caltrans District 12 was notified of the proposed Project and was sent the Notice of Intent (NOI) to adopt the IS/MND along with an electronic copy of the IS/MND for review. In response, Caltrans District 12 provided the letter included as Letter 1, herein.

The Project would not have an impact on the state highway network, including State Route 55, and the site is not adjacent to freeway on or exit ramps that could be impacted by the Project. Page 131 of the IS/MND details that the most trips during construction would occur from the demolition phase that is anticipated to last for 20 work days and involves approximately 81.5 haul trips that would occur throughout the day and 30 roundtrip worker trips; and the grading phase that would require of 115 haul trips that would also occur throughout the day and 30 round-trip worker trips per day for 8 days. These levels of temporary construction traffic would not exceed the City of Orange threshold for evaluation of roadways (provided on page 131) and would be less than significant on both local roadways and State Route 55. It is also substantially less than the trips generated by the previous Best Buy store, which generated 1,875 daily trips. This comment does not raise a specific issue with the adequacy of the IS/MND evaluation or raise any other CEQA issue. Therefore, no further response is required or provided.

Comment 4-9: The comment states that after revisions to impact analyses, the applicant needs to modify the IS/MND to indicate any changes to the level(s) of impact(s).

Response to Comment 4-9: As detailed in previous responses, the comments received do not contain any information related to a new or increased potential impact to the environment from implementation of the Project that would require changes to the IS/MND. Further, this comment also does not raise a specific issue with the adequacy of the IS/MND evaluation or raise any other CEQA issue. Thus, no further response is warranted.
531
North Tustin Street Residential Project
Response to Comments on the Public Review IS/MND MND NO. ENV25-0001 City of Orange 2-20
Final IS/MND
March 2026
Letter 5: Adrienne J. Gladson, AICP, Received February 23, 2026 (1 of 3 pages) 532
North Tustin Street Residential Project
Response to Comments on the Public Review IS/MND MND NO. ENV25-0001 City of Orange 2-21
Final IS/MND
March 2026
Letter 5: Adrienne J. Gladson, AICP, Received February 23, 2026 (2 of 3 pages) 533
North Tustin Street Residential Project
Response to Comments on the Public Review IS/MND MND NO. ENV25-0001 City of Orange 2-22
Final IS/MND
March 2026
Letter 5: Adrienne J. Gladson, AICP, Received February 23, 2026 (3 of 3 pages) 534
North Tustin Street Residential Project
Response to Comments on the Public Review IS/MND MND NO. ENV25-0001 City of Orange 2-23
Final IS/MND
March 2026
RESPONSE TO COMMENT LETTER 5: Adrienne J. Gladson, AICP Comment 5-1: This comment states that the IS/MND needs refinements regarding land use compatibility, aesthetics, natural resources, recreation, housing affordability, and public services; and that the IS/MND should further evaluate applicable goals and policies of the General Plan.

Response to Comment 5-1: The comment is introductory in nature and does not identify a specific issue related to the environmental analysis within the IS/MND and opines without evidence.

Further, the comment does not provide any substantial evidence nor a fair argument that the Project would result in a significant environmental impact or that changes to the IS/MND evaluation are required.

It should be noted that CEQA is an environmental protection statute; and thus, the IS/MND evaluation of Project consistency with General Plan policies is focused on the “applicable land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect” as directed by CEQA Guidelines Appendix G checklist, and included on page 96 of the IS/MND. The comment further lists topics but does not identify specific General Plan goals or policies related to those topics, or Project related conflict with any specific General Plan policies that would result in a potentially significant environmental impact pursuant to CEQA.

Comment 5-2: This comment recommends alternatives for the Project stating that they would assist with achieving greater compatibility (at least match Best Buy’s 30-foot building height) and a better transition to the one-story neighborhood adjacent to the site. The comment states that use of one-story design or first floor master bedrooms in a two-story design, complete view shed details to existing residential uses and existing billboard signage next to the 55 freeway (lights, moving copy, shadows), and line of sight diagrams would all yield better sensitivity and respect to adjacent property owners. The comment states that little detail (only conceptual, no details on species and sizes) is provided on use of mature trees and broad tree canopies to hide the units with three story massing or increasing wall heights along the perimeter or additional screening tools for these existing property owners.

Response to Comment 5-2: The comment does not raise a CEQA issue and does not raise an issue with the analysis within the IS/MND. CEQA Guidelines Appendix G provides thresholds of criteria for both aesthetics and land use, which were evaluated in the IS/MND and determined to have a less than significant impact. CEQA guidelines do not identify transitions between one- and three-story structures or between different land uses as potential impacts. Thus, no changes to the IS/MND are required.

However, as part of site design and planning of the Project, the concerns raised by the comment were evaluated. As detailed on page 2 of the IS/MND, the Project site is currently developed with one 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. Although separated by walls, the existing one large retail store and surface parking lot is currently inconsistent in character, bulk, and height, compared to the adjacent one-story residences.

The proposed residences would change the character of the site from large retail commercial to a residential neighborhood, which would be more consistent with the residential uses to the north and south of the site. The proposed residential structures would have a maximum height of 35 feet. 535
North Tustin Street Residential Project
Response to Comments on the Public Review IS/MND MND NO. ENV25-0001 City of Orange 2-24
Final IS/MND
March 2026
As detailed on page 16 of the IS/MND, the residential structures would have contemporary highly articulated exterior designs utilizing variations of architectural siding elements, articulation along building facades, and roof variations that would reduce the visual height of the building structures, as shown in IS/MND Figures 9 through 15.

Page 16 ends

would have a minimum 10-foot setback from the property line and not have roof decks. Figure 3 of the IS/MND provides an aerial view of the Project site and adjacent uses. As shown, a majority of the site area that is adjacent to the residential uses is bound by approximately 23 and 29-footwide drive aisles plus approximately 25-foot-deep garages, and guest parking in some locations.

The Project is not adjacent to private open space areas to the north, and only directly adjacent to four existing residences to the southeast. Thus, most of the proposed residences would be a minimum of 60 feet from the existing adjacent residences, with exception of five proposed residences that would be set between 14 and 23 feet from four residences to the southeast; however, backyards would be contiguous, and no new public locations would be adjacent to existing residential private spaces. The setbacks from adjacent residences are shown in IS/MND Figure 8, Conceptual Site Plan. And Figure 17, Wall Plan, shows that the existing 6-foot-high walls to the north and south of the site would remain and a new 8-foot-high wall would separate the Project site from the adjacent billboard parcel.

As part of the Project plans, views from the Project site and line of sight sections from the closest adjacent residential views were prepared, and are included as Figure 1, which shows the distance, height, adjacent walls, parking areas, and buildings; along with the line of sight from the second and third floors of the proposed residences. As detailed, views from the proposed residences would be of parking areas, walls, fences, landscaping and building sides. As shown on Figure 1, adjacent private residential areas would not be visible from the proposed second and third story areas.

In addition, the Project plans included shade and shadow exhibits, included as Figure 2, that identifies the shadows on December 21, which is the winter solstice that generates the greatest shadows, and on June 21, which is summer solstice that generates the most limited shadows. As detailed, shade and shadows generated by the Project would not encroach into adjacent residential open space or private living areas. Shade and shadow would only encroach to the north into the drive aisle, garage, and parking space area.

Page 16 ends

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. In response to this comment, additional details regarding the species of trees from the Project’s landscaping plans are provided herein as Figures 3 and 4.

Comment 5-3: This comment states that the Natural Resources Element of the General Plan provides that the City had an open space land inventory of 1.8 acres per 1,000 persons in 2010, which was a city-wide deficiency of 240 plus acres, with an interim goal of 3-acres per 1,000 persons; acquire 275 acres by 2030, and the minimum required Quimby Act goal for 5-acres per 1,000 persons (acquire 632 acres) by 2050. The comment states that the IS/MND does not adequately disclose this significant deficiency in its text or discuss the cumulative impacts of other 536
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Final IS/MND
March 2026
approved similar projects its analysis. The comment states that no mitigation solutions are considered, nor does it consider less impactful Project alternatives or land dedication. The comment asserts that this could provide a clear fair argument claim that mitigating this impact is deferred and that Environmental Impact Report (EIR) should be prepared, and at a minimum, the MND should be revisited to address this information and provide proper mitigation.

Response to Comment 5-3: The proposed Project would not result in impacts related to open space. As detailed on page 16 of the IS/MND, the proposed 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. In addition, the Project includes approximately 30,309 square feet (16.4% of the site) of landscaping.

Thus, much of the open space and recreation needs of the Project would be satisfied by the proposed onsite amenities.

Page 127 ends

City’s park objective is to provide 3 acres of parkland per 1,000 residents and the City has approximately 251 acres of parkland. At a rate of 3 acres of parkland per 1,000 residents the Project’s estimated 226 residents would require 0.678-acre (29,534 square feet) of parkland. In addition to the 6,031 square feet of open space recreation on the site, the City requires in-lieu fees for new residential projects to improve current park facilities and to acquire additional land for the construction of new parks. Therefore, the Project would result in the provision of onsite facilities and payment of in-lieu fees for acquisition and maintenance of offsite public facilities in compliance with existing development requirements. Thus, impacts would be less than significant.

It should further be noted that the City not meeting planning goals for acquisition of parkland and open space is not in itself a potential impact on the environment pursuant to CEQA. No changes to the IS/MND are required.

As substantiated by the previous and following responses, none of the conditions arise which would require preparation of an EIR pursuant to State CEQA Guidelines Sections 15064 and 15065. The petitioner challenging an MND and Project bears “the burden of proving ‘the existence of substantial evidence supporting a fair argument of significant environmental impact’” (Jensen v. City of Santa Rosa (2018) 23 Cal.App.5th 877, 886.). No substantial evidence supporting the fair argument of any new significant environmental impacts that would result from the Project or from a new mitigation measure proposed to be implemented has been brought forward in these comments.

Comment 5-4: This comment states that the MND fails to disclose this direct impact or consider the culminative impact of other projects pending or recently entitled/built in its disclosures. The MND does disclose payment of a park fee but doesn’t explain it and how it works, its history of achieving acquisition, if it actually covers the full cost of required land acquisition, park construction, operational expenses, the timing of said park land acquisition to match with unit occupancy, and the direct impact of the proposed Project over use of existing park land sites citywide on a short or long-term bases. It appears the full mitigation of the land dedication for open space will be deferred, will not happen, and a fair argument can be made this impact is significant and adverse.
537
North Tustin Street Residential Project
Response to Comments on the Public Review IS/MND MND NO. ENV25-0001 City of Orange 2-26
Final IS/MND
March 2026
Response to Comment 5-4: Refer to Response 5-3. In addition to the 6,031 square feet of open space recreation on the site, the City requires in-lieu fees for new residential projects to improve current park facilities and to acquire additional land for the construction of new parks. Thus, the Project would provide private facilities for residents and support public facilities through payment of in-lieu fees. The intent of the in-lieu fees is to achieve acquisition of public parkland through cumulative projects that would provide payment based on a nexus of proposed uses and open space and recreation demand, with larger projects providing a greater collective in-lieu fees. The cumulative provision of in-lieu fees allows the City to facilitate public areas of parkland and open space in addition to smaller areas of private recreation and open space that would be provided by individual developments.

The Project would result in approximately 226 residents at full capacity. The IS/MND describes that this limited population with provision of onsite open space and recreation and payment of inlieu fees would result in a less than significant impact. The IS/MND determined that the limited Project population would not generate an increase in use of the existing parks or recreational facilities such that substantial physical deterioration of facilities would occur or be accelerated that could cause construction of new or altered facilities. The comment does not provide substantial evidence of a fair argument that potential environmental impacts would occur. Thus, no changes to the IS/MND are required.

Comment 5-5: This comment states that the MND incorrectly discloses that the subject site is not identified as a housing opportunity site in the Housing Element. The comment states that a discussion on why this site is appropriate to add to the inventory along with what it will contribute to reaching approved goals and policies. The comment states that the IS/MND should disclose that this site would be added to the available housing site inventory, convert a fully utilized commercial property to a new housing opportunity site, brings a direct and cumulative net loss of sales tax revenue, and how it provides the housing opportunities at all incomes (low and very low is needed not above median income levels) and household types. The comment states that the units are threestory, and asserts that persons with disabilities will likely not be able to purchase or visit these homes, which is a discriminatory barrier, and that there is no option for a single story two-bedroom model that single person or small households who desire to downsize looking to purchase a smaller home. The comment states that all adopted housing policies and commitments should be discussed in the MND.

Response to Comment 5-5:As described previously, CEQA is an environmental protection statute that focuses on impacts to the environment (CEQA Guidelines Section 15358(b)). Therefore, consistent with CEQA, the IS/MND includes an analysis of the Project’s potentially significant physical impacts on the environment and does not include a discussion of the Project’s economic or social effects. However, as part of overall review of the proposed Project, an economic analysis has been prepared and reviewed by the City.

The IS/MND correctly states that the site is not identified as a housing opportunity site in the Housing Element. The Housing Element and General Plan Land Use Element do not restrict the number of parcels that can provide housing within the City. Conversely, Housing Elements are required per Government Code Section 65583.a to accommodate the City’s Regional Housing Need Allocation (RHNA) through eight-year planning periods. The Housing Element is required 538
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to identify potential sites and provide policies and programs to facilitate housing. It does not restrict housing on commercial or other non-residential sites.

As detailed on page 1-5 of the Housing Element, the planning period for the current RHNA 2021- 2029 planning period the City is allocated a total of 3,936 units, including 1,067 units affordable to very low-income households, 604 units affordable to low-income, 677 units affordable to moderate income, and 1,588 units affordable to above-moderate income households. Thus, 58 percent of the City’s RHNA allocation is for moderate and above-moderate income households.

As detailed on page 134 of the IS/MND, the proposed 71 residences equates to 1.8 percent of the City’s total RHNA allocation, and 3.1 percent of the City’s moderate and above moderate income household RHNA allocations. Although not previously identified as a housing site, the Project would assist in meeting the City’s RHNA housing needs. Additionally, the Project would assist in expanding the diversity of housing choices within the City. The IS/MND details in Section 14, Population and Housing, that single-family attached residences consist of 10.9 percent of the City’s housing units and residences within buildings containing between 2 and 4 units consist of

10.1 percent of the City’s housing units. The proposed residences are not discriminatory to persons with disabilities; as the new construction could be modified to include features to aid specific disabilities of future residents; and the structures would be required to meet ADA and OCTA emergency access requirements, as verified through the City’s development permitting process.

Further, the Project does not hinder the City’s ability to meet other income levels. The Housing Element details on page 3-56 that the City has adequate capacity to accommodate its 2021‐2029 RHNA with a five percent buffer in excess of the City’s very‐lower income RHNA need and a 2 percent buffer in excess of the City’s lower income RHNA. Although the comment opines that smaller residences of one-story with two-bedrooms should be an option, the Housing Element identifies that 56.2 percent of households within the City are family households and the average household size in the City is 3.08 persons. Further, the opinion of Project merits related to bedrooms do not pertain to the potential for significant physical impacts pursuant to CEQA, and no change to the IS/MND is required.

Comment 5-6: This comment states that the MND concludes that impacts to public safety (police and fire) will be incremental thus the impact is less than significant. Same is true for impacts to public works, libraries, and schools. The comment states that in the response the conclusion is made that no new staff will need to be hired to cover these service areas but fails to disclose that the City has over 70 full-time staff vacancies, many in police and fire. There is no discussion of how even basic level services will be maintained let alone cover the demands of this Project along with the culminative impacts of all projects pending, entitled, or recently approved for occupancy.

The comment states that service levels across the board would be significantly impacted, creating negative impacts. The comment requests comprehensive analysis of this adverse impact in the responses to comments.

Response to Comment 5-6: As described previously, CEQA is an environmental protection statute; and thus, impacts related to provision of public services are based upon the need for new or expanded facilities that, construction of which, could cause significant environmental impacts, as detailed in CEQA Guidelines Appendix G Checklist and within the IS/MND on page 125. 539
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Specifically regarding basic levels of service, the IS/MND details on page 125 that the closest fire station is 1.4 roadway miles from the Project site, has an average response time of 5 minutes and 28 seconds, and has 1.22 sworn fire staff per 1,000 residents. It is detailed that based on the existing staff ratio, 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. Furthermore, as part of review of the proposed Project, the Fire Department has reviewed the Project plans and determined that due to the limited number of new residents on the site, the increase in fire service demands from the Project would be minimal and the Department would be able to provide services, in addition to existing needs within the City.

Also, the IS/MND describes on page 126 that the Police Department had 95,570 calls for service in 2024 with a 4-minute average response time for emergency calls; and the dispatch received 49,276 emergency (911) calls of which 99.18 percent were answered within 10 seconds. The IS/MND also describes that the City’s existing 165 sworn full-time officers equate to 1.18 officers per 1,000 City residents. The addition of 226 residents at full capacity of the proposed Project would equate to a potential need for 0.27 of an additional sworn officer, which would not require construction of new or expanded Police Department facilities. Further, the IS/MND describes that the Project would comply with the requirements established in Chapter 15.52 of the Municipal Code (Building Security Ordinance #6-22) that incorporate the concepts of Crime Prevention Through Environmental Design (CPTED), which involve the placement, and orientation of structures, access and visibility of common areas, placement of doors, windows, addressing, lighting and landscaping to reduce needs for police services. Further, as part of review of the proposed Project the Police Department has reviewed the Project plans and has confirmed the ability to serve the Project, in addition to existing needs within the City.

Likewise, the City’s Public Works Department has reviewed the Project and has confirmed the ability to serve, as detailed in Section 19, Utilities and Service Systems, of the IS/MND. No specific concerns regarding public works services were identified by the comment. Potential impacts related to libraries were described on page 128 where it states that the Project site is located within an urban and developed area of the City that is already served by public facilities. Thus, redevelopment of the site with 71 residences that would house approximately 226 residents at full capacity would have a less than significant impact.

In addition, page 126 and 127 of the IS/MND describes that 11 elementary school students, 3 middle school students, and 7 high school students, are anticipated to be generated by the Project (based on Orange Unified School District assumptions). Page 127 of the IS/MND details that the School District’s 2025 Residential Commercial/Industrial Development School Fee Justification Study identifies that 4,408 elementary school seats, 751 middle school seats and 160 high school seats are available to house students generated from future residential units. Thus, the 21 students that would be generated from the Project would be accommodated by existing facilities.

Additionally, pursuant to Government Code Section 65995 et seq., the Project would be required to contribute school impact fees to the school district. Impacts related schools would be less than significant. Overall, impacts related to public services would be less than significant, and no changes to the IS/MND are required.
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Comment 5-7: This comment states that the MND notes the Project seeks approval through use of the Small Lot Subdivision Development Standards and requires Administrative Design Review.

Please explain this review, its process, and timing.

Response to Comment 5-7: As detailed on page 15 if the IS/MND, 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. Additionally, the Project includes an Administrative Design Review for consideration of the architectural design, conceptual landscaping, and overall compliance with the City’s zoning regulations.

As part of the development review and permitting process, the City would ensure that the Project meets the R3 zoning requirements with application of the Small Lot Subdivision Development Standards for fee simple duplex and detached residences. The Administrative design review would ensure Project compliance with applicable standards prior to issuance of construction permits. This comment does not raise any issue with the adequacy of the IS/MND evaluation or raise any other CEQA issue. Further, the comment does not provide any substantial evidence that the Project would result in a significant environmental impact or that changes to the IS/MND evaluation are required.

Comment 5-8: This comment states Environmental Justice – no environmental justice impacts and mitigation measures are not disclosed. The comment also concludes the letter by stating they look forward to a response to comments 10 days prior to a hearing.

Response to Comment 5-8: This comment does not provide any substantial evidence that the Project could result in a significant environmental impact or that changes to the IS/MND evaluation are required. CEQA is an environmental protection statute that is concerned with physical changes to the environment (CEQA Guidelines Section 15358(b)). The environment includes land, air, water, minerals, flora, fauna, ambient noise, and objects of historic or aesthetic significance (CEQA Guidelines Section 15360). Moreover, CEQA also requires a project evaluate its impacts in relation to changes in an area’s population, housing needs and coverage under adequate public services. Any potential environmental justice effects are social issues that are not considered effects on the environment (CEQA Guidelines Sections 15064(e) and 15131(a)). Thus, consistent with CEQA, the IS/MND includes an analysis of the Project’s potentially significant physical impacts on the environment pursuant CEQA Guidelines Appendix G threshold criteria and does not include discussion of environmental justice.

This comment is conclusionary in nature. As described on page 1, State CEQA Guidelines Section 15088 does not require a Lead Agency to prepare written responses to comments received on a Draft IS/MND. However, the City of Orange has elected to prepare written responses with the intent of providing a comprehensive and meaningful evaluation of the proposed Project. As substantiated by the previous responses above, none of the conditions arise which would require changes to the evaluation of the IS/MND.
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Letter 6: Lisa Ackerman Baldwin, Received February 24, 2026 (1 page) 542
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RESPONSE TO COMMENT LETTER 6: Lisa Ackerman Baldwin
Comment 6-1: This comment expresses concern about how the zoning change would affect the city and how the proposed Project will affect property values and quality of life in the surrounding neighborhoods.

Response to Comment 6-1: The comment does not contain any comments related to the IS/MND or information requiring changes to the IS/MND. CEQA is an environmental protection statute that is concerned with the physical changes to the environment (CEQA Guidelines Section 15358(b)). Any economic and social effects of the proposed project are not treated as effects on the environment (CEQA Guidelines Sections 15064(e) and 15131(a)). Therefore, consistent with CEQA, the IS/MND includes an analysis of the Project’s potentially significant physical impacts on the environment and does not include a discussion of the Project’s economic or social effects.

The change from a vacant commercial site to a residential neighborhood was reviewed in the IS/MND pursuant to CEQA, which determined that potential impacts related to land use, population and housing, public services, recreation, transportation, and utilities and services systems (such as related to the quality of life) would be less than significant. No specific comments related to the IS/MND evaluation of physical environmental impacts were raised by the comment.

Comment 6-2: This comment asserts disagreement that little impact on traffic would result. The comment states that the times of day that vehicles would be leaving Project site would most likely correspond with the residents in of Coco Palms at 2295 N. Tustin Street, just to the south that would lead to a backup of north bound traffic with the signal control, and exasperate south bound Tustin traffic for those turning left out of the community.

Response to Comment 6-2: The comment provides opinion and does not provide any substantial evidence that the trip generations (IS/MND Tables T-1 and T-2) that were prepared pursuant to accepted Institute of Transportation Engineers trip generation rates and reviewed and approved by the City’s Traffic Engineering Division are inaccurate. As shown in Table T-2, the proposed Project is expected to generate 34 AM peak hour and 40 PM peak hour trips, which is less than the City’s threshold to require roadway analysis of 100 peak hour trips.

Regarding the vehicular trips from the change in zoning, Table T-1 identifies that the Best Buy store is estimated to have previously generated 1,875 daily trips, including 194 PM peak hour trips.

Potential future uses under the existing GC land use designation that allows a maximum FAR of

1.0 would generate a similar volume of trips. In comparison, Table T-2 shows that the proposed Project is expected to generate a total of 511 daily trips, including 40 PM peak hour trips.

Therefore, the Project would result in 1,364 fewer daily trips and 154 fewer PM peak hour trips than the previous commercial retail use on the site.

Comment 6-3: This comment states that as an adjacent one-story development they don't want three story residents with south facing windows looking down, nor want to have to look up at them; that it is a perception and safety thing.

Response to Comment 6-3: The comment does not raise a CEQA issue and does not raise an issue with the analysis within the IS/MND. However, as part of site design and planning of the Project, 543
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the concerns raised by the comment were evaluated. Page 16 of the IS/MND details that the proposed residences along north and south boundaries would have a minimum 10-foot setback from the property line and not have roof decks. Figure 3 of the IS/MND provides an aerial view of the Project site and adjacent uses. As shown, a majority of the site area that is adjacent to the residential uses is bound by approximately 23 and 29-foot-wide drive aisles plus approximately 25-foot-deep garages, and guest parking in some locations. The Project is not adjacent to private open space areas to the north, and only directly adjacent to four existing residences to the southeast.

Thus, most of the proposed residences would be a minimum of 60 feet from the existing adjacent residences, with exception of five proposed residences that would be set between 14 and 23 feet from four residences to the southeast; however, those backyards would be contiguous, and no new public locations would be adjacent to existing residential private spaces. The setbacks from adjacent residences are shown in IS/MND Figure 8, Conceptual Site Plan. And Figure 17, Wall Plan, shows that the existing 6-foot-high walls to the north and south of the site would remain.

Comment 6-4: This comment expresses concern about the loss of this commercial zoning and related sales tax revenue.

Response to Comment 6-4: The comment provides an opinion about the Project that is not related to the IS/MND evaluation and does not include information requiring changes to the IS/MND. As described previously, CEQA is an environmental protection statute that is concerned with the physical changes to the environment (CEQA Guidelines Section 15358(b)). Any economic and social effects of the proposed Project are not treated as effects on the environment (CEQA Guidelines Sections 15064(e) and 15131(a)). Therefore, consistent with CEQA, the IS/MND does not include a discussion of the Project’s economic effects, including those related to sales tax revenue. However, as part of overall review of the proposed Project an economic analysis has been prepared and reviewed by the City.

Comment 6-5: This comment states that residents noticed that when the previous building, a bowling alley, was demolished and the Best Buy was built, cracks in foundations began to show up. The comment expresses concern that with demolition of Best Buy and concrete crushing operations, even in the middle of the development, will have a negative impact to our properties.

Response to Comment 6-5: Potential impacts related to construction vibration were evaluated as detailed on pages 118 through 121 of the IS/MND and Mitigation Measure NOI-1 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. As detailed in Table N-18 of the IS/MND, with implementation of the 20-foot equipment buffer zone, construction equipment 544
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vibration would be below the Caltrans Transportation and Construction Vibration Guidance Manual vibration damage threshold for building vibration damage. Therefore, potential impacts related to construction vibration would be less than significant.

Comment 6-6: This comment refers to residents to the north of the Project and states that the commenter would not be in favor of the emergency gate emptying into that property. The comment provides thanks for including the comments into the public comments section Response to Comment 6-6: The comment provides an opinion about the Project that is not related to the IS/MND evaluation and does not include information requiring changes to the IS/MND.

Further, the comment is conclusionary in nature, and no further response is warranted. 545
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Letter 7: Coco Palms HOA Board of Directors, Received February 25, 2026 (1 page) 546
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RESPONSE TO COMMENT LETTER 7: Coco Palms HOA Board of Directors Comment 7-1: This comment expresses concern about the transition from General Commercial to Medium Density Residential at the site and privacy impacts from rooftop gardens. The comment states that the proposed three-story structures include roof patios/gardens that would directly overlook existing homes, creating a significant privacy intrusion.

Response to Comment 7-1: Page 15 of the IS/MND describes that 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. As shown on Figure 16, Open Space Plan, all of the residences with proposed roof decks are located in the center of the Project site and all of the proposed residences along the north and south boundaries would have a private yard adjacent to perimeter walls. Thus, no roof decks would overlook existing residences.

Page 16 ends

would have a minimum 10-foot setback from the property line. Figure 3 of the IS/MND provides an aerial view of the Project site and adjacent uses, including the Coco Palms Community. As shown, the site is adjacent to 29-foot-wide drive aisles plus approximately 25-foot-deep garages, and guest parking in the Coco Palms Community to the south of the Project site.

As part of the Project plans, views from the Project site and line of sight sections from the closest existing residences were prepared, and are included as Figure 1, which shows the distance, heights, adjacent walls, parking areas, and buildings; along with the line of sight from the second and third floors of the proposed residences. As detailed, the closest proposed residence would be set back 61 feet and 10 inches from existing residences in the Coco Palms community. Figure 1 also shows that views from the proposed residences of the Coco Palms areas would be of parking, walls, landscaping and building sides. Private residential areas would not be visible from the proposed second and third story areas.

Comment 7-2: This comment expresses concern that rezoning this land from commercial to residential will result in a permanent loss of sales tax revenue for the City of Orange, further straining municipal services that would be utilized by a higher density of residents.

Response to Comment 7-2: The comment is not related to the IS/MND evaluation and does not include information requiring changes to the IS/MND. CEQA is an environmental protection statute that is concerned with the physical changes to the environment (CEQA Guidelines Section 15358(b)). Any economic effects of the proposed Project are not treated as effects on the environment (CEQA Guidelines Sections 15064(e) and 15131(a)). Therefore, consistent with CEQA, the IS/MND does not include a discussion of the Project’s economic effects, including those related to sales tax revenue. However, as part of overall review of the proposed Project an economic analysis has been prepared and reviewed by the City; and the City has verified the ability to provide municipal services to the Project, in addition to existing City service demands.

Comment 7-3: This comment expresses concern regarding the adequacy of the existing plumbing and sewage infrastructure on Tustin Street to support an additional 71 high-density units. 547
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Response to Comment 7-3: As detailed on page 147 of the IS/MND, the Project would install new onsite water and sewer lines, which connect to the existing 12-inch diameter water main located in N. Tustin Avenue and existing 12-inch sewer line within E. Heim Avenue. The existing off-site water and sewer lines would accommodate the proposed Project, as confirmed by the City’s Public Works Department, and would not require expansion to serve the Project.

Comment 7-4: This comment states that the addition of approximately 226 new residents will significantly impact traffic flow on Tustin Street and that inadequate on-site parking will lead to spill over into neighboring areas.

Response to Comment 7-4: As detailed on page 132 of the IS/MND the proposed Project is expected to generate a total of 511 daily trips, including 34 AM peak hour and 40 PM peak hour trips. This is less than the City’s threshold to require roadway analysis due to potential roadway effects, which is 100 peak hour trips or 1,600 daily trips. Thus, the proposed Project would not significantly impact traffic flow on N. Tustin Street. Regarding parking, the proposed Project includes a two-car garage for each residence, 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 5 more than required by the City. Thus, the Project includes adequate parking pursuant to City requirements.

Comment 7-5: This comment requests that trash dumpsters be placed at a sufficient distance from our property line to ensure that odors do not impact residents.

Response to Comment 7-5: The proposed Project does not include dumpsters. Each of the proposed residences would have separate 35-gallon trash, recycle, and organic bins; and solid waste pick ups would occur along the internal drive aisle, towards the center of the site, and not along the property lines. Due to the distance, residential building, fence, and wall barriers and the limited volume of solid waste within each 35-gallon bin, impacts related to odors are anticipated to be less than significant.

Comment 7-6: This comment expresses concern about construction noise and requests strict enforcement of noise ordinances, particularly regarding rock crushing and heavy machinery, to protect resident quality of life during the construction phase. The comment asks that these points be included in the official record for the Planning Commission and City Council.

Response to Comment 7-6: The IS/MND includes evaluation of the Project construction noise, including concrete crushing, at the closest residences in the Coco Palms Community on pages 109 through 113, which was determined to be less than significant pursuant to criteria from the Federal Transit Administration Transit Noise and Vibration Impact Assessment Manual. In addition, the City’s construction permitting would ensure that construction is limited to 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. The comment will be included in the Final IS/MND along with all other comments received.
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Letter 8: Doug Hamilton, Received February 25, 2026 (1 page) 549
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RESPONSE TO COMMENT LETTER 8: Doug Hamilton
Comment 8-1: This comment suggests that there should be a commercial zoning component running north and south, facing Tustin Street across the front of the housing development, and that the new housing tract be located behind the new commercial retail space. The comment states that it's a compromise that would protect the City's budget and that sales tax revenue sources from properties zoned Commercial must be preserved at all costs. The comment asserts that Councilmembers protect the careful balance of zoning throughout our city as it relates to sales tax revenue and good management practices that protect the City's budget.

Response to Comment 8-1: The proposed Project is consistent with the comment, whereby commercial uses would be located along N. Tustin Street, in front of the proposed residences. As detailed on IS/MND Figure 8, Conceptual Site Plan, the Project site would be accessed by a 29- foot-wide driveway that would also serve the existing retail use to the north of the driveway and a proposed commercial use to the south of the driveway. As shown on IS/MND Figure 8, Conceptual Site Plan, and Figure 18, Conceptual Landscaping Plan, the proposed residences would not front N. Tustin Street but would be set behind (east of) commercial uses, as suggested by the comment.

The comment provides an opinion about the Project that is not related to the IS/MND evaluation and does not include information requiring changes to the IS/MND. It should be further noted that CEQA is an environmental protection statute that is concerned with the physical changes to the environment (CEQA Guidelines Section 15358(b)). Any economic and social effects of the proposed Project are not treated as effects on the environment (CEQA Guidelines Sections 15064(e) and 15131(a)). Therefore, consistent with CEQA, the IS/MND does not include a discussion of the Project’s economic effects, including those related to sales tax revenue. However, as part of overall review of the proposed Project an economic analysis has been prepared and reviewed by the City.
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Figure 1: Proposed Project Line of Sight Sections
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Figure 2: Proposed Project Shade and Shadow
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Figure 3: Proposed Schematic Planting Plan
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Figure 4: Proposed Tree Images
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CHAPTER 3

REVISIONS TO THE PUBLIC REVIEW IS/MND
This chapter of the Final Initial Study/Mitigated Negative Declaration (IS/MND) contains revisions to the Public Review IS/MND based upon: (1) clarifications required to prepare a response to a specific comment; and/or (2) typographical errors. These revisions do not alter any impact significance conclusions as disclosed in the IS/MND. Changes made to the IS/MND text are identified here in strikeout text to indicate deletions and in double underlined text to signify additions.

Revisions in Response to Written Comments and City Changes to Text The following revisions, organized by IS/MND Section, have been made in response to comments received on the IS/MND and to provide additional clarification.

Figure 18, Conceptual Landscaping Plan
Figure 18, Conceptual Landscaping Plan, on page 43 of the IS/MND has been replaced with the updated Figure 18, provided below, wherein the arrow for keynote 16 correctly points to the property line, as identified in the legend.

Appendix L, Mitigation Monitoring and Reporting Program The sub header and second and third paragraphs on the first page of the Mitigation Monitoring and Reporting Program (MMRP) of Appendix L have been revised as follows:

Mitigation Monitoring and Reporting Program Plan
The California Environmental Quality Act (CEQA) requires that when a public agency completes an environmental document which includes measures to mitigate or avoid significant environmental effects, the public agency must adopt a reporting or monitoring plan. This requirement ensures that environmental impacts found to be potentially significant will be mitigated. The reporting or monitoring plan must be designed to ensure compliance during project implementation (Public Resources Code Section 21081.6).

This Mitigation Monitoring and Reporting Program (MMRP) delineates responsibilities for monitoring the Project but also allows the City flexibility and discretion in determining how best 555
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to monitor implementation. Monitoring procedures will vary according to the type of mitigation measure. Adequate monitoring consists of demonstrating that monitoring procedures took place and that mitigation measures were implemented. This includes the review of all monitoring reports, enforcement actions, and document disposition, unless otherwise noted in the Mitigation Monitoring and Reporting MMRP checklist. If an adopted mitigation measure is not being properly implemented, the designated monitoring personnel shall require corrective actions to ensure adequate implementation.
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CHAPTER 4

MITIGATION MONITORING AND REPORTING PROGRAM
The California Environmental Quality Act (CEQA) requires that when a public agency completes an environmental document which includes measures to mitigate or avoid significant environmental effects, the public agency must adopt a reporting or monitoring plan. This requirement ensures that environmental impacts found to be potentially significant will be mitigated. The reporting or monitoring plan must be designed to ensure compliance during project implementation (Public Resources Code Section 21081.6).

In compliance with Public Resources Code Section 21081.6, the attached Mitigation Monitoring and Reporting Program (MMRP) checklist has been prepared for the North Tustin Street Residential Project. The table identifies Project Design Features (PDFs); Plans, Programs, and Policies (PPPs); and Mitigation Measures (MMs) required by the City to mitigate or avoid significant adverse impacts associated with the implementation of the Project. This MMRP Checklist is intended to provide verification that all applicable mitigation measures relative to significant environmental impacts are monitored and reported. Monitoring will include: 1) verification that each mitigation measure has been implemented; 2) recordation of the actions taken to implement each mitigation measure; and 3) retention of records in the City’s North Tustin Street Residential Project file.

This MMRP delineates responsibilities for monitoring the Project but also allows the City flexibility and discretion in determining how best to monitor implementation. Monitoring procedures will vary according to the type of mitigation measure. Adequate monitoring consists of demonstrating that monitoring procedures took place and that mitigation measures were implemented. This includes the review of all monitoring reports, enforcement actions, and document disposition, unless otherwise noted in the MMRP checklist. If an adopted mitigation measure is not being properly implemented, the designated monitoring personnel shall require corrective actions to ensure adequate implementation.

Reporting consists of establishing a record that a mitigation measure is being implemented, and generally involves the following steps:
• The City distributes reporting forms to the appropriate entities for verification of compliance. • Departments/agencies with reporting responsibilities will review the Initial Study/Mitigated Negative Declaration, which provides general background information on the reasons for including specified mitigation measures.
• Periodic meetings may be held during Project implementation to report on compliance of mitigation measures.
• Responsible parties provide the City with verification that monitoring has been conducted and ensure, as applicable, that mitigation measures have been implemented. Monitoring compliance may be documented through existing review and approval programs such as field inspection reports and plan review.
• The City prepares a reporting form periodically during the construction phase and an annual report summarizing all project mitigation monitoring efforts. 559
City of Orange North Tustin Street Residential Project
Mitigation Monitoring and Reporting Program MND NO. ENV25-0001 City of Orange 4-2
Final IS/MND
March 2026
• Appropriate mitigation measures will be included in construction documents and/or conditions of permits/approvals.

Minor changes to the MMRP, if required, would be made in accordance with CEQA and would be permitted after review and approval by the City. Such changes could include reassignment of monitoring and reporting responsibilities, plan redesign to make any appropriate improvements, and/or modification, substitution or deletion of mitigation measures subject to conditions described in CEQA Guidelines Section 15162. No change will be permitted unless the MMRP continues to satisfy the requirements of Public Resources Code Section 21081. 560
City of Orange North Tustin Street Residential Project
Mitigation Monitoring and Reporting Program MND NO. ENV25-0001 City of Orange 4-3
Final IS/MND
March 2026
Mitigation Monitoring and Reporting Program Checklist
No. Project Design Feature / Plan, Program, Policy /
Mitigation Measure
Time Frame and
Responsible
Party for
Implementation
Time Frame and
Responsible
Party for
Monitoring
Verification of Compliance
Initials Date Remarks
Aesthetics
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.

Prior to Building
Permits.

City of Orange
Building & Safety
Prior to Building
Permits.

City of Orange
Building & Safety
Air Quality
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.

Prior to
Demolition,
Grading and
Building Permits
City of Orange
Building & Safety
During
construction
City of Orange
Building & Safety
561
City of Orange North Tustin Street Residential Project
Mitigation Monitoring and Reporting Program MND NO. ENV25-0001 City of Orange 4-4
Final IS/MND
March 2026
No. Project Design Feature / Plan, Program, Policy /
Mitigation Measure
Time Frame and
Responsible
Party for
Implementation
Time Frame and
Responsible
Party for
Monitoring
Verification of Compliance
Initials Date Remarks
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.

Prior to
Demolition,
Grading and
Building Permits
City of Orange
Building & Safety
During
Construction
City of Orange
Building & Safety
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 “LowVolatile Organic Compounds” paints (no more than 50 gram/liter of VOC) and/or High Pressure Low Volume
(HPLV) applications shall be used.

Prior to Building
Permits
City of Orange
Building & Safety
During
Construction
City of Orange
Building & Safety
562
City of Orange North Tustin Street Residential Project
Mitigation Monitoring and Reporting Program MND NO. ENV25-0001 City of Orange 4-5
Final IS/MND
March 2026
No. Project Design Feature / Plan, Program, Policy /
Mitigation Measure
Time Frame and
Responsible
Party for
Implementation
Time Frame and
Responsible
Party for
Monitoring
Verification of Compliance
Initials Date Remarks
Biological Resources
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.

Prior to
Demolition and
Grading Permits
City of Orange
Planning
Prior to
Demolition and
Grading Permits
Qualified
Biologist
Cultural Resources
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
Prior to Grading
Permits.

During
Construction
563
City of Orange North Tustin Street Residential Project
Mitigation Monitoring and Reporting Program MND NO. ENV25-0001 City of Orange 4-6
Final IS/MND
March 2026
No. Project Design Feature / Plan, Program, Policy /
Mitigation Measure
Time Frame and
Responsible
Party for
Implementation
Time Frame and
Responsible
Party for
Monitoring
Verification of Compliance
Initials Date Remarks
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..

City of Orange
Planning
City of Orange
Planning
Energy
PPP E1 Title 24 CalGreen Compliance: T 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.

Prior to Building
Permits.

City of Orange
Building & Safety
Before
construction.

City of Orange
Building & Safety
Geology and Soils
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
Prior to Building
Permits
Before
construction.
564
City of Orange North Tustin Street Residential Project
Mitigation Monitoring and Reporting Program MND NO. ENV25-0001 City of Orange 4-7
Final IS/MND
March 2026
No. Project Design Feature / Plan, Program, Policy /
Mitigation Measure
Time Frame and
Responsible
Party for
Implementation
Time Frame and
Responsible
Party for
Monitoring
Verification of Compliance
Initials Date Remarks
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.

City of Orange
Building & Safety
City of Orange
Building & Safety
Greenhouse Gas Emissions
PPP E1 Title 24 CalGreen Compliance. As listed previously in Energy.

Prior to Building
Permits
City of Orange
Building & Safety
Before
Construction
City of Orange
Building & Safety
Hydrology and Water Quality
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
Prior to Grading
and Demolition
Permits
City of Orange
Public Works
Prior to
Construction
City of Orange
Public Works
565
City of Orange North Tustin Street Residential Project
Mitigation Monitoring and Reporting Program MND NO. ENV25-0001 City of Orange 4-8
Final IS/MND
March 2026
No. Project Design Feature / Plan, Program, Policy /
Mitigation Measure
Time Frame and
Responsible
Party for
Implementation
Time Frame and
Responsible
Party for
Monitoring
Verification of Compliance
Initials Date Remarks
(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.

Prior to Grading
and Building
Permits
City of Orange
Building and
Public Works
Prior to
Construction
City of Orange
Building and
Public Works
Noise
PDF-1 Interior Noise. Project building plans, specifications, and permits shall detail that the third floor of the
residence in the northeastern most portion of the site
(Lot 54) will be developed with upgraded windows
that have a minimum Sound Transmission Class
(STC) rating of 31.

Prior to Building
and Occupancy
Permits
City of Orange
Building and
Public Works
Site inspection of
Lot 54 prior to
Occupancy
Permits
City of Orange
Building and
Public Works
MM
NOI-1
Vibration. 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 Prior to Grading
and Demolition
Permits
During
Construction
City of Orange
Building & Safety
566
City of Orange North Tustin Street Residential Project
Mitigation Monitoring and Reporting Program MND NO. ENV25-0001 City of Orange 4-9
Final IS/MND
March 2026
No. Project Design Feature / Plan, Program, Policy /
Mitigation Measure
Time Frame and
Responsible
Party for
Implementation
Time Frame and
Responsible
Party for
Monitoring
Verification of Compliance
Initials Date Remarks
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.

City of Orange
Building & Safety
Tribal Cultural Resources
MM
TCR-1
Native American Monitoring.

A. The Project plans, specifications, and grading
permits shall state that the Project applicant shall
retain a Native American Monitor. The monitor
shall be retained prior to the commencement of any
“ground-disturbing activity” for the subject Project
at all Project locations (i.e., both on-site and any
off-site locations that are included in the project
description and/or required in connection with the
Project, such as public improvement work).
“Ground-disturbing activity” shall include, but is
not limited to, demolition, pavement removal,
potholing, auguring, grubbing, tree removal,
boring, grading, excavation, drilling, and
trenching.

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

Prior to Ground
Disturbing
Activities
City of Orange
Planning
During
Construction
Native American
Monitor
567
City of Orange North Tustin Street Residential Project
Mitigation Monitoring and Reporting Program MND NO. ENV25-0001 City of Orange 4-10
Final IS/MND
March 2026
No. Project Design Feature / Plan, Program, Policy /
Mitigation Measure
Time Frame and
Responsible
Party for
Implementation
Time Frame and
Responsible
Party for
Monitoring
Verification of Compliance
Initials Date Remarks
C. The monitor shall complete daily monitoring logs
that will provide descriptions of the relevant
ground-disturbing activities, the type of
construction activities performed, locations of
ground-disturbing activities, soil types, culturalrelated materials, and any other facts, conditions, materials, or discoveries of significance to the
Tribe. Monitor logs shall identify and describe any
discovered TCRs, including but not limited to,
Native American cultural and historical artifacts,
remains, places of significance, etc., (collectively,
tribal cultural resources, or “TCR”), as well as any
discovered Native American (ancestral) human
remains and burial goods. Copies of monitor logs
shall be provided to the Project applicant/lead
agency upon written request to the Tribe.

D. On-site tribal monitoring shall conclude upon the
latter of the following (1) written confirmation to
the monitoring Tribe from a designated point of
contact for the Project applicant/lead agency that
all ground-disturbing activities and phases that
may involve ground-disturbing activities on the
Project site or in connection with the Project are
complete; or (2) a determination and written
notification by the monitoring Tribe to the Project
applicant/lead agency that no future, planned
construction activity and/or
568
City of Orange North Tustin Street Residential Project
Mitigation Monitoring and Reporting Program MND NO. ENV25-0001 City of Orange 4-11
Final IS/MND
March 2026
No. Project Design Feature / Plan, Program, Policy /
Mitigation Measure
Time Frame and
Responsible
Party for
Implementation
Time Frame and
Responsible
Party for
Monitoring
Verification of Compliance
Initials Date Remarks
development/construction phase at the Project site
possesses the potential to impact TCRs.

MM
TCR-2
Unanticipated Discovery of Tribal Cultural
Resource Objects.

A. Upon discovery of any TCRs, the monitoring tribe
notify the City and Project Applicant and all
construction activities in the immediate vicinity of
the discovery shall cease (i.e., not less than the
surrounding 50 feet) and shall not resume until the
discovered TCR has been fully assessed by the
tribal monitor and/or tribal archaeologist. The
monitoring tribe shall recover and retain all
discovered TCRs in the form and/or manner the
monitoring tribe deem appropriate.

During Ground
Disturbing
Activities
City of Orange
Planning
During
Construction
Native American
Monitor
MM
TCR-3
Unanticipated Discovery of Human Remains and
Associated Funerary or Ceremonial Objects.

A. MM TCR-3: Unanticipated Discovery of Human
Remains and Associated Funerary or Ceremonial
Objects.

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

During Ground
Disturbing
Activities
City of Orange
Planning
During
Construction
Native American
Monitor
569
City of Orange North Tustin Street Residential Project
Mitigation Monitoring and Reporting Program MND NO. ENV25-0001 City of Orange 4-12
Final IS/MND
March 2026
No. Project Design Feature / Plan, Program, Policy /
Mitigation Measure
Time Frame and
Responsible
Party for
Implementation
Time Frame and
Responsible
Party for
Monitoring
Verification of Compliance
Initials Date Remarks
C. If Native American human remains and/or grave
goods are discovered or recognized on the Project
site, then Public Resource Code 5097.9 as well as
Health and Safety Code Section 7050.5 shall be
followed.

D. Human remains and grave/burial goods shall be
treated alike per California Public Resources Code
section 5097.98(d)(1) and (2).

E. Preservation in place (i.e., avoidance) is the
preferred manner of treatment for discovered
human remains and/or burial goods.

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

PPP
CUL-1
Human Remains. California Health and Safety Code
Section 7050.5. Listed previously in Section 5,
Cultural Resources.

Prior to Grading
Permits
City of Orange
Planning
During
Construction
City of Orange
Planning
570
Appendix A: Air Quality, Energy, and Greenhouse Gas Impact Analysis
Attachment 8
571

PROJECT OVERVIEW
This technical memorandum presents an analysis of the air quality, energy, and greenhouse gas (GHG) impacts for the North Tustin Street Project (proposed Project) in the city of Orange. The Project site is located at 2375 North Tustin Street in the northern portion of the city of Orange. Regional access to the Project site is provided by SR-55, from either the Katella Avenue interchange to the south or the Lincoln Avenue interchange to the north, which both intersect with North Tustin Street, a primary arterial.

The Project site comprises one parcel encompassing approximately 4.235 gross acres. The parcel is identified by Orange County Assessor’s Parcel Number (APN) 372-642-31. The Project site is fully developed and currently contains a vacant 45,676-square-foot (SF) Best Buy retail store building that is approximately 30 feet in height, along with a surface parking lot and landscaping.

The applicant for the Project is requesting approval from the City of Orange to demolish the existing structure and improvements on the Project site and construct 71 paired and detached residences, along with open space/recreation and parking. The residential structures would be three stories high. Each residential unit would have three or four bedrooms, ranging in size from approximately 2,008 to 2,117 SF, 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 aerial of the Project site and the conceptual site plan are shown in Figure 1, Project Aerial, and Figure 2, Conceptual Site Plan.

The Project requests the approval of a General Plan Amendment to change the land use from General Commercial (GC) to Medium Density Residential (MDR), 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 Limited Business Tustin Redevelopment Project Area (C-TR) to Multiple-Family Residential (R3).

To support the California Environmental Quality Act (CEQA) document, this report analyzes the proposed Project’s construction and operational impacts to air quality (emission of criteria pollutants), energy usage, and GHG emissions using the California Emissions Estimator Model (CalEEMod Version 2022.1) land use emission model and Emission Factor (EMFAC Version 2021) model. The Project site is within the jurisdiction of the South Coast Air Quality Management District (SCAQMD). Therefore, significance thresholds from SCAQMD are used.

To: City of Orange Planning Department
Drafted by: Tiffany Dang, EPD Solutions, Inc.

Reviewed by: Tina Yuan, Alex J. Garber, EPD Solutions, Inc.

Date: 10/3/2025
Re: Air Quality, Energy, and Greenhouse Gas Impact Analysis for the North Tustin Street Project, EPD Project Number 25-032
572
Figure 1: Project Aerial
Maxar
0 150 300
Feet
±
Legend
Project Site
North Tustin Street
SR-55
N Tustin St
E Heim Ave
573
North Tustin Street Figure 2: Conceptual Site Plan
STOP
STOP
PL 3A
1 STORY RETAIL TUSTIN STREET

PROPOSED

COMMERCIAL NOT A PART
5 6
6 6
R50.0
R55.0
R55.0 R50.0
R50.0 R55.0
R50.0
R55.0
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 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' 10.2' 10.1' 3.1' 10' 10' 10.2' 10.4' 10.5' 10.8' 11' 11.2' 11.4' 11.6' 10.5' 10.4' 11.1' 10.7' 10.8' 10.9' 11' 11.1' 11.3' 11.3' 11.4' 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' 10.1' 10.6' 10.6' 10.7' 10.1' 10.1' 10.8' 10.1' 10.8' 10.1' 10.7' 10.2' 10.6' 10'

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'

16.6' 29.0 11.5 9.8
F.H.

F.H.

R17.5 W/ ANTI-GRAFFITI PAINT

W/ ANTI-GRAFFITI PAINT
470.25' 192.60' 140.00' 8.24'
537.45' 170.60'
222.51'
275.01' 60.00' // // // //
// // // // // // // // // //
// // // // // // // //
// // || || ||
> > > > >
> >
> > > > > > > > > > >
> > > > > > > > > >
1 1
4 1
2 2
3 3
4 1
2 3
4 7
7 8
9 9
10 9
10 10
7 7
7 7
7 7
7 10
4 11
12 13
13 13
13 13
13 14
15 15
15 Not to scale ±
574
North Tustin Street Project Air Quality, Energy, and GHG Impact Analysis 4 SUMMARY OF AIR QUALITY, ENERGY, AND GHG IMPACTS
Air Quality
The proposed Project’s maximum daily emissions for construction would not exceed SCAQMD’s regional or local thresholds of significance for any criteria pollutants. Operation of the Project would not exceed SCAQMD’s regional thresholds of significance. Projects that do not exceed regional thresholds are assumed not to have a significant impact on both a project level and a cumulative level. The proposed Project also aligns with SCAQMD’S 2022 Air Quality Management Plan (AQMP), reflecting adherence to regional air quality management goals and standards. Furthermore, odors produced by the construction and operation of the proposed Project would be minimal. Additionally, all construction activities would comply with applicable SCAQMD rules and regulations, including Rule 402, Rule 403, and Rule 1113 as further described in the air quality analysis section. Impacts on air quality would therefore be less than significant and no mitigation would be required.

Energy
The proposed Project’s energy consumption for construction activities would be conditioned to require compliance with existing fuel standards, machinery efficiency standards, and California Air Resources Board (CARB) requirements that limit idling of construction trucks and equipment. There are no unusual Project characteristics that would cause the use of construction equipment that would be less energy efficient compared with other similar construction sites in other parts of the state. Additionally, through compliance with existing standards, operation of the Project would not result in an energy demand on a per-development basis that is greater than other development projects in Southern California. Furthermore, the proposed Project would be required to meet the California Code of Regulations (CCR) Title 24 energy efficiency standards and comply with all applicable City energy codes. The Project buildings would install solar panels in compliance with current Title 24 requirements. Therefore, the Project would not inhibit the use of, and would instead allow for, future flexibility relating to renewable energy. Overall, the Project would therefore result in less-than-significant impacts related to inefficient, wasteful, or unnecessary consumption of energy and future growth of renewable energy, and no mitigation would be required.

GHG Emissions
The proposed Project’s construction and operational GHG emissions would total 896 metric tons of carbon dioxide equivalent (MTCO2e). The Project’s total GHG emissions would not exceed SCAQMD’s Tier III significance threshold of 3,000 MTCO2e per year. Additionally, the proposed Project is consistent with the actions and measures of the City’s General Plan, CARB’s 2022 Scoping Plan, and SCAG’s 2024 Connect SoCal and would not interfere with the policies and goals set within those plans. Therefore, the Project would have a less-than-significant impact on GHG emissions and no mitigation would be required.

575
North Tustin Street Project Air Quality, Energy, and GHG Impact Analysis 5 METHODOLOGY
To calculate the construction and operational impacts, air quality emissions, energy consumption, and GHG emissions were estimated using CalEEMod v. 2022.1 and EMFAC v. 2021. The passenger vehicles were analyzed using the CalEEMod default trip distance information.1 Table 1, Construction Schedule, shows the construction schedule modeled. Following CalEEMod’s default schedule, construction would last approximately 14 months.

Table 1: Construction Schedule
To provide a Project specific analysis of potential impacts, the following non-default assumptions and adjustments were used in the CalEEMod emission model for this analysis:
• Land Use: The lot acreage and building square footage was adjusted to match the site plan. • Construction, Off-Road Equipment: It was conservatively assumed that all equipment would be used for 8 hours per workday. Tractors/loaders/backhoes were replaced with crawler tractors in the site preparation and grading phases to accurately measure acres disturbed. One diesel-powered crushing/processing equipment was added to the demolition phase to account for the crushing of demolition material.
• Construction, Off-Road Equipment Emission Factors: Emissions factors for diesel crushing equipment were input using EMFAC OFFROAD2021 values for the Orange County sub-area, 2026. Due to a bug in CalEEMod, emissions resulting from the crushing equipment were manually calculated (included as Appendix B) and added to the total grading phase emissions. • Construction, Dust from Material Movement: Based on the Project’s grading plan, the grading phase is expected to result in a net export of approximately 7,350 cubic yards of soil. • Construction, Demolition: The Project proposes demolition of the existing retail building, parking lot, and hardscape. Demolition tonnage was provided by the Project Applicant. • Operations, Vehicle Data: Weekday, Saturday, and Sunday trip rates were adjusted to match the Institute of Transportation Engineers (ITE) Trip Generation Manual, 11th Edition, auto trip rates for single family attached housing (ITE Land Use Code 215).
• Operations, Hearths: Wood burning fireplaces and stoves were removed as they are prohibited by SCAQMD Rule 445.
1 EPD utilized the Metropolitan Planning Organization (MPO) default data provided in CalEEMod, as it provides more accurate trip length data than the region-wide CSTDM trip length data.

Activity Start Date End Date Total Working Days
Demolition 9/1/2026 9/29/2026 20
Site Preparation 9/30/2026 10/7/2026 5
Grading 10/8/2026 10/19/2026 8
Building Construction 10/20/2026 9/7/2027 230
Paving 9/8/2027 10/3/2027 18
Architectural Coating 10/4/2027 10/29/2027 18
Source: CalEEMod Output Sheets (see Appendix A).
576
North Tustin Street Project Air Quality, Energy, and GHG Impact Analysis 6 Rock Crushing
In addition to PM10 and PM2.5 derived from exhaust, emissions resulting from crushing asphalt hardscape had been calculated and added to CalEEMod’s emissions outputs. This analysis assumes all crushing would occur during the demolition phase. Fugitive dust emissions comprised of PM10 and PM2.5 were calculated using emission factors provided by AP-42, Section 11.19, Crushed Stone Processing and Pulverized Mineral Processing (United States Environmental Protection Agency, 2005). Pursuant to SCAQMD Rule 403, Fugitive Dust, it was assumed that crushing operations would utilize watering for dust suppression. Thus, controlled rates were used to estimate emissions for the proposed Project. The estimated emissions were added to the demolition phase. Calculations are included in Appendix B. 577
North Tustin Street Project Air Quality, Energy, and GHG Impact Analysis 7 AIR QUALITY
Regional Emissions
The SCAQMD has adopted maximum daily emission thresholds (pounds/day) for the criteria pollutants during construction and operation of a project (South Coast Air Quality Management District, 2023). While incremental regional air quality impacts of an individual project are generally very small and difficult to measure, SCAQMD’s regional maximum emission thresholds set standards to reduce the burden of SCAQMD to attain and maintain ambient air quality standards. The CalEEMod Project emissions along with regional construction and operational thresholds for each of the criteria pollutants are listed in Table 2, Regional Construction Emission Estimates, and Table 3, Regional Operational Emission Estimates, respectively. These emission thresholds apply to Project emissions generated both from on-site sources (such as off-road construction equipment and fugitive dust) and off-site sources (vehicle travel arriving to and leaving from the site).

Project construction would be required to comply with several SCAQMD rules and regulations which would further reduce impacts to air quality emissions. These rules include Rule 402, Public Nuisance, which prohibits the discharge of air contaminants that cause injury, nuisance, or annoyance to the public or damage to property; Rule 403, Fugitive Dust, which aims to minimize fugitive particulate matter dust from construction activities; and Rule 1113, Architectural Coatings, which only allows low VOC paints to be used. Compliance with Rules 403 and 1113 have been accounted for in the CalEEMod modeling. Project construction is assumed to water exposed areas to reduce fugitive dust. In addition, CalEEMod’s default VOC content for residential architectural coatings is 50 grams per liter (g/L).

The CalEEMod output sheets for the proposed Project can be found in Appendix A, CalEEMod Output Sheets.

Detailed tables showing the emissions from each construction phase can be found in Appendix C. As noted in Table 2, construction of the proposed lots would not exceed any of SCAQMD’s regional construction thresholds. Therefore, the proposed Project would result in less-than-significant regional construction impacts.

Table 2: Regional Construction Emission Estimates
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: CalEEMod Output Sheets (see Appendix A and Appendix C).

Operation of the Project would generate emissions of criteria pollutants from vehicle trips, residential equipment, and energy consumption. The Project’s estimated maximum daily regional operational emissions estimates are provided in Table 3, Regional Operational Emission Estimates, would not exceed any of SCAQMD’s regional operational thresholds. No mitigation would be required. Therefore, the Project would result in less-than-significant regional operational impacts. 578
North Tustin Street Project Air Quality, Energy, and GHG Impact Analysis 8 Table 3: Regional Operational Emission Estimates
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: CalEEMod Output Sheets (see Appendix A).

Local Emissions
Localized significance thresholds (LSTs) were also adopted by the SCAQMD to evaluate projects which would not exceed the regional emission significance thresholds but may have the potential to exceed State and national air quality standards within a project’s vicinity. These thresholds set the maximum rates of daily construction or operational emissions from a project site that would not exceed a national or State ambient air quality standard (South Coast Air Quality Management District, 2008a). The differences between regional thresholds and LSTs are as follows:

1. Regional thresholds include all sources of project construction and operational emissions generated from on-site and off-site emission sources whereas the LSTs only consider the emissions generated from on-site emission sources.

2. LSTs only apply to carbon monoxide (CO), nitrogen oxides (NOx), and particulate matter (PM10 and PM2.5), while regional thresholds include both reactive organic gases (ROG) and sulfur dioxide (SO2).

3. Regional thresholds apply to emission sources located anywhere within the SCAQMD whereas the LSTs are location dependent and rely on the size of the project and emission location relative to the nearest sensitive receptor. A sensitive receptor is defined as an individual who is most susceptible to negative health effects when exposed to air pollutants and includes children, the elderly, and adults with chronic health issues. Locations for sensitive receptors include residences, schools, elderly care centers, and hospitals.

The SCAQMD provides screening tables (Appendix C of the SCAQMD 2008 Final Localized Significance Threshold Methodology) for projects that disturb less than or equal to 5 acres in a day (South Coast Air Quality Management District, 2008b). These tables were created to easily determine if the daily emissions of NOx, CO, PM10, and PM2.5 from a project could result in a significant impact to the local air quality. The thresholds are determined by:
• Source receptor area (SRA), which is the geographic area within the SCAQMD that can act as both a source of emissions and a receptor of emission impacts (the Project is located within SRA 17, Central Orange County);
• Size of grading disturbance (construction)/size of the project (operation); and • Distance to the nearest sensitive receptor.

Using the SCAQMD’s methodology to estimate acres of ground disturbance, the site preparation phase was determined to result in a maximum of 3.5 acres of ground disturbance per day. Therefore, the SCAQMD thresholds for a 2-acre and 5-acre site were interpolated to calculate thresholds for a 3.5-acre site, as 579
North Tustin Street Project Air Quality, Energy, and GHG Impact Analysis 9 recommended in their methodology. Calculations for site disturbance can be found in Appendix C. Distance to the nearest sensitive receptor also determines the emission thresholds. There are existing residential communities to the north and south of the Project site, with the closest sensitive receptor approximately 5 meters (16 feet) south of the Project site. Therefore, the construction emission thresholds for 25 meters were used, since it is the closest receptor distance for thresholds provided by the LST mass look-up tables.

Table 4, Localized Construction Emission Estimates, shows the thresholds and estimated maximum daily construction emissions for the proposed Project. As shown in these tables below, the proposed Project would not exceed the SCAQMD LST screening thresholds and would therefore have a less-than-significant localized construction air quality impact.

Table 4: Localized Construction Emission Estimates
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: CalEEMod Output Sheets (see Appendix A).

According to the SCAQMD LST methodology, LSTs apply to project-related stationary and 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 Project would operate as a residential community, which does not typically involve diesel vehicles regularly idling or queueing for long periods. Therefore, due to the lack of significant stationary source emissions or idling diesel-powered vehicles, impacts related to operational LSTs are presumed to be less than significant.

Air Quality Management Plan Consistency
The Project site is located in the South Coast Air Basin, which is within the jurisdictional boundaries of the 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 South Coast Air Basin. The 2022 AQMP is based on 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.

Consistency Criterion No. 1 refers to the SCAG’s growth forecasts, and associated assumptions included in the AQMP. The future air quality levels projected in the AQMP are based on SCAG’s growth projections, which are based, in part, on the general plans of cities located within the SCAG region. While SCAG has 580
North Tustin Street Project Air Quality, Energy, and GHG Impact Analysis 10 updated the RTP/SCS to the Connect SoCal 2024, which provides growth and forecasting estimates for 2019 through 2050, this update was adopted after the 2022 AQMP. Therefore, the analysis below uses assumptions from the 2020-2045 RTP/SCS for consistency with the most recent AQMP.

The 2022 AQMP was based on the Project site’s existing General Plan land use designation of 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 the VMT Screening Analysis prepared for this Project, the former Best Buy store generated approximately 1,875 daily vehicle trips and the proposed 71 residential units under the proposed General Plan land use designation of MDR would generate approximately 511 daily vehicle trips (EPD Solutions, Inc., 2025). Thus, the proposed Project, including General Plan Amendment, 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 (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, presented in Tables 2 through 4, 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.

Since the Project would be consistent with both Consistency Criterion No. 1 and 2, the Project would not conflict with the 2022 AQMP.

Odors
Odors would be produced during the construction of the proposed Project due to the operation of heavyduty off-road equipment. The primary odor emitted would be diesel particulate matter from the vendor trucks and heavy-duty off-road equipment. This odor may be noticeable by nearby residents; however, these odors would be expected and not necessarily objectionable. These odors would also dissipate quickly and would be temporary. Therefore, due to the nature of the odor produced during construction as temporary and non-objectionable to a substantial number of people, the odor impact from construction of the proposed Project would be less than significant.

For operational odor emissions, SCAQMD’s CEQA Air Quality Handbook describes odor complaints associated with the following land uses:
• Agricultural uses
• Chemical plants
• Composting activities
• Dairies
• Fiberglass molding
• Food processing plants
• Landfills
• Refineries
• Wastewater treatment plants
The Project does not propose any of the above land uses and is required to comply with 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 581
North Tustin Street Project Air Quality, Energy, and GHG Impact Analysis 11 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.

Thus, impacts associated with odor produced by operation of the proposed Project would be less than significant.

Conclusion
The proposed Project’s maximum daily regional construction, local construction, and regional operational emissions would not exceed the SCAQMD’s thresholds for any criteria pollutants. All construction activities would comply with the applicable SCAQMD rules and regulations. Additionally, the proposed Project is consistent with SCAQMD’S 2022 AQMP, reflecting adherence to regional air quality management goals and standards. Finally, for odors produced during construction, these would be temporary and not significantly objectionable, and for odors produced during operation, the proposed Project involves land uses that typically do not generate significant odor complaints and would comply with SCAQMD Rule 402.

Therefore, the proposed Project would result in less-than-significant air quality impacts. No mitigation is required.
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North Tustin Street Project Air Quality, Energy, and GHG Impact Analysis 12 ENERGY
The State CEQA Guidelines do not have specific thresholds for energy consumption. Rather, the question in Appendix G: VI Energy (a) asks, “[Would the proposed Project] Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources during project construction or operation?” and in (b) asks, “[Would the project] Conflict with or obstruct a State or local plan for renewable energy or energy efficiency?” (California Energy Commission, 2023). Therefore, for the purpose of this analysis, a significant impact would occur if:
(a) The project design and/or location encourages wasteful, inefficient, and unnecessary consumption of energy, especially fossil fuels such as coal, natural gas, and petroleum, as well as the use of fuel by vehicles anticipated to travel to and from the project; or (b) The project design impedes the growth of future renewable energy developments.

Southern California Edison and the Southern California Gas Company would provide electricity and natural gas, respectively, for construction and operation of the proposed Project’s vicinity. While natural gas use is not proposed, CalEEMod’s default natural gas consumption was included for a conservative analysis of the Project. The following assumptions were used to calculate the energy (electricity, natural gas, and petroleum) consumption of the proposed Project:
• Construction equipment fuel consumption was derived from CARB OffRoad2025 emission model. • Fuel Consumption from vehicle travel was derived from CARB EMFAC2025 emission model. • Electrical and natural gas usage was derived from the CalEEMod model Version 2022.1.

The most recent version of CalEEMod (v 2022.1) for air quality and GHG emissions uses emission rates from EMFAC2021. However, to provide the most updated data for energy consumption, this analysis uses data from EMFAC2025, which was updated in May 2025.

Construction
Electricity and Natural Gas Usage
Due to the Project size and the fact that construction is temporary, the electricity used during construction of the proposed Project would be substantially less than that required for Project operation and would have a negligible contribution to the Project’s overall energy consumption. The electric power used during construction would be for as-necessary lighting and electronic equipment such as computers inside temporary construction trailers. Natural gas is not anticipated to be needed for construction activities. Any consumption of natural gas would be minor and negligible in comparison to the usage during the operation of the proposed Project. Since operation of the Project would result in a nominal increase in countywide electricity and natural gas consumption, as described below, construction energy consumption would in turn result in a less-than-significant impact to energy.

Petroleum Fuel Usage
The equipment associated with construction activities (off-road/heavy duty vehicles) would rely on diesel fuel as would vendor and haul trucks involved in delivering building materials and removing soil material from the Project site. Construction workers would travel to and from the Project site throughout the duration of construction, and for a conservative analysis, it is assumed that construction workers would travel in gasoline-powered passenger vehicles. It should be noted that total fuel consumption is a conservative analysis and would likely overstate the amount of fuel usage, as specific construction equipment is not expected to operate during the entire duration of the construction activity (i.e., crane). The trips included worker vehicles, vendor vehicles, and haul vehicles. Table 5, Total Construction Fuel Usage, shows the overall fuel consumption for Project construction, obtained from the CARB OffRoad 2025 emission model and the CARB EMFAC2025 583
North Tustin Street Project Air Quality, Energy, and GHG Impact Analysis 13 model. Detailed tables of fuel consumption by construction equipment and on-road vehicles can be found in Appendix D.

Table 5: Total Construction Fuel 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: Fuel Calculation Sheets (see Appendix D).

As shown in Table 5, 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. The data for Orange County can be found in Appendix D. 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, 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, the Project would not result in wasteful, inefficient, or unnecessary consumption of energy, and the proposed Project would result in lessthan-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 in this report. Electricity and natural gas consumption can be found in the CalEEMod Output Sheets attached (Appendix A). The gasoline consumption rates utilize the same assumptions that were used for the worker vehicles.

As previously mentioned, the Project would be required to install solar panels in accordance with Title 24, Part 6 requirements. The Project’s energy consumption, shown below in Table 6, Annual Project Operational Energy Requirements, presents a conservative estimate of energy consumption without taking credit for solar use.
584
North Tustin Street Project Air Quality, Energy, and GHG Impact Analysis 14 Table 6: Annual Project Operational Energy Requirements 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: CalEEMod Output Sheets (see Appendix A).

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 kilowatthours (California Energy Commission, 2023a) and natural gas consumption was estimated at 60,825,476,870 thousand British thermal units (California Energy Commission, 2023b). As shown in Table 6, Annual Project Operational Energy Requirements, 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. As previously shown in Table 5, gasoline consumption in Orange County in 2026 is estimated at 907,921,969 gallons (see Appendix D). Therefore, the proposed Project operations would account for 0.009 percent of gasoline fuel consumption in Orange County. Thus, the Project would not result in wasteful, inefficient, or unnecessary consumption of energy, and the Project would result in less-than-significant energy impacts during operation. No mitigation would be required.

Future Renewable Energy Developments
The proposed Project would be required to meet the CCR Title 24 energy efficiency standards in effect during permitting of proposed Project and comply with all applicable City energy codes. The City’s administration of the CCR Title 24 requirements includes review of design components and energy conservation measures during the permitting process, which ensures that all requirements are met. In addition, Project design and operation would comply with State Building Energy Efficiency Standards, appliance efficiency regulations, and green building standards. The Project buildings would install solar in compliance with current Title 24 requirements, which would further reduce energy consumption. As such, the Project would not inhibit the use of and would allow for future flexibility relating to renewable energy.

Conclusion
The Project’s energy consumption for construction activities related to development of the site for residential uses would be permitted to require compliance with existing fuel standards, machinery efficiency standards, and CARB requirements that limit idling of construction trucks and equipment. Construction activities related to the proposed Project and the associated infrastructure are not expected to result in demand for fuel greater on a per-unit-of-development basis than any other development projects in Southern California.

There are no unusual Project characteristics that would cause the use of construction equipment that would 585
North Tustin Street Project Air Quality, Energy, and GHG Impact Analysis 15 be less energy efficient compared with other similar construction sites in other parts of the state. Also, CCR Title 13, Motor Vehicles, section 2449(d)(3), Idling, limits idling times of construction vehicles to no more than 5 minutes, thereby precluding unnecessary and wasteful consumption of fuel due to unproductive idling of construction equipment. Construction and operation of the proposed Project would be required to meet the CCR Title 24 energy efficiency standards and comply with all applicable City energy codes. The Project would also install solar panels in compliance with current Title 24 requirements. Therefore, the construction and operation of the Project would result in a less-than-significant impact related to inefficient, wasteful, or unnecessary consumption of energy, and the Project would not inhibit the use of and would allow for future flexibility relating to renewable energy. No mitigation would be required. 586
North Tustin Street Project Air Quality, Energy, and GHG Impact Analysis 16 GREENHOUSE GAS EMISSIONS
Regulatory Background and Thresholds
California State Executive Order S-3-05, issued by Governor Arnold Schwarzenegger in June 2005, established comprehensive GHG reduction targets for the state (Executive Department State of California, 2005). It mandated reducing GHG emissions to 2000 levels by 2010, to 1990 levels by 2020, and to 80 percent below 1990 levels by 2050. This Executive Order laid the foundation for subsequent climate change mitigation efforts in California, including the development of various policies and programs aimed at reducing emissions across sectors such as transportation, energy, and industry. The objective of the Executive Order is to contribute to capping worldwide CO2 concentrations at 450 parts per million (ppm), stabilizing global climate change.

SCAQMD convened a GHG Emissions CEQA Significance Threshold Working Group to help lead agencies determine significance thresholds for GHG emissions when SCAQMD is not the lead agency. The last working group was held in September 2010 (Meeting No. 15) and proposed a tiered approach (Tier I to Tier V), equivalent to the existing consistency determination requirements in CEQA Guidelines Sections 15064(h)(3) or 15125(d) (South Coast Air Quality Management District, 2010). Tier III, which is applicable to the Project, is described in further detail below.

Tier III – Numerical Screening Thresholds
The SCAQMD’s draft threshold uses the Executive Order S-3-05 goal as the basis for the Tier III screening level. Tier III consists of screening values which the lead agency can choose from, but it 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 impact would be less than significant:
• Option 1, all land use types: 3,000 MTCO2e per year
• Option 2, based on land use type:
o Residential: 3,500 MTCO2e per year
o Commercial: 1,400 MTCO2e per year
o Mixed-use: 3,000 MTCO2e per year
Based on the foregoing guidance, the City has elected to rely on compliance with a local air district (SCAQMD) threshold in the determination of significance of Project-related GHG emissions, as stated in the City’s Guidance for Greenhouse Gas Emissions Analysis Memo. Specifically, the City has selected the interim 3,000 MTCO2e per year threshold for residential projects, recommended by SCAQMD staff against which to compare Project-related GHG emissions. Projects within the City should use the relevant threshold for its land use type and compare emissions to the City’s GHG inventory contained in the 2010 General Plan EIR or other available regional/local inventories (City of Orange, 2020).

The City understands that the 3,000 MTCO2e per year threshold was proposed by the 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 per year threshold was developed and recommended by the SCAQMD, an expert agency, based on substantial evidence as provided in the Draft Guidance Document – Interim CEQA Greenhouse Gas Significance Threshold document and subsequent Working Group meetings (latest of which occurred in 2010) (South Coast Air Quality Management District, 2008c). The 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 the SCAQMD, this threshold “uses the Executive Order 587
North Tustin Street Project Air Quality, Energy, and GHG Impact Analysis 17 S-3-05 goal (80 percent below 1990 levels by 2050) as the basis for deriving the screening level” and, thus, remains valid for use in year 2025 and for purposes of this analysis. Lastly, this threshold has been used for hundreds of GHG analyses performed for projects located within the SCAQMD’s jurisdiction.

Project GHG Emissions
The Project’s construction GHG emissions are shown in Table 7, Project Construction GHG Emissions, and the overall construction and operational emissions are shown in Table 8, Total Project GHG Emissions, below.

These emissions were calculated using the CalEEMod model. The construction emissions are amortized over 30 years and added to the operational GHG emissions. As shown in Table 8, the Project’s construction and operation GHG emissions would total 896 MTCO2e per year. As discussed in the Energy section, operation of the Project would not consume natural gas. However, this analysis includes CalEEMod’s default natural gas consumption assumptions. Therefore, GHG emissions resulting from natural gas usage as been included in Table 8.

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. In addition, the Project would not exceed SCAQMD’s 3,000 MTCO2e per year threshold. Therefore, impacts related to GHG emissions would be less than significant with no mitigation required.

Table 7: Project Construction GHG 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: CalEEMod Output Sheets (see Appendix A).
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North Tustin Street Project Air Quality, Energy, and GHG Impact Analysis 18 Table 8: Total Project GHG Emissions
Activity Annual GHG Emissions
(MTCO2e)
Mobile 629
Area 1
Energy 224
Water 7
Waste 18
Refrigeration <0.1
Gross Project Operation Emissions 879
Project Construction Emissions 16
Total Project Emissions 896
2004 GHG Emissions Inventory 2,072,493
Percent Increase 0.04
Tier III Significance Threshold 3,000
Threshold Exceeded? No
Note: Numbers have been rounded.

Source: CalEEMod Output Sheets (see Appendix A).

Project Consistency with Plans, Policies, and Regulations The City of Orange published the Guidance for Greenhouse Gas Emissions Analysis Memo to provide guidance for determining the significance of GHG impacts a project may have. According to this memo, project-specific analysis of GHG impacts must discuss consistency with the City’s General Plan Policies related to GHG reduction, the 2022 CARB Scoping Plan, and the most recent version of the SCAG RTP/SCS (City of Orange, 2020). As detailed below, the Project would not conflict with any local or regional GHG reduction plans.

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. Policies directly related to GHG reduction and energy efficiency for residential developments are discussed below in Table 9, City of Orange General Plan Consistency Summary. As shown below, the Project would not conflict with policies of the 2010 General Plan.
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North Tustin Street Project Air Quality, Energy, and GHG Impact Analysis 19 Table 9: City of Orange General Plan Consistency Summary Policy Consistency
Circulation & Mobility 3.3: Transit-oriented design
within commercial, employment, medium density
residential, and mixed-use areas.

No Conflict. 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.

No Conflict. 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.

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.

No Conflict. 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 electric heat pumps installed
during construction and electric hookups for all
appliances.

Infrastructure 4.4: Integrated and cost-effective
design and technology features within new
development.

Natural Resources 2.1: Implement and enforce
regional air quality management plans.

No Conflict. 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.

Natural Resources 2.3: Native and drought-tolerant
plants, proper soil preparation, and efficient
irrigation systems for landscaping.

No Conflict. The proposed Project would be planted
with drought-tolerant plants.

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.

No Conflict. As shown above in Table 8, the Project
would not exceed SCAQMD’s Tier III GHG threshold.

Therefore, the Project would not impede the City’s
ability to reduce GHG emissions.

Source: (City of Orange, 2015, pp. 24-30)
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North Tustin Street Project Air Quality, Energy, and GHG Impact Analysis 20 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 10, 2022 Scoping Plan Consistency Summary, below 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 10: 2022 Scoping Plan Consistency Summary
Action Consistency
GHG Emissions Reductions Relative to the SB 32 Target
40% Below 1990 levels by 2030. No Conflict. 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.

No Conflict. The Project proposes the development of a
medium density residential community. 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. No Conflict. 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), contributing to 6 million heat
pumps installed statewide by 2030.

No Conflict. The Project would comply with Title 24, Part 6 building energy requirements, which would require all inunit 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.

No Conflict. 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).

No Conflict. 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.
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North Tustin Street Project Air Quality, Energy, and GHG Impact Analysis 21 Action Consistency
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).

No Conflict. 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 mixeduse, walkable, and compact infill development (such as increasing allowable density of the neighborhood).

No Conflict. 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.

Local Action Policies - Building Decarbonization
Adopt all-electric new construction reach codes. No Conflict. 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 sensors, smart power
strips, equipment controllers, etc.).

No Conflict. 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.

Facilitate deployment of renewable energy
production and distribution and energy storage.

No Conflict. The proposed Project would be constructed in accordance with the CALGreen Building Energy Efficiency Standards (Title 24 Part 6) and meet all other requirements related to energy efficiency standards.

Source: (California Air Resources Board, 2022, pp. 72-79) SCAG Connect SoCal 2024
In addition, on April 4, 2024, SCAG’s Regional Council adopted Connect SoCal 2024, the 2024-2050 Regional Transportation Plan/Sustainable Communities Strategy, which includes long-range regional transportation plans, regional transportation improvement programs, regional housing needs allocations, and other plans for the region. SCAG’s Connect SoCal 2024 policies focus largely on regional transportation and the efficiency of transportation, which are implemented by counties and cities within the SCAG region, as part of the overall planning and maintenance of the regional transportation system. These strategies are also intended to reduce GHG emissions from passenger vehicles. As an individual development, the policies are not directly applicable to the Project. However, the proposed Project would not interfere with the implementation of these policies, since the Project would result in a medium density residential community pursuant to the current Title 24 standards.
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North Tustin Street Project Air Quality, Energy, and GHG Impact Analysis 22 Conclusion
As described above, the proposed Project’s construction and operational GHG emissions would total 896 MTCO2e, which would not exceed the SCAQMD’s significance Tier III threshold of 3,000 MTCO2e per year.

Additionally, the Project is consistent with the actions and measures of the City’s General Plan, CARB’s 2022 Scoping Plan, and SCAG Connect SoCal 2024, and would not interfere with the policies and goals in these plans. Therefore, the Project would have a less-than-significant impact related to GHG emissions. No mitigation would be required.
593
North Tustin Street Project Air Quality, Energy, and GHG Impact Analysis 23 REFERENCES
California Air Resources Board. (2022). 2022 Scoping Plan for Achieving Carbon Neutrality. Retrieved from https://ww2.arb.ca.gov/sites/default/files/2023-04/2022-sp.pdf California Energy Commission. (2023). CEQA Statues and Guidelines Attachment 10 Appendix :

Environmental Checklist Form. Retrieved from
https://www.energy.ca.gov/sites/default/files/2024-01/11_Attachment_10_- _Appendix_G_from_CEQA_Handbook_ada.docx
California Energy Commission. (2023a). Electricity Consumption. Retrieved from https://www.energy.ca.gov/data-reports/energy-almanac/california-electricity-data/californiaenergy-consumption-dashboards-0 California Energy Commission. (2023b). Natural Gas Consumption. Retrieved from https://www.energy.ca.gov/data-reports/energy-almanac/california-electricity-data/californiaenergy-consumption-dashboards-1 City of Orange. (2010, March). Orange General Plan Program Environmental Impact Report. Retrieved from https://www.cityoforange.org/home/showpublisheddocument/240/637698173340500000 City of Orange. (2015). Orange General Plan - Natural Resources. Retrieved from https://www.cityoforange.org/home/showpublisheddocument/210/637698172559270000 City of Orange. (2020). Guidance for Greenhouse Gas Emissions Analysis. Retrieved from https://www.cityoforange.org/home/showpublisheddocument/5729/638767809268670000 Department of Finance. (2025). E-5 Population and Housing Estimates for Cities, Counties, and the State, 2020-2025. Retrieved from https://dof.ca.gov/forecasting/demographics/estimates/e-5- population-and-housing-estimates-for-cities-counties-and-the-state-2020-2025/ EPD Solutions, Inc. (2025). Vehicle Miles Traveled (VMT) Screening Analysis - North Tustin Street Residential Project.

Executive Department State of California. (2005). Executive Order S-3-05. Retrieved from https://www.library.ca.gov/wp-content/uploads/GovernmentPublications/executive-orderproclamation/5129-5130.pdf South Coast Air Quality Management District. (2008a, July). Final Localized Significance Threshold Methodology. Retrieved from http://www.aqmd.gov/docs/defaultsource/ceqa/handbook/localized-significance-thresholds/final-lst-methodology-document.pdf South Coast Air Quality Management District. (2008b). Final Localized Significance Threshold Methodology Appendix C. Retrieved from https://www.aqmd.gov/docs/defaultsource/ceqa/handbook/localized-significance-thresholds/appendix-c-mass-rate-lst-look-uptables.pdf?sfvrsn=2.

South Coast Air Quality Management District. (2008c). Interim CEQA GHG Significance Threshold for Stationary Sources, Rules and Plans. Retrieved from https://www.aqmd.gov/docs/defaultsource/ceqa/handbook/greenhouse-gases-(ghg)-ceqa-significancethresholds/ghgboardsynopsis.pdf 594
North Tustin Street Project Air Quality, Energy, and GHG Impact Analysis 24 South Coast Air Quality Management District. (2010). Minutes for the GHG CEQA Significance Threshold Stakeholder Working Group #15. Retrieved from https://www.aqmd.gov/docs/defaultsource/ceqa/handbook/greenhouse-gases-(ghg)-ceqa-significance-thresholds/year-2008- 2009/ghg-meeting-15/ghg-meeting-15-minutes.pdf
South Coast Air Quality Management District. (2023, March). South Coast AQMD Air Quality Significance Thresholds. Retrieved from https://www.aqmd.gov/docs/default-source/ceqa/handbook/southcoast-aqmd-air-quality-significance-thresholds.pdf?sfvrsn=25 United States Environmental Protection Agency. (2005). 11.19.2 Crushed Stone Processing and Pulverized Mineral Processing. Retrieved from https://www.epa.gov/sites/default/files/2020- 10/documents/c11s1902.pdf
595
North Tustin Street Project Air Quality, Energy, and GHG Impact Analysis APPENDIX A: CALEEMOD OUTPUT SHEETS
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25-032 N Tustin Street Residential Detailed Report
Table of Contents

1. Basic Project Information

1.1. Basic Project Information

1.2. Land Use Types

1.3. User-Selected Emission Reduction Measures by Emissions Sector

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds

2.2. Construction Emissions by Year, Unmitigated

2.4. Operations Emissions Compared Against Thresholds

2.5. Operations Emissions by Sector, Unmitigated

3. Construction Emissions Details

3.1. Demolition (2026) - Unmitigated

3.3. Site Preparation (2026) - Unmitigated

3.5. Grading (2026) - Unmitigated

3.7. Building Construction (2026) - Unmitigated

3.9. Building Construction (2027) - Unmitigated
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3.11. Paving (2027) - Unmitigated

3.13. Architectural Coating (2027) - Unmitigated

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated

4.2.3. Natural Gas Emissions By Land Use - Unmitigated

4.3. Area Emissions by Source

4.3.1. Unmitigated

4.4. Water Emissions by Land Use

4.4.1. Unmitigated

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated

4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated
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4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated

5. Activity Data

5.1. Construction Schedule

5.2. Off-Road Equipment

5.2.1. Unmitigated

5.3. Construction Vehicles

5.3.1. Unmitigated

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies

5.5. Architectural Coatings

5.6. Dust Mitigation
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5.6.1. Construction Earthmoving Activities

5.6.2. Construction Earthmoving Control Strategies

5.7. Construction Paving

5.8. Construction Electricity Consumption and Emissions Factors

5.9. Operational Mobile Sources

5.9.1. Unmitigated

5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated

5.10.2. Architectural Coatings

5.10.3. Landscape Equipment

5.11. Operational Energy Consumption

5.11.1. Unmitigated

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated

5.13. Operational Waste Generation

5.13.1. Unmitigated

5.14. Operational Refrigeration and Air Conditioning Equipment 600
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5.14.1. Unmitigated

5.15. Operational Off-Road Equipment

5.15.1. Unmitigated

5.16. Stationary Sources

5.16.1. Emergency Generators and Fire Pumps

5.16.2. Process Boilers

5.17. User Defined

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated

5.18.2. Sequestration

5.18.2.1. Unmitigated

6. Climate Risk Detailed Report

6.1. Climate Risk Summary

6.2. Initial Climate Risk Scores

6.3. Adjusted Climate Risk Scores
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6.4. Climate Risk Reduction Measures

7. Health and Equity Details

7.1. CalEnviroScreen 4.0 Scores

7.2. Healthy Places Index Scores

7.3. Overall Health & Equity Scores

7.4. Health & Equity Measures

7.5. Evaluation Scorecard

7.6. Health & Equity Custom Measures

8. User Changes to Default Data
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1. Basic Project Information

1.1. Basic Project Information
Data Field Value
Project Name 25-032 N Tustin Street Residential
Construction Start Date 9/1/2026
Operational Year 2027
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s) 1.80
Precipitation (days) 21.2
Location 33.827949174634625, -117.83443813400079
County Orange
City Orange
Air District South Coast AQMD
Air Basin South Coast
TAZ 5774
EDFZ 7
Electric Utility Southern California Edison
Gas Utility Southern California Gas
App Version 2022.1.1.30

1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) Landscape Area (sq ft)
Special Landscape
Area (sq ft)
Population Description
Single Family
Housing

71.0 Dwelling Unit 2.30 188,155 38,834 1,835 212 —
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Parking Lot 38.0 Space 0.34 0.00 0.00 — — —
Other Asphalt
Surfaces

1.77 Acre 1.59 0.00 0.00 — — —

1.3. User-Selected Emission Reduction Measures by Emissions Sector No measures selected

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Unmit. 3.90 34.7 32.1 0.07 7.69 4.37 9,507
Daily, Winter (Max) — — — — — — —
Unmit. 66.9 34.7 31.9 0.08 7.69 4.37 11,595
Average Daily (Max) — — — — — — —
Unmit. 3.94 5.56 8.12 0.01 0.73 0.29 1,670
Annual (Max) — — — — — — —
Unmit. 0.72 1.01 1.48 < 0.005 0.13 0.05 277
Exceeds (Daily Max) — — — — — — —
Threshold 75.0 100 550 150 150 55.0 —
Unmit. No No No No No No —
Exceeds (Average
Daily)
— — — — — — —
Threshold 75.0 100 550 150 150 55.0 —
Unmit. No No No No No No —

2.2. Construction Emissions by Year, Unmitigated
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Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Year ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily - Summer (Max) — — — — — — —
2026 3.90 34.7 32.1 0.07 7.69 4.37 9,507
2027 1.19 10.5 15.4 0.03 0.77 0.43 3,215
Daily - Winter (Max) — — — — — — —
2026 3.90 34.7 31.9 0.08 7.69 4.37 11,595
2027 66.9 10.5 15.2 0.03 0.77 0.43 3,197
Average Daily — — — — — — —
2026 0.41 4.20 4.41 0.01 0.73 0.29 1,313
2027 3.94 5.56 8.12 0.01 0.40 0.23 1,670
Annual — — — — — — —
2026 0.08 0.77 0.80 < 0.005 0.13 0.05 217
2027 0.72 1.01 1.48 < 0.005 0.07 0.04 277

2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Unmit. 6.67 2.13 21.0 0.05 4.39 1.17 6,134
Daily, Winter (Max) — — — — — — —
Unmit. 6.30 2.22 15.7 0.05 4.39 1.17 5,937
Average Daily (Max) — — — — — — —
Unmit. 6.24 2.02 16.4 0.04 3.68 0.99 5,310
Annual (Max) — — — — — — —
Unmit. 1.14 0.37 3.00 0.01 0.67 0.18 879
Exceeds (Daily Max) — — — — — — —
Threshold 55.0 55.0 550 150 150 55.0 —
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Unmit. No No No No No No —
Exceeds (Average
Daily)
— — — — — — —
Threshold 55.0 55.0 550 150 150 55.0 —
Unmit. No No No No No No —
Exceeds (Annual) — — — — — — —
Threshold — — — — — — 3,000
Unmit. — — — — — — No

2.5. Operations Emissions by Sector, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Mobile 1.91 1.41 16.6 0.04 4.33 1.12 4,619
Area 4.72 0.04 4.03 < 0.005 < 0.005 < 0.005 10.8
Energy 0.04 0.69 0.29 < 0.005 0.06 0.06 1,354
Water — — — — — — 42.4
Waste — — — — — — 106
Refrig. — — — — — — 1.35
Total 6.67 2.13 21.0 0.05 4.39 1.17 6,134
Daily, Winter (Max) — — — — — — —
Mobile 1.89 1.53 15.4 0.04 4.33 1.12 4,433
Area 4.36 0.00 0.00 0.00 0.00 0.00 0.00
Energy 0.04 0.69 0.29 < 0.005 0.06 0.06 1,354
Water — — — — — — 42.4
Waste — — — — — — 106
Refrig. — — — — — — 1.35
Total 6.30 2.22 15.7 0.05 4.39 1.17 5,937
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Average Daily — — — — — — —
Mobile 1.59 1.31 13.4 0.04 3.62 0.93 3,799
Area 4.60 0.03 2.76 < 0.005 < 0.005 < 0.005 7.40
Energy 0.04 0.69 0.29 < 0.005 0.06 0.06 1,354
Water — — — — — — 42.4
Waste — — — — — — 106
Refrig. — — — — — — 1.35
Total 6.24 2.02 16.4 0.04 3.68 0.99 5,310
Annual — — — — — — —
Mobile 0.29 0.24 2.44 0.01 0.66 0.17 629
Area 0.84 < 0.005 0.50 < 0.005 < 0.005 < 0.005 1.23
Energy 0.01 0.13 0.05 < 0.005 0.01 0.01 224
Water — — — — — — 7.03
Waste — — — — — — 17.6
Refrig. — — — — — — 0.22
Total 1.14 0.37 3.00 0.01 0.67 0.18 879

3. Construction Emissions Details

3.1. Demolition (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e
Onsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Off-Road Equipment 2.29 20.7 19.0 0.03 0.84 0.78 3,438
Demolition — — — — 4.41 0.67 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max) — — — — — — —
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Average Daily — — — — — — —
Off-Road Equipment 0.13 1.13 1.04 < 0.005 0.05 0.04 188 Demolition — — — — 0.24 0.04 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Off-Road Equipment 0.02 0.21 0.19 < 0.005 0.01 0.01 31.2 Demolition — — — — 0.04 0.01 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Worker 0.05 0.05 0.79 0.00 0.20 0.05 198
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.08 6.67 2.95 0.04 1.55 0.49 5,870
Daily, Winter (Max) — — — — — — —
Average Daily — — — — — — —
Worker < 0.005 < 0.005 0.04 0.00 0.01 < 0.005 10.5
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 0.38 0.16 < 0.005 0.08 0.03 321
Annual — — — — — — —
Worker < 0.005 < 0.005 0.01 0.00 < 0.005 < 0.005 1.73
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 0.07 0.03 < 0.005 0.02 < 0.005 53.2

3.3. Site Preparation (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e
Onsite — — — — — — —
Daily, Summer (Max) — — — — — — —
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Off-Road Equipment 3.83 34.6 31.0 0.05 1.77 1.62 5,551
Dust From Material
Movement
———— 5.66 2.69—
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max)———————
Off-Road Equipment 3.83 34.6 31.0 0.05 1.77 1.62 5,551
Dust From Material
Movement
———— 5.66 2.69—
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily———————
Off-Road Equipment 0.05 0.47 0.42 < 0.005 0.02 0.02 76.0 Dust From Material
Movement
———— 0.08 0.04—
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual———————
Off-Road Equipment 0.01 0.09 0.08 < 0.005 < 0.005 < 0.005 12.6 Dust From Material
Movement
———— 0.01 0.01—
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite———————
Daily, Summer (Max)———————
Worker 0.07 0.06 1.05 0.00 0.26 0.06 264
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max)———————
Worker 0.07 0.07 0.91 0.00 0.26 0.06 251
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily———————
Worker < 0.005 < 0.005 0.01 0.00 < 0.005 < 0.005 3.49
609
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Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.58 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00

3.5. Grading (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e
Onsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Daily, Winter (Max) — — — — — — —
Off-Road Equipment 2.16 19.1 19.1 0.03 1.04 0.96 3,146
Dust From Material
Movement
— — — — 2.26 0.94 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — —
Off-Road Equipment 0.05 0.42 0.42 < 0.005 0.02 0.02 68.9 Dust From Material
Movement
— — — — 0.05 0.02 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Off-Road Equipment 0.01 0.08 0.08 < 0.005 < 0.005 < 0.005 11.4 Dust From Material
Movement
— — — — 0.01 < 0.005 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite — — — — — — —
Daily, Summer (Max) — — — — — — —
610
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Daily, Winter (Max) — — — — — — —
Worker 0.05 0.05 0.68 0.00 0.20 0.05 188
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.11 9.73 4.19 0.05 2.18 0.68 8,261
Average Daily — — — — — — —
Worker < 0.005 < 0.005 0.02 0.00 < 0.005 < 0.005 4.18
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 0.22 0.09 < 0.005 0.05 0.01 181
Annual — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.69 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 0.04 0.02 < 0.005 0.01 < 0.005 30.0

3.7. Building Construction (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e
Onsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Daily, Winter (Max) — — — — — — —
Off-Road Equipment 1.16 10.7 14.1 0.03 0.41 0.38 2,639
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — —
Off-Road Equipment 0.17 1.52 2.01 < 0.005 0.06 0.05 377 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Off-Road Equipment 0.03 0.28 0.37 < 0.005 0.01 0.01 62.4 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite — — — — — — —
611
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Daily, Summer (Max) — — — — — — —
Daily, Winter (Max) — — — — — — —
Worker 0.09 0.09 1.16 0.00 0.33 0.08 321
Vendor < 0.005 0.25 0.12 < 0.005 0.07 0.02 248
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — —
Worker 0.01 0.01 0.17 0.00 0.05 0.01 46.5
Vendor < 0.005 0.04 0.02 < 0.005 0.01 < 0.005 35.5
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Worker < 0.005 < 0.005 0.03 0.00 0.01 < 0.005 7.69
Vendor < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 5.88 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00

3.9. Building Construction (2027) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e
Onsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Off-Road Equipment 1.11 10.2 14.0 0.03 0.36 0.34 2,639
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max) — — — — — — —
Off-Road Equipment 1.11 10.2 14.0 0.03 0.36 0.34 2,639
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — —
Off-Road Equipment 0.54 4.98 6.87 0.01 0.18 0.16 1,291
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
612
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Off-Road Equipment 0.10 0.91 1.25 < 0.005 0.03 0.03 214 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Worker 0.07 0.08 1.26 0.00 0.33 0.08 332
Vendor < 0.005 0.23 0.12 < 0.005 0.07 0.02 244
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max) — — — — — — —
Worker 0.07 0.08 1.09 0.00 0.33 0.08 315
Vendor < 0.005 0.24 0.12 < 0.005 0.07 0.02 244
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — —
Worker 0.04 0.04 0.55 0.00 0.16 0.04 156
Vendor < 0.005 0.12 0.06 < 0.005 0.03 0.01 119
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Worker 0.01 0.01 0.10 0.00 0.03 0.01 25.9
Vendor < 0.005 0.02 0.01 < 0.005 0.01 < 0.005 19.7
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00

3.11. Paving (2027) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e
Onsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Off-Road Equipment 0.81 7.29 10.4 0.02 0.29 0.27 1,604
Paving 0.28 — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
613
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Daily, Winter (Max)———————
Off-Road Equipment 0.81 7.29 10.4 0.02 0.29 0.27 1,604
Paving 0.28——————
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily———————
Off-Road Equipment 0.04 0.36 0.52 < 0.005 0.01 0.01 79.1 Paving 0.01——————
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual———————
Off-Road Equipment 0.01 0.07 0.09 < 0.005 < 0.005 < 0.005 13.1 Paving < 0.005——————
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite———————
Daily, Summer (Max)———————
Worker 0.06 0.06 0.99 0.00 0.26 0.06 260
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max)———————
Worker 0.06 0.06 0.85 0.00 0.26 0.06 247
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily———————
Worker < 0.005 < 0.005 0.04 0.00 0.01 < 0.005 12.3
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual———————
Worker < 0.005 < 0.005 0.01 0.00 < 0.005 < 0.005 2.04
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
614
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Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00

3.13. Architectural Coating (2027) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e
Onsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Daily, Winter (Max) — — — — — — —
Off-Road Equipment 0.15 1.11 1.50 < 0.005 0.03 0.02 179 Architectural Coatings 66.7 — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — —
Off-Road Equipment 0.01 0.05 0.07 < 0.005 < 0.005 < 0.005 8.81 Architectural Coatings 3.29 — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Off-Road Equipment < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 1.46 Architectural Coatings 0.60 — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Daily, Winter (Max) — — — — — — —
Worker 0.01 0.02 0.22 0.00 0.07 0.02 63.0
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — —
Worker < 0.005 < 0.005 0.01 0.00 < 0.005 < 0.005 3.15
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
615
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Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.52 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Single Family Housing 1.91 1.41 16.6 0.04 4.33 1.12 4,619 Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Other Asphalt
Surfaces

0.00 0.00 0.00 0.00 0.00 0.00 0.00
Total 1.91 1.41 16.6 0.04 4.33 1.12 4,619
Daily, Winter (Max) — — — — — — —
Single Family Housing 1.89 1.53 15.4 0.04 4.33 1.12 4,433 Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Other Asphalt
Surfaces

0.00 0.00 0.00 0.00 0.00 0.00 0.00
Total 1.89 1.53 15.4 0.04 4.33 1.12 4,433
Annual — — — — — — —
Single Family Housing 0.29 0.24 2.44 0.01 0.66 0.17 629 Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00
616
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Other Asphalt 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Surfaces
Total 0.29 0.24 2.44 0.01 0.66 0.17 629

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Single Family Housing — — — — — — 467
Parking Lot — — — — — — 12.5
Other Asphalt
Surfaces
— — — — — — 0.00
Total — — — — — — 479
Daily, Winter (Max) — — — — — — —
Single Family Housing — — — — — — 467
Parking Lot — — — — — — 12.5
Other Asphalt
Surfaces
— — — — — — 0.00
Total — — — — — — 479
Annual — — — — — — —
Single Family Housing — — — — — — 77.3
Parking Lot — — — — — — 2.06
Other Asphalt
Surfaces
— — — — — — 0.00
Total — — — — — — 79.4

4.2.3. Natural Gas Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) 617 25-032 N Tustin Street Residential Detailed Report, 9/30/2025 22 / 43
Land Use ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Single Family Housing 0.04 0.69 0.29 < 0.005 0.06 0.06 875 Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Other Asphalt
Surfaces

0.00 0.00 0.00 0.00 0.00 0.00 0.00
Total 0.04 0.69 0.29 < 0.005 0.06 0.06 875
Daily, Winter (Max) — — — — — — —
Single Family Housing 0.04 0.69 0.29 < 0.005 0.06 0.06 875 Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Other Asphalt
Surfaces

0.00 0.00 0.00 0.00 0.00 0.00 0.00
Total 0.04 0.69 0.29 < 0.005 0.06 0.06 875
Annual — — — — — — —
Single Family Housing 0.01 0.13 0.05 < 0.005 0.01 0.01 145 Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Other Asphalt
Surfaces

0.00 0.00 0.00 0.00 0.00 0.00 0.00
Total 0.01 0.13 0.05 < 0.005 0.01 0.01 145

4.3. Area Emissions by Source

4.3.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Source ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Hearths 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Consumer Products 4.03 — — — — — —
Architectural Coatings 0.33 — — — — — —
618
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Landscape Equipment 0.35 0.04 4.03 < 0.005 < 0.005 < 0.005 10.8 Total 4.72 0.04 4.03 < 0.005 < 0.005 < 0.005 10.8
Daily, Winter (Max) — — — — — — —
Hearths 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Consumer Products 4.03 — — — — — —
Architectural Coatings 0.33 — — — — — —
Total 4.36 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Hearths 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Consumer Products 0.74 — — — — — —
Architectural Coatings 0.06 — — — — — —
Landscape Equipment 0.04 < 0.005 0.50 < 0.005 < 0.005 < 0.005 1.23 Total 0.84 < 0.005 0.50 < 0.005 < 0.005 < 0.005 1.23

4.4. Water Emissions by Land Use

4.4.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Single Family Housing — — — — — — 42.4
Parking Lot — — — — — — 0.00
Other Asphalt
Surfaces
— — — — — — 0.00
Total — — — — — — 42.4
Daily, Winter (Max) — — — — — — —
Single Family Housing — — — — — — 42.4
Parking Lot — — — — — — 0.00
619
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Other Asphalt — — — — — — 0.00
Surfaces
Total — — — — — — 42.4
Annual — — — — — — —
Single Family Housing — — — — — — 7.03
Parking Lot — — — — — — 0.00
Other Asphalt
Surfaces
— — — — — — 0.00
Total — — — — — — 7.03

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Single Family Housing — — — — — — 106
Parking Lot — — — — — — 0.00
Other Asphalt
Surfaces
— — — — — — 0.00
Total — — — — — — 106
Daily, Winter (Max) — — — — — — —
Single Family Housing — — — — — — 106
Parking Lot — — — — — — 0.00
Other Asphalt
Surfaces
— — — — — — 0.00
Total — — — — — — 106
Annual — — — — — — —
Single Family Housing — — — — — — 17.6
Parking Lot — — — — — — 0.00
620
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Other Asphalt
Surfaces
— — — — — — 0.00
Total — — — — — — 17.6

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Single Family Housing — — — — — — 1.35
Total — — — — — — 1.35
Daily, Winter (Max) — — — — — — —
Single Family Housing — — — — — — 1.35
Total — — — — — — 1.35
Annual — — — — — — —
Single Family Housing — — — — — — 0.22
Total — — — — — — 0.22

4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipment Type ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Total — — — — — — —
Daily, Winter (Max) — — — — — — —
Total — — — — — — —
Annual — — — — — — —
621
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Total — — — — — — —

4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipment Type ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Total — — — — — — —
Daily, Winter (Max) — — — — — — —
Total — — — — — — —
Annual — — — — — — —
Total — — — — — — —

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipment Type ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Total — — — — — — —
Daily, Winter (Max) — — — — — — —
Total — — — — — — —
Annual — — — — — — —
Total — — — — — — —

4.10. Soil Carbon Accumulation By Vegetation Type
622
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4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetation ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Total — — — — — — —
Daily, Winter (Max) — — — — — — —
Total — — — — — — —
Annual — — — — — — —
Total — — — — — — —

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Total — — — — — — —
Daily, Winter (Max) — — — — — — —
Total — — — — — — —
Annual — — — — — — —
Total — — — — — — —

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Avoided — — — — — — —
Subtotal — — — — — — —
Sequestered — — — — — — —
623
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Subtotal — — — — — — —
Removed — — — — — — —
Subtotal — — — — — — —
— — — — — — — —
Daily, Winter (Max) — — — — — — —
Avoided — — — — — — —
Subtotal — — — — — — —
Sequestered — — — — — — —
Subtotal — — — — — — —
Removed — — — — — — —
Subtotal — — — — — — —
— — — — — — — —
Annual — — — — — — —
Avoided — — — — — — —
Subtotal — — — — — — —
Sequestered — — — — — — —
Subtotal — — — — — — —
Removed — — — — — — —
Subtotal — — — — — — —
— — — — — — — —

5. Activity Data

5.1. Construction Schedule
Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase Description Demolition Demolition 9/1/2026 9/29/2026 5.00 20.0 —
Site Preparation Site Preparation 9/30/2026 10/7/2026 5.00 5.00 — Grading Grading 10/8/2026 10/19/2026 5.00 8.00 —
624
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Building Construction Building Construction 10/20/2026 9/7/2027 5.00 230 — Paving Paving 9/8/2027 10/3/2027 5.00 18.0 —
Architectural Coating Architectural Coating 10/4/2027 10/29/2027 5.00 18.0 —

5.2. Off-Road Equipment

5.2.1. Unmitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Demolition Concrete/Industrial
Saws
Diesel Average 1.00 8.00 33.0 0.73
Demolition Rubber Tired Dozers Diesel Average 2.00 8.00 367 0.40 Demolition Excavators Diesel Average 3.00 8.00 36.0 0.38 Demolition Crushing/Proc.

Equipment
Diesel Average 1.00 8.00 200 0.60
Site Preparation Rubber Tired Dozers Diesel Average 3.00 8.00 367 0.40 Site Preparation Tractors/Loaders/Back
hoes
Diesel Average 0.00 8.00 84.0 0.37
Site Preparation Crawler Tractors Diesel Average 4.00 8.00 87.0 0.43 Grading Graders Diesel Average 1.00 8.00 148 0.41
Grading Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40 Grading Tractors/Loaders/Back
hoes
Diesel Average 0.00 8.00 84.0 0.37
Grading Crawler Tractors Diesel Average 3.00 8.00 87.0 0.43 Grading Excavators Diesel Average 1.00 8.00 36.0 0.38
Building Construction Cranes Diesel Average 1.00 8.00 367 0.29 Building Construction Forklifts Diesel Average 3.00 8.00 82.0 0.20 Building Construction Generator Sets Diesel Average 1.00 8.00 14.0 0.74 Building Construction Tractors/Loaders/Back
hoes
Diesel Average 3.00 8.00 84.0 0.37
Building Construction Welders Diesel Average 1.00 8.00 46.0 0.45 625
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Paving Pavers Diesel Average 1.00 8.00 81.0 0.42
Paving Paving Equipment Diesel Average 2.00 8.00 89.0 0.36 Paving Rollers Diesel Average 2.00 8.00 36.0 0.38
Paving Cement and Mortar
Mixers
Diesel Average 2.00 8.00 10.0 0.56
Paving Tractors/Loaders/Back
hoes
Diesel Average 1.00 8.00 84.0 0.37
Architectural Coating Air Compressors Diesel Average 1.00 8.00 37.0 0.48

5.3. Construction Vehicles

5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Demolition — — — —
Demolition Worker 15.0 18.5 LDA,LDT1,LDT2
Demolition Vendor — 10.2 HHDT,MHDT
Demolition Hauling 81.5 20.0 HHDT
Demolition Onsite truck — — HHDT
Site Preparation — — — —
Site Preparation Worker 20.0 18.5 LDA,LDT1,LDT2
Site Preparation Vendor — 10.2 HHDT,MHDT
Site Preparation Hauling 0.00 20.0 HHDT
Site Preparation Onsite truck — — HHDT
Grading — — — —
Grading Worker 15.0 18.5 LDA,LDT1,LDT2
Grading Vendor — 10.2 HHDT,MHDT
Grading Hauling 115 20.0 HHDT
Grading Onsite truck — — HHDT
Building Construction — — — —
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Building Construction Worker 25.6 18.5 LDA,LDT1,LDT2
Building Construction Vendor 7.59 10.2 HHDT,MHDT
Building Construction Hauling 0.00 20.0 HHDT
Building Construction Onsite truck — — HHDT
Paving — — — —
Paving Worker 20.0 18.5 LDA,LDT1,LDT2
Paving Vendor — 10.2 HHDT,MHDT
Paving Hauling 0.00 20.0 HHDT
Paving Onsite truck — — HHDT
Architectural Coating — — — —
Architectural Coating Worker 5.11 18.5 LDA,LDT1,LDT2
Architectural Coating Vendor — 10.2 HHDT,MHDT
Architectural Coating Hauling 0.00 20.0 HHDT
Architectural Coating Onsite truck — — HHDT

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies
Non-applicable. No control strategies activated by user.

5.5. Architectural Coatings
Phase Name Residential Interior Area
Coated (sq ft)
Residential Exterior Area
Coated (sq ft)
Non-Residential Interior Area
Coated (sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
Architectural Coating 381,014 127,005 0.00 0.00 5,057

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities
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Phase Name Material Imported (cy) Material Exported (cy) Acres Graded (acres) Material Demolished (Ton of Acres Paved (acres) Debris)
Demolition 0.00 0.00 0.00 6,520 —
Site Preparation — — 17.5 0.00 —
Grading — 7,350 50.0 0.00 —
Paving 0.00 0.00 0.00 0.00 2.72

5.6.2. Construction Earthmoving Control Strategies
Control Strategies Applied Frequency (per day) PM10 Reduction PM2.5 Reduction Water Exposed Area 3 74% 74%
Water Demolished Area 2 36% 36%

5.7. Construction Paving
Land Use Area Paved (acres) % Asphalt
Single Family Housing 0.78 0%
Parking Lot 0.34 100%
Other Asphalt Surfaces 1.59 100%

5.8. Construction Electricity Consumption and Emissions Factors kWh per Year and Emission Factor (lb/MWh)
Year kWh per Year CO2 CH4 N2O
2026 0.00 346 0.03 < 0.005
2027 0.00 346 0.03 < 0.005

5.9. Operational Mobile Sources

5.9.1. Unmitigated
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Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year Single Family
Housing
511 622 509 192,252 5,002 6,086 4,981 1,881,157
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Other Asphalt
Surfaces

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated
Hearth Type Unmitigated (number)
Single Family Housing —
Wood Fireplaces 0
Gas Fireplaces 0
Propane Fireplaces 0
Electric Fireplaces 0
No Fireplaces 71
Conventional Wood Stoves 0
Catalytic Wood Stoves 0
Non-Catalytic Wood Stoves 0
Pellet Wood Stoves 0

5.10.2. Architectural Coatings
Residential Interior Area Coated (sq
ft)
Residential Exterior Area Coated (sq
ft)
Non-Residential Interior Area Coated
(sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
381013.875 127,005 0.00 0.00 5,057
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5.10.3. Landscape Equipment
Season Unit Value
Snow Days day/yr 0.00
Summer Days day/yr 250

5.11. Operational Energy Consumption

5.11.1. Unmitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr) CO2 CH4 N2O Natural Gas (kBTU/yr) Single Family Housing 489,555 346 0.0330 0.0040 2,721,810 Parking Lot 13,050 346 0.0330 0.0040 0.00
Other Asphalt Surfaces 0.00 346 0.0330 0.0040 0.00

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated
Land Use Indoor Water (gal/year) Outdoor Water (gal/year) Single Family Housing 2,664,321 638,931
Parking Lot 0.00 0.00
Other Asphalt Surfaces 0.00 0.00

5.13. Operational Waste Generation

5.13.1. Unmitigated
Land Use Waste (ton/year) Cogeneration (kWh/year)
Single Family Housing 56.2 —
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Parking Lot 0.00 —
Other Asphalt Surfaces 0.00 —

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated
Land Use Type Equipment Type Refrigerant GWP Quantity (kg) Operations Leak Rate Service Leak Rate Times Serviced Single Family Housing Average room A/C &
Other residential A/C
and heat pumps
R-410A 2,088 < 0.005 2.50 2.50 10.0
Single Family Housing Household
refrigerators and/or
freezers
R-134a 1,430 0.12 0.60 0.00 1.00

5.15. Operational Off-Road Equipment

5.15.1. Unmitigated
Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor

5.16. Stationary Sources

5.16.1. Emergency Generators and Fire Pumps
Equipment Type Fuel Type Number per Day Hours per Day Hours per Year Horsepower Load Factor

5.16.2. Process Boilers
Equipment Type Fuel Type Number Boiler Rating (MMBtu/hr) Daily Heat Input (MMBtu/day) Annual Heat Input (MMBtu/yr)

5.17. User Defined
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Equipment Type Fuel Type

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres

5.18.2. Sequestration

5.18.2.1. Unmitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)

6. Climate Risk Detailed Report

6.1. Climate Risk Summary
Cal-Adapt midcentury 2040–2059 average projections for four hazards are reported below for your project location. These are under Representation Concentration Pathway (RCP) 8.5 which assumes GHG emissions will continue to rise strongly through 2050 and then plateau around 2100.

Climate Hazard Result for Project Location Unit
Temperature and Extreme Heat 13.1 annual days of extreme heat Extreme Precipitation 4.30 annual days with precipitation above 20 mm Sea Level Rise — meters of inundation depth
Wildfire 0.00 annual hectares burned 632
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Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from observed historical data (32 climate model ensemble from Cal-Adapt, 2040–2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about ¾ an inch of rain, which would be light to moderate rainfall if received over a full day or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Sea Level Rise data are for the grid cell in which your project are located. The projections are from Radke et al. (2017), as reported in Cal-Adapt (Radke et al., 2017, CEC-500-2017-008), and consider inundation location and depth for the San Francisco Bay, the Sacramento-San Joaquin River Delta and California coast resulting different increments of sea level rise coupled with extreme storm events. Users may select from four scenarios to view the range in potential inundation depth for the grid cell. The four scenarios are: No rise, 0.5 meter, 1.0 meter, 1.41 meters Wildfire data are for the grid cell in which your project are located. The projections are from UC Davis, as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider historical data of climate, vegetation, population density, and large (> 400 ha) fire history. Users may select from four model simulations to view the range in potential wildfire probabilities for the grid cell. The four simulations make different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature possibilities (MIROC5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

6.2. Initial Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat 1 0 0 N/A
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise 1 0 0 N/A
Wildfire 1 0 0 N/A
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation 0 0 0 N/A
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.

The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores do not include implementation of climate risk reduction measures.

6.3. Adjusted Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat 1 1 1 2
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise 1 1 1 2
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Wildfire 1 1 1 2
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation 1 1 1 2
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores include implementation of climate risk reduction measures.

6.4. Climate Risk Reduction Measures

7. Health and Equity Details

7.1. CalEnviroScreen 4.0 Scores
The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state.

Indicator Result for Project Census Tract
Exposure Indicators —
AQ-Ozone 55.4
AQ-PM 77.1
AQ-DPM 65.0
Drinking Water 54.6
Lead Risk Housing 24.6
Pesticides 46.3
Toxic Releases 95.8
Traffic 83.2
Effect Indicators —
CleanUp Sites 0.00
Groundwater 14.3 634
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Haz Waste Facilities/Generators 70.9
Impaired Water Bodies 0.00
Solid Waste 9.67
Sensitive Population —
Asthma 12.9
Cardio-vascular 10.5
Low Birth Weights 32.3
Socioeconomic Factor Indicators —
Education 37.6
Housing 21.1
Linguistic 49.6
Poverty 5.92
Unemployment 41.8

7.2. Healthy Places Index Scores
The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.

Indicator Result for Project Census Tract
Economic —
Above Poverty 82.93340177
Employed 61.27293725
Median HI 86.71885025
Education —
Bachelor's or higher 83.65199538
High school enrollment 100
Preschool enrollment 83.44668292
Transportation —
Auto Access 97.49775439
Active commuting 54.36930579
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Social—
2-parent households 43.48774541
Voting 69.85756448
Neighborhood—
Alcohol availability 65.1353779
Park access 23.41845246
Retail density 55.74233286
Supermarket access 50.09624022
Tree canopy 63.41588605
Housing—
Homeownership 88.14320544
Housing habitability 83.54933915
Low-inc homeowner severe housing cost burden 51.27678686 Low-inc renter severe housing cost burden 52.73963814
Uncrowded housing 93.44283331
Health Outcomes—
Insured adults 74.11779802
Arthritis 14.6
Asthma ER Admissions 90.1
High Blood Pressure 17.2
Cancer (excluding skin) 8.0
Asthma 55.1
Coronary Heart Disease 23.5
Chronic Obstructive Pulmonary Disease 35.3
Diagnosed Diabetes 60.0
Life Expectancy at Birth 68.0
Cognitively Disabled 88.7
Physically Disabled 78.7
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Heart Attack ER Admissions 89.9
Mental Health Not Good 73.6
Chronic Kidney Disease 35.4
Obesity 86.4
Pedestrian Injuries 47.9
Physical Health Not Good 65.0
Stroke 39.4
Health Risk Behaviors—
Binge Drinking 43.3
Current Smoker 73.9
No Leisure Time for Physical Activity 69.0
Climate Change Exposures—
Wildfire Risk 1.5
SLR Inundation Area 0.0
Children 86.0
Elderly 25.4
English Speaking 77.9
Foreign-born 53.6
Outdoor Workers 45.8
Climate Change Adaptive Capacity—
Impervious Surface Cover 52.6
Traffic Density 89.1
Traffic Access 55.4
Other Indices—
Hardship 20.8
Other Decision Support—
2016 Voting 85.2
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7.3. Overall Health & Equity Scores
Metric Result for Project Census Tract
CalEnviroScreen 4.0 Score for Project Location (a) 26.0 Healthy Places Index Score for Project Location (b) 83.0 Project Located in a Designated Disadvantaged Community (Senate Bill 535) No Project Located in a Low-Income Community (Assembly Bill 1550) No Project Located in a Community Air Protection Program Community (Assembly Bill 617) No a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.

7.4. Health & Equity Measures
No Health & Equity Measures selected.

7.5. Evaluation Scorecard
Health & Equity Evaluation Scorecard not completed.

7.6. Health & Equity Custom Measures
No Health & Equity Custom Measures created.

8. User Changes to Default Data
Screen Justification
Land Use Adjusted lot acreage values to match site plan.

Construction: Off-Road Equipment Conservatively assumed all equipment would run 8 hours a day. Replaced tractors/loaders/backhoes with crawler tractors to accurately assess site disturbance in the site preparation and grading phases. Added 1 crushing equipment for crushing of demolition material during the demolition phase.

Construction: Dust From Material Movement Assumed 7350 CY of soil export per project grading plan.

Operations: Vehicle Data Adjusted trip rates to ITE 11th edition, land use code 215 Operations: Hearths Assumed zero fire places proposed pursuant to SCAQMD Rule 445, which prohibits new wood burning devices.
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Construction: Construction Phases Extended site preparation phase from 5 days to 10 days to account for asphalt crushing of existing material
639
North Tustin Street Project Air Quality, Energy, and GHG Impact Analysis APPENDIX B: CRUSHING EMISSIONS FACTORS
640
ROG NOx CO SOx PM10 PM2.5
Demolition 1.2 17.3 27.0 0.1 11.4 2.1
Off-Road Equipment 0.7 5.3 18.4 0.0 0.2 0.2
Demolition 0.0 0.0 0.0 0.0 6.9 1.1
Off-Site Worker 0.1 0.1 0.9 0.0 0.2 0.1
Off-Site Hauling 0.1 10.3 4.5 0.1 2.4 0.7
Crushing PM 0.0 0.0 0.0 0.0 1.6 0.1
Crushing EM 0.3 1.6 3.2 0.0 0.1 0.1
Site Preparation 1.7 13.3 33.2 0.1 6.8 3.5
Off-Road 1.7 13.3 32.2 0.1 0.8 0.8
Dust from Material Movement 0.0 0.0 0.0 0.0 5.7 2.7
Off-Site (Worker Trip) 0.1 0.1 1.1 0.0 0.3 0.1
Grading 1.4 31.8 29.6 0.2 8.1 3.1
Off-Road 1.1 9.0 19.1 0.0 0.6 0.5
Dust from Material Movement 0.0 0.0 0.0 0.0 2.3 0.9
Off-Site (Worker Trip) 0.1 0.1 0.8 0.0 0.2 0.0
Off-Site (Hauling Trip) 0.3 22.8 9.7 0.1 5.1 1.6
Building Construction 1.0 8.1 17.2 0.0 0.7 0.4
Off-Road 0.9 7.7 15.9 0.0 0.3 0.3
Onsite Truck 0.0 0.0 0.0 0.0 0.0 0.0
Off-Site (Worker Trip) 0.1 0.1 1.2 0.0 0.3 0.1
Vendor 0.0 0.3 0.1 0.0 0.1 0.0
Maximum Year 1 1.7 31.8 33.2 0.2 11.4 3.5
Building Construction 1.2 10.5 15.4 0.0 0.8 0.4
Off-Road 1.1 10.2 14.0 0.0 0.4 0.3
Onsite Truck 0.0 0.0 0.0 0.0 0.0 0.0
Off-Site (Worker Trip) 0.1 0.1 1.3 0.0 0.3 0.1
Vendor 0.0 0.2 0.1 0.0 0.1 0.0
Paving 1.1 7.4 11.4 0.0 0.5 0.3
Off-Road 0.8 7.3 10.4 0.0 0.3 0.3
Paving 0.3 0.0 0.0 0.0 0.0 0.0
Off-Site (Worker Trip) 0.1 0.1 1.0 0.0 0.3 0.1
Architectural Coating 66.9 1.1 1.7 0.0 0.1 0.0
Off-Road 0.2 1.1 1.5 0.0 0.0 0.0
Architectural Coating 66.7 0.0 0.0 0.0 0.0 0.0
Off-Site (Worker Trip) 0.0 0.0 0.2 0.0 0.1 0.0
Maximum Year 2 66.9 10.5 15.4 0.0 0.8 0.4
Maximum Construction 66.9 31.8 33.2 0.2 11.4 3.5
SCAQMD Thresholds 75 100 550 150 150 55
Threshold Exceeded? No No No No No No
Unmitigated Construction Emissions
Notes: ROG = reactive organic gases, NOx = nitrogen oxides, CO = carbon monoxide, SOx = sulfur oxides, PM10 = particulate matter 10 microns in diameter, PM2.5 = particulate matter 2.5 microns in diameter Source: CalEEMod Output Sheets.

Construction Activity
Maximum Daily Regional Emissions
(pounds/day)
2026 (Year 1)
2027 (Year 2)
641
ROG NOx CO SOx PM10 PM2.5
Mobile 1.9 1.5 15.4 0.0 4.3 1.1
Area 4.4 - - - - -
Energy 0.0 0.7 0.3 0.0 0.1 0.1
Total Winter Proposed
Project Operational
Emissions

6.3 2.2 15.7 0.0 4.4 1.2
Mobile 1.9 1.4 16.6 0.0 4.3 1.1
Area 4.7 0.0 4.0 0.0 0.0 0.0
Energy 0.0 0.7 0.3 0.0 0.1 0.1
Total Summer
Proposed Project
Operational Emissions

6.7 2.1 21.0 0.0 4.4 1.2
Mobile 1.9 1.5 16.6 0.0 4.3 1.1
Area 4.7 0.0 4.0 0.0 0.0 0.0
Energy 0.0 0.7 0.3 0.0 0.1 0.1
Maximum
Operational Emissions 6.7 2.3 21.0 0.0 4.4 1.2
SCAQMD Significance
Thresholds 55 55 550 150 150 55
Threshold Exceeded? No No No No No No
Summer
Maximum
Proposed Operational Emissions
Operational Activity
Maximum Daily Regional Emissions
(pounds/day)
Winter
642
Demolition Rubber Tired Dozers 2 8 0.5 1
1 Crawler Tractors 4 8 0.5 2
Graders 0 8 0.5 0
Scrapers 0 8 1 0
Rubber Tired Dozers 3 8 0.5 1.5

3.5 Graders 1 8 0.5 0.5
Rubber Tired Dozers 1 8 0.5 0.5
Crawler Tractors 3 8 0.5 1.5
Scrapers 0 8 1 0

2.5 3.5
Acres Disturbed per Piece
of Equipment per Day
Source: CalEEMod Output Sheets.

Construction Equipment Modeled in CalEEMod and Acres Disturbed Per Day Total Acres Disturbed Per Day (Site Prep)
Total Acres Disturbed Per Day (Grading)
Maximum Acres Disturbed Per Day
Activity Equipment Type Equipment
Quantity
Acres Disturbed
per Day
Total Acres Disturbed Per Day (Demo)
Operating
Hours per
Day
Grading
Site
Preparation
643
NOx CO PM10 PM2.5
Demolition 5.3 26.7 8.8 1.3
Site Preparation 13.3 32.2 6.5 3.5
Grading 9.0 19.1 2.8 1.5
Building Construction 7.7 15.9 0.3 0.3
Maximum Year 1 13.3 32.2 8.8 3.5
Building Construction 10.2 14.0 0.4 0.3
Paving 7.3 10.4 0.3 0.3
Architectural Coating 1.1 1.5 0.0 0.0
Maximum Year 2 10.2 14.0 0.4 0.3
Maximum Daily Emissions 13.3 32.2 8.8 3.5
SCAQMD Screening Thresholds 149 984 9.5 5.5
Threshold Exceeded? No No No No
Year 2
Localized Construction Emission Estimates
Construction Activity
Maximum Daily Localized Emissions
(pounds/day)
Year 1
644
North Tustin Street Project Air Quality, Energy, and GHG Impact Analysis APPENDIX C: DETAILED AIR QUALITY TABLES
645

EMISSION FACTORS COUNT
Model Output: Off-Road Web Query (v1.1.2) Emissions InventoryRegion Type: Sub-Area Step 1: Convert hph/year to hph/dayRegion: Orange (SC) Step 2: Convert tpd to gpdCalendar Year: 2026 Step 3: Divide emissions by hph/day to get grams/hphScenario: All Adopted Rules - Exhaust HC ROG TOG CO NOx CO2 PM10 PM2.5 SOx NH3 Step 4: Convert hph to bhp-hrVehicle Classification: Off-Road Web Query Equipment TypesUnits: tons/day for Emissions, gallons/year for Fuel, hours/year for Activity, Horsepower-hours/year for Horsepower-hoursRegion Calendar YeVehicle CatModel YearHorsepoweFuel HC_tpd ROG_tpd TOG_tpd CO_tpd NOx_tpd CO2_tpd PM10_tpd PM2.5_tpd SOx_tpd NH3_tpd Fuel ConsumTotal_Activ Total_PopuHorsepower_Hours_hhpy hph/day Orange (SC 2026 ConstructioAggregate Aggregate Diesel 0.000133 0.000161 0.000191 0.000605 0.002378 1.31786855 5.83203E-05 5.36547E-05 1.2484E-05 0 41755.251 11251.36 15.53035 823251.1643 2255.483 Conversion factors HC_gpd ROG_gpd TOG_gpd CO_gpd NOx_gpd CO2_gpd PM10_gpd PM2.5_gpd SOx_gpd NH3_gpd 907185 grams in 1 ton 120.3706 145.6484 173.3336 548.7135 2157.155 1195550.58 52.90730176 48.67471762 11.32529303 0

0.98632 bhp in 1 HP
HC_grams/ROG_gram TOG_gramsCO_grams/NOx_gramsCO2_grams/hphPM10_grams/hph PM2.5_grams/hph SOx_grams/hph NH3_grams/hph

0.053368 0.064575 0.07685 0.24328 0.956405 530.0641903 0.023457197 0.021580622 0.005021228 0 FINAL VALUES HC_grams/ROG_gram TOG_gramsCO_grams/NOx_gramsCO2_grams/bhpPM10_grams/bhp- PM2.5_grams/bhp SOx_grams/bhp-hNH3_grams/bhp-hr

0.054108 0.065471 0.077916 0.246654 0.96967 537.4160417 0.023782543 0.021879939 0.005090871 0 646
Equipment Fuel Type Number/d hours/day hp LF Emissions Rates (g/bhp-hr) Equipment crushing/proc diesel 1 8 367 0.4 TOG ROG NOx CO SO₂ PM10E PM2.5E CO₂ CH₄ N₂O

0.077916 0.065471 0.96967 0.246654 0.005091 0.023783 0.02188 537.416 0.022 0.004

CONVERSION FACTORS
453.592 grams in 1 lb 0.198973 0.167193 2.476238 0.629879 0.013001 0.060733 0.055875 1372.395 0.056181 0.0102150.98632 bhp in 1 HP 647
ROCK CRUSHING CALCULATIONS: AP-42 SOURCES
PHASE 1 SITE DATA Section 11.19.2-2: PM10, PM2.5Total Rock Weight (tons) Demolition Duration tons/day https://www.epa.gov/sites/default/files/2020-10/documents/c11s1902.pdf 3240 20 162
Source
Total PM-10 Emission Factor
PM-10 Emissions (lbs/day)
Total PM2.5 Emission Factor PM-2.5 Emissions (lbs/day) Tertiary Crushing (controlled) 0.00054 0.08748 0.0001 0.0162 Fines Crushing (controlled) 0.0012 0.1944 0.00007 0.01134Screening (controlled) 0.00074 0.11988 0.00005 0.0081Fines Screening (controlled) 0.0022 0.3564 ND 0Conveyor Transfer Point (contro 4.60E-05 0.007452 1.30E-05 0.002106Wet Drilling 8.00E-05 0.01296 ND 0Truck Unloading 1.60E-05 0.002592 ND 0Truck Loading 1.00E-04 0.0162 ND 0TOTAL 0.797364 0.037746 WATERING REDUCTION 36% PM10 PM2.5

0.51031296 0.02415744
648
North Tustin Street Project Air Quality, Energy, and GHG Impact Analysis APPENDIX D: FUEL CALCULATIONS
649
Fuel Rate Fuel Use
(gal/hp-hr) (gallons)
Concrete/Industrial Saws 1 8 33 0.73 20 3,854 0.041937376 161.64 Rubber Tired Dozers 2 8 367 0.4 20 46,976 0.050817531 2,387.20 Excavators 3 8 36 0.38 20 6,566 0.051468449 337.96
Crawler Tractors 4 8 87 0.43 5 5,986 0.050999088 305.26 Rubber Tired Dozers 3 8 148 0.41 5 7,282 0.050817531 370.03 Crushing/Proc. 1 8 200 0.6 5 4,800 0.050719942 243.46
Graders 1 8 148 0.41 8 3,884 0.050766925 197.15
Rubber Tired Dozers 1 8 367 0.4 8 9,395 0.050817531 477.44 Crawler Tractors 3 8 87 0.43 8 7,183 0.050999088 366.31 Excavators 1 8 36 0.38 8 876 0.051468449 45.06
Cranes 1 8 367 0.29 230 195,831 0.046434547 9,093.33
Forklifts 3 8 82 0.2 230 90,528 0.052939448 4,792.50
Tractors/Loaders/Backhoes 3 8 84 0.37 230 171,562 0.05300741 9,094.04 Generator Sets 1 8 14 0.74 230 19,062 0.069037993 1,316.03 Welders 1 8 46 0.45 230 38,088 0.030223713 1,151.16
Pavers 1 8 81 0.42 18 4,899 0.051655802 253.06
Rollers 2 8 36 0.38 18 3,940 0.052272257 205.94
Paving Equipment 2 8 89 0.36 18 9,228 0.051186523 472.32 Architectual Coating Air Compressors 1 8 37 0.48 18 2,557 0.029379007 75.14 28,458.24
Model Output: Off-Road Web Query (v1.1.2) Emissions InventoryRegion Type: Sub-AreaRegion: Orange (SC)Calendar Year: 2026Scenario: All Adopted Rules - ExhaustVehicle Classification: Off-Road Web Query Equipment TypesUnits: tons/day for Emissions, gallons/year for Fuel, hours/year for Activity, Horsepower-hours/year for Horsepower-hoursRegion Calendar.Year Vehicle.Category Model.Year Horsepower.Bin Fuel Fuel.ConsumptioHorsepower_HoFuel.Rate Orange (SC) 2026 Construction and Mining - Crawler Tractors Aggregate Aggregate Diesel 784892.2512 15390319.23 0.050999088Orange (SC) 2026 Construction and Mining - Crushing/Processing Equipment Aggregate Aggregate Diesel 41755.25093 823251.1643 0.050719942Orange (SC) 2026 Construction and Mining - Excavators Aggregate Aggregate Diesel 2477860.08 48143282.78 0.051468449Orange (SC) 2026 Construction and Mining - Graders Aggregate Aggregate Diesel 356900.3229 7030174.114 0.050766925Orange (SC) 2026 Construction and Mining - Misc - Concrete/Industrial Saws Aggregate Aggregate Diesel 4839.2 115391.1 0.041937376Orange (SC) 2026 Construction and Mining - Off-Highway Trucks Aggregate Aggregate Diesel 1065828.57 21051545.68 0.050629469Orange (SC) 2026 Construction and Mining - Pavers Aggregate Aggregate Diesel 159410.1796 3086007.282 0.051655802Orange (SC) 2026 Construction and Mining - Paving Equipment Aggregate Aggregate Diesel 176178.9235 3441900.607 0.051186523Orange (SC) 2026 Construction and Mining - Rollers Aggregate Aggregate Diesel 418156.5927 7999589.409 0.052272257Orange (SC) 2026 Construction and Mining - Rubber Tired Dozers Aggregate Aggregate Diesel 97459.83317 1917838.819 0.050817531Orange (SC) 2026 Construction and Mining - Scrapers Aggregate Aggregate Diesel 992080.6688 19605884.81 0.050601168Orange (SC) 2026 Construction and Mining - Tractors/Loaders/Backhoes Aggregate Aggregate Diesel 2410382.755 45472562.08 0.05300741Orange (SC) 2026 Industrial - Forklifts Aggregate Aggregate Diesel 1256468.647 23734071.58 0.052939448Orange (SC) 2026 Light Commercial - Misc - Air Compressors Aggregate Aggregate Diesel 98536.21128 3353966.75 0.029379007Orange (SC) 2026 Light Commercial - Misc - Generator Sets Aggregate Aggregate Diesel 415673.2127 6020934.15 0.069037993Orange (SC) 2026 Light Commercial - Misc - Welders Aggregate Aggregate Diesel 496890.9077 16440432.2 0.030223713Orange (SC) 2026 Construction and Mining - Misc - Cranes Aggregate Aggregate Gasoline 10636.1 229055.75 0.046434547 Site Preparation
Construction Equipment Fuel Usage (Off-Road)
Total
Source: Fuel Calculation Sheets (see Attachment C)
Building Construction
Horsepower Load Factor Days of Construction Total Horsepower- hours Activity Equipment Number Hours per day Grading
Paving
Demolition
650
Construction Source Total Trips VMT Fuel Rate (Gallons/Miles) Gallons of Diesel Fuel Gallons of Gasoline Fuel Haul Trucks 5098.0 101960.0 6.2 16,350 -
Vendor Trucks 3491.4 35611.8 8.9 4,007 -
Worker Vehicles 13701.6 253480.2 24.3 - 10,431
20,357 10,431

5.3. Construction Vehicles Construction Schedule Days per phase5.3.1 Unmitigated Demolition 20Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Site Prep 5Demolition Grading 8Demolition Worker 15 18.5 LDA,LDT1,LDT2 Building Construction 230Demolition Vendor 10.2 HHDT,MHDT Paving 18Demolition Hauling 81.5 20 HHDT Coating 18Demolition Onsite truck HHDTSite PreparationSite Preparation Worker 20 18.5 LDA,LDT1,LDT2Site Preparation Vendor 10.2 HHDT,MHDTSite Preparation Hauling 0 20 HHDTSite Preparation Onsite truck HHDTGradingGrading Worker 15 18.5 LDA,LDT1,LDT2Grading Vendor 10.2 HHDT,MHDTGrading Hauling 114.875 20 HHDTGrading Onsite truck HHDTBuilding ConstructionBuilding Construction Worker 25.56 18.5 LDA,LDT1,LDT2Building Construction Vendor 7.5899 10.2 HHDT,MHDTBuilding Construction Hauling 0 20 HHDTBuilding Construction Onsite truck HHDTPavingPaving Worker 20 18.5 LDA,LDT1,LDT2Paving Vendor 10.2 HHDT,MHDTPaving Hauling 0 20 HHDTPaving Onsite truck HHDTArchitectural CoatingArchitectural Coating Worker 5.112 18.5 LDA,LDT1,LDT2Architectural Coating Vendor 10.2 HHDT,MHDTArchitectural Coating Hauling 0 20 HHDTArchitectural Coating Onsite truck HHDT Source: EMFAC2025 (v2.0.0) Emissions InventoryRegion Type: Sub-AreaRegion: Orange (SC)Calendar Year: 2026Season: AnnualUnits: miles/year for Combustion VMT and Electric VMT, trips/year for Trips, tons/year for Emissions, 1000 gallons/year for Fuel Consumption, kWh/year for Energy Consumption, kg/year for Hydrogen ConsumptionRegion Calendar Year Vehicle Category Model Year Speed Fuel Total VMT Fuel Consumption Fuel Rate Trip % Orange (SC) 2026 HHDT Aggregate Aggregate Diesel 561441537.2 90029.71103 6.236180598 100% Orange (SC) 2026 LHDT1 Aggregate Aggregate Diesel 202217878.1 9768.386964 20.70125588Orange (SC) 2026 LHDT2 Aggregate Aggregate Diesel 197754155.7 10798.30689 18.31344097 Total
Source: CalEEMod Output Sheets (see Attachment B)
Construction On-Road Fuel Consumption
651
Orange (SC) 2026 MHDT Aggregate Aggregate Diesel 259735745.3 29225.55792 8.887280986 100% Orange (SC) 2026 LDA Aggregate Aggregate Gasoline 8044304182 307402.6873 26.16862023 50%Orange (SC) 2026 LDT1 Aggregate Aggregate Gasoline 915988079.6 40634.13976 22.54232734 25%Orange (SC) 2026 LDT2 Aggregate Aggregate Gasoline 6227284368 278942.7636 22.32459551 25% 50/25/25 Splits 24.30104083
652
Construction Source Gallons of Diesel Fuel Gallons of Gasoline Fuel On-road Construction Vehicles 20,357 10,431
Off-Road Construction
Equipment 28,458 -
Total 48,815 10,431
On-road Countywide 148,172,563 877,821,674
Off-road Countywide 14,096,267 977,564
onroad percentage 0.014% 0.001%
offroad percentage 0.202% -
Model Output: Off-Road Web Query (v1.1.2) Emissions InventoryRegion Type: CountyRegion: OrangeCalendar Year: 2026Scenario: All Adopted Rules - ExhaustVehicle Classification: Off-Road Web Query Equipment TypesUnits: tons/day for Emissions, gallons/year for Fuel, hours/year for Activity, Horsepower-hours/year for Horsepower-hoursRegion Calendar Year Vehicle Category Model Yea HorsepoweFuel Fuel Consumption Orange 2026 Construction and Mining - Bore/Drill Rigs Aggregate Aggregate Diesel 305087.6071Orange 2026 Construction and Mining - Bucket Aggregate Aggregate Diesel 7153.907637Orange 2026 Construction and Mining - Compactor Aggregate Aggregate Diesel 11642.54923 Orange 2026 Construction and Mining - Concrete Mixer Aggregate Aggregate Diesel 1077.218975Orange 2026 Construction and Mining - Concrete Pump Aggregate Aggregate Diesel 10931.98532Orange 2026 Construction and Mining - Crane less than 3Aggregate Aggregate Diesel 5284.01283Orange 2026 Construction and Mining - Cranes Aggregate Aggregate Diesel 265504.5885Orange 2026 Construction and Mining - Crawler Tractors Aggregate Aggregate Diesel 784892.2512Orange 2026 Construction and Mining - Crushing/ProcessAggregate Aggregate Diesel 41755.25093Orange 2026 Construction and Mining - Excavators Aggregate Aggregate Diesel 2477860.08Orange 2026 Construction and Mining - Graders Aggregate Aggregate Diesel 356900.3229Orange 2026 Construction and Mining - Hopper Tractor TAggregate Aggregate Diesel 706.2194177Orange 2026 Construction and Mining - Misc - Bore/Drill Aggregate Aggregate Diesel 85.1Orange 2026 Construction and Mining - Misc - Cement AnAggregate Aggregate Diesel 124.2Orange 2026 Construction and Mining - Misc - Concrete/ Aggregate Aggregate Diesel 4839.2Orange 2026 Construction and Mining - Misc - Dumpers/TAggregate Aggregate Diesel 10Orange 2026 Construction and Mining - Misc - ExcavatorsAggregate Aggregate Diesel 71.5Orange 2026 Construction and Mining - Misc - Other Aggregate Aggregate Diesel 266.4Orange 2026 Construction and Mining - Misc - Pavers Aggregate Aggregate Diesel 18.9 Construction Fuel Consumption Summary
653
Orange 2026 Construction and Mining - Misc - Paving EquAggregate Aggregate Diesel 31.9 Orange 2026 Construction and Mining - Misc - Plate Com Aggregate Aggregate Diesel 89.2Orange 2026 Construction and Mining - Misc - Rollers Aggregate Aggregate Diesel 548Orange 2026 Construction and Mining - Misc - Rubber TirAggregate Aggregate Diesel 13.1Orange 2026 Construction and Mining - Misc - Signal Boa Aggregate Aggregate Diesel 3535.25Orange 2026 Construction and Mining - Misc - Skid Steer Aggregate Aggregate Diesel 3670Orange 2026 Construction and Mining - Misc - Tractors/L Aggregate Aggregate Diesel 342Orange 2026 Construction and Mining - Misc - Trenchers Aggregate Aggregate Diesel 461Orange 2026 Construction and Mining - Nurse Rig Other Aggregate Aggregate Diesel 65.20325114 Orange 2026 Construction and Mining - Off-Highway TracAggregate Aggregate Diesel 445252.6358 Orange 2026 Construction and Mining - Off-Highway TrucAggregate Aggregate Diesel 1065828.57Orange 2026 Construction and Mining - Other ConstructioAggregate Aggregate Diesel 509387.7034 Orange 2026 Construction and Mining - Pavers Aggregate Aggregate Diesel 159410.1796Orange 2026 Construction and Mining - Paving EquipmenAggregate Aggregate Diesel 176178.9235 Orange 2026 Construction and Mining - Rollers Aggregate Aggregate Diesel 418156.5927Orange 2026 Construction and Mining - Rough Terrain FoAggregate Aggregate Diesel 520129.8972Orange 2026 Construction and Mining - Rubber Tired DozAggregate Aggregate Diesel 97459.83317Orange 2026 Construction and Mining - Rubber Tired LoaAggregate Aggregate Diesel 1816611.083Orange 2026 Construction and Mining - Scrapers Aggregate Aggregate Diesel 992080.6688Orange 2026 Construction and Mining - Skid Steer LoaderAggregate Aggregate Diesel 851290.483Orange 2026 Construction and Mining - Spray Truck Aggregate Aggregate Diesel 10441.2567Orange 2026 Construction and Mining - Spreader Tractor Aggregate Aggregate Diesel 1316.378776Orange 2026 Construction and Mining - Spreader Truck Aggregate Aggregate Diesel 8176.531814 Orange 2026 Construction and Mining - Surfacing Equip
mAggregate Aggregate Diesel 84219.91477
Orange 2026 Construction and Mining - Tank Truck Aggregate Aggregate Diesel 17845.26527Orange 2026 Construction and Mining - Tanker Truck Tra Aggregate Aggregate Diesel 1359.898226Orange 2026 Construction and Mining - Telescopic Handl Aggregate Aggregate Diesel 35626.9539Orange 2026 Construction and Mining - Tractors/LoadersAggregate Aggregate Diesel 2410382.755Orange 2026 Construction and Mining - Trenchers Aggregate Aggregate Diesel 84045.28901Orange 2026 Construction and Mining - Vacuum Truck Aggregate Aggregate Diesel 27130.65338Orange 2026 Construction and Mining - Water Truck Aggregate Aggregate Diesel 80968.41256Orange 2026 Construction and Mining - Misc - Asphalt PaAggregate Aggregate Gasoline 19866.7Orange 2026 Construction and Mining - Misc - Bore/Drill Aggregate Aggregate Gasoline 12864.65Orange 2026 Construction and Mining - Misc - Cement AnAggregate Aggregate Gasoline 74534Orange 2026 Construction and Mining - Misc - Concrete/ Aggregate Aggregate Gasoline 95662.05Orange 2026 Construction and Mining - Misc - Cranes Aggregate Aggregate Gasoline 10636.1Orange 2026 Construction and Mining - Misc - Crushing/PAggregate Aggregate Gasoline 478Orange 2026 Construction and Mining - Misc - Dumpers/TAggregate Aggregate Gasoline 7755.7Orange 2026 Construction and Mining - Misc - Other Aggregate Aggregate Gasoline 16206Orange 2026 Construction and Mining - Misc - Paving EquAggregate Aggregate Gasoline 140412.75Orange 2026 Construction and Mining - Misc - Plate Com Aggregate Aggregate Gasoline 50918Orange 2026 Construction and Mining - Misc - Rollers Aggregate Aggregate Gasoline 67223.65Orange 2026 Construction and Mining - Misc - Rough Ter Aggregate Aggregate Gasoline 75044Orange 2026 Construction and Mining - Misc - Rubber TirAggregate Aggregate Gasoline 39785 654
Orange 2026 Construction and Mining - Misc - Signal Boa Aggregate Aggregate Gasoline 1441.6 Orange 2026 Construction and Mining - Misc - Skid Steer Aggregate Aggregate Gasoline 145672.7Orange 2026 Construction and Mining - Misc - Surfacing EAggregate Aggregate Gasoline 61798 Orange 2026 Construction and Mining - Misc - Tampers/RAggregate Aggregate Gasoline 8510Orange 2026 Construction and Mining - Misc - Tractors/L Aggregate Aggregate Gasoline 25528.1Orange 2026 Construction and Mining - Misc - Trenchers Aggregate Aggregate Gasoline 123226.9 655
Operational Source Countywide Energy Consumption Percentage Increase Proposed Project 18,759,000,000 0.003%
Proposed Project 60,825,476,870 0.004%
Annual VMT
Proposed Project 1,881,157.3 77,410.6 877,821,673.9 0.009% CalEEMod OutputLand Use Type Trips/Weekday Trips/Saturday VMT/Year Single Family Housing 511.2 621.96 1881157.321Parking Lot 00 0Other Asphalt Surface 00 05.11. Operational Energy Consumption5.11.1 UnmitigatedLand Use Electricity (kWh/yr) Natural Gas (kBTU/yr)Single Family Housing 489555.3013 2721809.579Parking Lot 13050.22752 0Other Asphalt Surface 0 0 Source: EMFAC2025 (v2.0.0) Emissions Inventory
Region Type: CountyRegion: OrangeCalendar Year: 2026Season: AnnualVehicle Classification: EMFAC2007 CategoriesUnits: miles/year for Combustion VMT and Electric VMT, trips/year for Trips, tons/year for Emissions, 1000 gallons/year for Fuel Consumption, kWh/year for Energy Consumption, kg/year for Hydrogen ConsumptionRegion Calendar Year Vehicle Category Model Year Speed Fuel Fuel ConsumptionOrange 2026 HHDT Aggregate Aggregate Diesel 90029.71103 Orange 2026 LDA Aggregate Aggregate Diesel 531.2474279Orange 2026 LDT1 Aggregate Aggregate Diesel 12.39961316Orange 2026 LDT2 Aggregate Aggregate Diesel 430.4057661Orange 2026 LHDT1 Aggregate Aggregate Diesel 9768.386964Orange 2026 LHDT2 Aggregate Aggregate Diesel 10798.30689Orange 2026 MDV Aggregate Aggregate Diesel 4900.201638Orange 2026 MH Aggregate Aggregate Diesel 994.6018995Orange 2026 MHDT Aggregate Aggregate Diesel 29225.55792Orange 2026 OBUS Aggregate Aggregate Diesel 921.4344754Orange 2026 SBUS Aggregate Aggregate Diesel 560.3093819Orange 2026 HHDT Aggregate Aggregate Gasoline 99.24342338Orange 2026 LDA Aggregate Aggregate Gasoline 307402.6873Orange 2026 LDT1 Aggregate Aggregate Gasoline 40634.13976Orange 2026 LDT2 Aggregate Aggregate Gasoline 278942.7636Orange 2026 LHDT2 Aggregate Aggregate Gasoline 7316.230399Orange 2026 MCY Aggregate Aggregate Gasoline 2513.971064Orange 2026 MDV Aggregate Aggregate Gasoline 207488.0276Orange 2026 MH Aggregate Aggregate Gasoline 4002.68797Orange 2026 MHDT Aggregate Aggregate Gasoline 25916.43022 Source: CalEEMod Output Sheets (see Attachment B)
2,721,809.6
Energy Usage
502,605.5
Gallons of Gasoline Fuel
Operational Energy Consumption
Electricity (Kilowatt-Hour)
Natural Gas (Thousands British Thermal Units)
Petroleum (Gasoline) Consumption
656
Orange 2026 OBUS Aggregate Aggregate Gasoline 1687.833577 Orange 2026 SBUS Aggregate Aggregate Gasoline 645.3856039Orange 2026 UBUS Aggregate Aggregate Gasoline 1172.27338Fuel Sum Annual ConsumptionDiesel 148172.563 148,172,563Gasoline 877821.6739 877,821,674 657
Appendix B: Tree Survey and Arborist Report
658
Tree Survey and Arborist Report
for an approximate 4.1-acre Site
Located at 2375 N Tustin St, Orange, California
Prepared for: Melia Homes
Contact: Chad Brown, VP of Planning & Development
9860 Irvine Center Drive
Irvine, CA 92618
Prepared by: CalPacific Sciences
George J Wirtes, MS, RCA #738
ISA Certified and ASCA Registered Consulting Arborist
Report Date: June 24, 2025
659
Tree Survey and Arborist Report
Page ii
Table of Contents
Section 1: Executive Summary............................................................................................................ 1 Section 2: Background ......................................................................................................................... 2

2.1 - Project Location and Description...................................................................................... 2

2.2 - Site and Vicinity Characteristics....................................................................................... 3

2.2.1 - Natural Surroundings........................................................................................ 3

2.2.2 - Vegetation Community ..................................................................................... 3

2.3 - Assignment and Scope of Survey ..................................................................................... 3

2.4 - Survey Method and Health Assessment............................................................................ 4

2.5 - Tree Risk Assessment ....................................................................................................... 4

2.6 - Local Tree Regulation (City of Orange Municipal Code Chapter 12.32)......................... 5

2.6.1 - Street Trees (Chapter 12.28.020) ...................................................................... 5

2.6.2 - Tree Removal Permit (Chapter 12.32).............................................................. 6

2.7 - Limitations and Exceptions of Assessment....................................................................... 6 Section 3: Subject Trees and Observations........................................................................................ 8

3.1 - Observations.................................................................................................................... 11

3.1.1 - Urban Forest.................................................................................................... 13 Section 4: Discussion, Conclusion, and Recommendations ............................................................ 15

4.1 - Conclusion ...................................................................................................................... 15

4.2 - Discussion ....................................................................................................................... 15

4.3 - Recommendations........................................................................................................... 15

4.3.1 - Tree Replacement ........................................................................................... 15

4.3.2 - Trees Preserved............................................................................................... 15

4.3.3 - Migratory Bird Treaty Act .............................................................................. 16

4.3.4 - Tree Protection During Construction.............................................................. 16 Section 5: Qualifications Of Arborist ............................................................................................... 18 Section 6: References.......................................................................................................................... 19 Appendix A - Tree Species Matrix............................................................................. 20 660
Tree Survey and Arborist Report

Page 1 ends

Orange City CouncilMay 26, 2026

Orange City Council
May 26, 2026