Attachment 4 Initial Study/CEQA Analysis Under CEQA Guidelines Section 15183 — Orange City Council, July 14, 2026 (part 1 of 2)

27128 Paseo Espada, Suite 1524, San Juan Capistrano, CA 92675 www.sagecrestplanning.com
INITIAL STUDY/CEQA ANALYSIS UNDER CEQA GUIDELINES §15183

RANCHO RIDGE RESIDENTIAL
647 N Rancho Santiago Blvd
Orange, CA 92869

February 12, 2026
Attachment 4
City of Orange

Initial Study/CEQA Analysis Under CEQA Guidelines §15183 for the

Rancho Ridge Residential Development Project
(Tentative Tract Map No. 0052-23, Conditional Use Permit No. 3203-23, Major Site Plan Review No. 1137-23, and Design Review No. 5119-23)

Prepared for
City of Orange
Community Development
Planning Division
300 E. Chapman Avenue
Orange, CA 92866

Contact:

Applicant
Rancho Ridge, LLC
11625 Wander Lane
Dallas, Texas 75230

Prepared By
27128 Paseo Espada, Suite 1524
San Juan Capistrano, CA 92675
949.996.7243
Contact: David Blumenthal, AICP

February 12, 2026

Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
TTM 0052-23, Zone Change, CUP 3203-23, Major Site Plan Review 1137-23, Design Review 5119-23 Page ii

TABLE OF CONTENTS

1. INTRODUCTION ............................................................................................................... 1

1.1. PURPOSE AND BACKGROUND ......................................................................................... 1

1.2. OVERVIEW OF CEQA GUIDELINES § 15183 ...................................................................... 3

1.3. DOCUMENTS INCORPORATED BY REFERENCE ................................................................ 5

1.4. CONTACT PERSON ............................................................................................................ 6

2. PROJECT SUMMARY AND ENVIRONMENTAL DETERMINATION ......................................... 7

2.1 PROJECT SUMMARY ......................................................................................................... 7

2.2 ORGANIZATION OF ENVIRONMENTAL ANALYSIS ............................................................ 9

2.3 ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED ................................................... 11

2.4 DETERMINATION............................................................................................................ 12

3. PROJECT DESCRIPTION ................................................................................................... 13

3.1 BACKGROUND ................................................................................................................ 13

3.2 PROJECT CHARACTERISTICS ........................................................................................... 14

3.3 PROJECT OPERATIONS ................................................................................................... 17

3.4 PROJECT APPROVALS ..................................................................................................... 18

4. EVALUATION OF ENVIRONMENTAL IMPACTS ................................................................. 24

4.1 AESTHETICS AND VISUAL RESOURCES ........................................................................... 26

4.2 AGRICULTURE AND FORESTRY RESOURCES ................................................................... 36

4.3 AIR QUALITY ................................................................................................................... 40

4.4 BIOLOGICAL RESOURCES................................................................................................ 60

4.5 CULTURAL RESOURCES .................................................................................................. 71

4.6 ENERGY .......................................................................................................................... 81

4.7 GEOLOGY AND SOILS ..................................................................................................... 88

4.8 GREENHOUSE GAS EMISSIONS .................................................................................... 100

4.9 HAZARDS AND HAZARDOUS MATERIALS ..................................................................... 109

4.10 HYDROLOGY AND WATER QUALITY ............................................................................. 122

4.11 LAND USE PLANNING ................................................................................................... 132

4.12 MINERAL RESOURCES .................................................................................................. 136 Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
TTM 0052-23, Zone Change, CUP 3203-23, Major Site Plan Review 1137-23, Design Review 5119-23 Page iii

4.13 NOISE ........................................................................................................................... 140

4.14 POPULATION AND HOUSING ....................................................................................... 162

4.15 PUBLIC SERVICES .......................................................................................................... 166

4.16 RECREATION ................................................................................................................. 183

4.17 TRANSPORTATION ....................................................................................................... 189

4.18 TRIBAL CULTURAL RESOURCES .................................................................................... 198

4.19 UTILITIES AND SERVICE SYSTEMS ................................................................................ 202

4.20 WILDFIRE ...................................................................................................................... 209

5. LIST OF PREPARERS ....................................................................................................... 216

6. REFERENCES ................................................................................................................... 217 TABLES
Table 1 - Surrounding Land Use ............................................................................................. 8 Table 2 – General Plan Policies (Scenic Quality and Aesthetics) .............................. 33 Table 3 – Construction-Related Regional Pollutant Emissions ..................................... 52 Table 4 – Maximum Number of Acres Disturbed Per Day ............................................ 52 Table 5 – Local Construction Emissions at the Nearest Receptors ............................ 53 Table 6 - Regional Operational Pollutant Emissions ....................................................... 54 Table 7 – Project-Related Greenhouse Gas Emissions ................................................ 103 Table 8 – Project Consistency with CARB Scoping Plan Policies and Measures . 104 Table 9 – Construction Noise Levels (dBA Leq) ............................................................. 151 Table 10 – Increase in Existing Noise Levels Along Roadways as a Result of Project (dBA CNEL) .............................................................................................................................. 154 Table 11 – Construction Vibration Levels at the Nearest Receptors ....................... 157 Table 12 – Existing and Future Park Acreage Needs ................................................... 186

FIGURES
Figure 1 – Regional Vicinity ................................................................................................... 19 Figure 2 – Site Location – Aerial View................................................................................. 20 Figure 3 – General Plan Land Use Designation ............................................................... 21 Figure 4 – Zoning Map ............................................................................................................ 22 Figure 5 – Conceptual Site Plan .......................................................................................... 23 Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
TTM 0052-23, Zone Change, CUP 3203-23, Major Site Plan Review 1137-23, Design Review 5119-23 Page iv
Figure 6 – Project Site Agricultural Designation ............................................................. 120 Figure 7 – Fire Hazard Severity Zones ................................................................................ 121 Figure 8 – Mineral Resource Map ...................................................................................... 139 Figure 9 – Noise Monitoring Locations ............................................................................. 161

APPENDICES*
Appendix A – Rancho Ridge Infill Project Air Quality, Global Climate Change, and Energy Impact Study, Ganddini Group, Inc. March 31, 2023 Appendix B – Rancho Ridge Infill Project Biological Technical Report, Noreas, January 2023
Appendix C – Rancho Ridge Infill Project Transportation Study Screening Assessment, Ganddini Group, Inc., February 12, 2026
Appendix D – Preliminary Geotechnical Investigation, Proposed Residential Development 647 North Rancho Santiago Boulevard, Albus & Associates, August 2022
Appendix E – Phase I Environmental Site Assessment – 647 North Rancho Santiago Boulevard, Partner Engineering and Science, March 5, 2021 Appendix F – Preliminary Hydrology Analysis for Rancho Ridge Tentative Tract Map No. 19279, Hunsaker & Associates, Inc., May 15, 2024
Appendix G – Preliminary Water Quality Management Plan – Rancho Ridge – Tentative Parcel Map No. 19279, Hunsaker & Associates, Inc., March 23, 2023 Appendix H – Noise Impact Analysis Rancho Ridge Infill Project, Ganddini Group, Inc., March 27, 2023
Appendix I – Fire Behavior Modeling Summary, Dudek, August 2025 Appendix J – Conceptual Fuel Modification Plan, Dudek, August 2025

*Please note that the technical studies appended in this document were prepared with a previous scope of 13 single-family dwelling units instead of 11 single-family dwelling units. While the appendices referenced indicate analysis based on units that exceed the currently proposed 11 units, the appendices’ analyses are still applicable to the Proposed Project. The Proposed Project consists of fewer dwelling units than originally evaluated. Therefore, the Proposed Project is not expected to result in any new or more substantial impacts than what was previously analyzed for the larger scope of work.

ACRONYMNS
Acronym Definition

AB 32 Assembly Bill 32
AB 52 Assembly Bill 52
AER Annual Emission Reporting
ADA Americans with Disabilities Act
ADT Average Daily Traffic
AFY Acre Feet Per Year
AQMP Air Quality Management Plan
APE Area of Potential Effect
APN Assessor Parcel Number
BMPs Best Management Practices
CAAQS California Ambient Air Quality Standards
CARB California Air Resources Board
CDF California Department of Finance
CDFW California Department of Fish and Wildlife
CERCLA Comprehensive Environmental Response, Compensation, & Liability Act CEQA California Environmental Quality Act
City City of Orange
CNEL Community Noise Equivalent Level
CO Carbon Monoxide
CRHR California Register of Historic Resources
CVC California Vehicle Code
dBA A-Weighted Decibels
DIF Development Impact Fees
DF Design Features
DOSH California Division of Safety and Health
DPM Diesel Particulate Matter
DTSC Department of Toxic Substances Control
EPA Environmental Protection Agency
ESA Endangered Species Act
FAR Floor Area Ratio
FEMA Federal Emergency Management Agency
FMMP Farmland Mapping Management Program
GHG Greenhouse Gas
GP PEIR City of Orange General Plan Program Environmental Impact Report HCP Habitat Conservation Plan
gpd/acre Gallons per Day per Acre
ITE Institute of Transportation Engineers
LID Low Impact Design
Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
TTM 0052-23, Zone Change, CUP 3203-23, Major Site Plan Review 1137-23, Design Review 5119-23 Page vi
LOS Level of Service
LST Localized Significance Threshold
mgd Millions of Gallons per Day
MMRP Mitigation Monitoring and Reporting Program
MRZ Mineral Resources Zone
MS4 Municipal Separate Storm Water Sewer System
NAAQS National Ambient Air Quality Standards
NAHC Native American Heritage Commission
NCCP Natural Communities Conservation Plan
ND Negative Declaration
NO2 Nitrogen Dioxide
NOx Nitrogen Oxides
NPDES National Pollutant Discharge Elimination System
OGP Orange General Plan
OSHA Occupational Safety and Health Administration
Pb Lead
PM-2.5 Particulate Matter Less Than 2.5 Microns in Diameter PM-10 Particulate Matter Less Than 10 Microns in Diameter PRIMMP Paleontological Resource Impact Mitigation Monitoring Program RCRA Resource Conservation and Recovery Act
RTP Regional Transportation Plan/Sustainable Communities Strategy RWQCB Regional Water Quality Control Board
SB 100 Senate Bill 100
SARWQCB Santa Ana Regional Water Quality Control Board
SGMA Sustainability Groundwater Management Act
SF Square Feet
SCAB South Coast Air Basin
SCAG Southern California Association of Governments
SCAQMD South Coast Air Quality Management District
SLF Sacred Lands File
SO2 Sulfur Dioxide
SOx Sulfur Oxide
SRA Source Receptor Areas
SWPPP Stormwater Pollution Prevention Plan
SWRCB State Water Resources Control Board
TIA Traffic Impact Analysis
VMT Vehicle Miles Traveled
VOC Volatile Organic Compounds
USDA-NRCS U.S. Department of Agriculture, Natural Resources Conservation Service UWMP Urban Water Management Plan

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1. INTRODUCTION

1.1. Purpose and Background
Rancho Ridge, LLC. (Applicant) proposes to establish a Planned Unit Development (PUD) and to subdivide the lot into 11 parcels, each improved with a single-family residence with attached private garages and driveways.

Additional improvements would include private and common usable open space and landscaping as well as a twenty-five-foot-wide interior street, giving access throughout the site (Proposed Project). The Proposed Project is located at 647 N. Rancho Santiago Blvd. and consists of a total land area of 1.92-acres (APN 379-301-05). The Project Site is zoned for Single-Family Residential (R-1-10) and has a General Plan land use designation for Low Density Residential.

The Project Site is designated as Low Density Residential by the Orange General Plan (OGP) and is zoned R-1-10. The Project proposes a Conditional Use Permit to establish a Planned Unit Development (PUD), which includes a Zone Change to update the zoning designation from R-1-10 to R-1-10 (PUD), a Major Site Plan Review, a Design Review, and a Tentative Tract Map to allow the Project Site to be subdivided into 11 residential parcels and three common area lots. The Proposed Project would be consistent with Land Use Policy 1.3, “Provide a range of housing densities and types to meet the diverse needs and lifestyles of residents” by allowing a housing density that is consistent with the neighborhood and adding new units to the City’s housing stock. The Proposed Project is subject to the approval of the following entitlements:
 Approval of Tentative Tract Map No. 0052-23 to split existing parcel into 11 parcels (APN 379-301-05)
 Approval of Zone Change
 Approval of Conditional Use Permit No. 3203-23
 Approval of Major Site Plan Review No. 1137-23
 Approval of Design Review No. 5119-23
The Proposed Project includes the construction of 11 single-family detached dwellings each with an attached garage and driveway, associated landscaping and common and private open space. The Project Site would be developed on

1.92 acres with a density of 5.7 dwelling units per acre (du/ac). Six of the eleven units would consist of three bedrooms, 3 bathrooms, and would be approximately 2,425 square feet. Five of the eleven units would consist of three bedrooms, a loft,

2.5-3.0 bathrooms, and would be approximately 2,724 square feet. Each unit would provide two covered parking spaces in attached garages, totaling 22 covered parking spaces for the Project. The Proposed Project would also provide 17 guest parking spaces for the entire site, 1 on each private driveway and 6 on the eastern portion of the Project Site.

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The Proposed Project would have two plan types. Plan 1 features 3 bedrooms and

3.0 bathrooms, totaling 2,425 square feet per unit. Plan 2 contains 3 bedrooms, a loft and 2.5-3.0 bathrooms, totaling 2,724 square feet per unit.

The Proposed Project would provide approximately 0.32-acres of landscaping in the form of front yards and walking paths, approximately 0.43-acre of private usable space in the form of private backyards, and 0.13-acre of common open space in the eastern portion of the Project Site. Additionally, the Proposed Project would require the closure of one existing driveway at the northwestern site boundary along Rancho Santiago Blvd. The second existing driveway located at the southwestern site boundary along Rancho Santiago Blvd would be reconstructed for the proposed two-way access driveway and associated landscaping, signage, and pavement.

The Proposed Project also features additional improvements including walls, site lighting, and circulation.

Wall improvements include: a 5’-6” high vinyl fence surrounding the north, east, and west individual lot boundaries, a 5’-9” high split face concrete masonry unit (CMU) wall with precision cap along the northern, eastern, and southern Project Site boundaries and at Lot 1, and a 3’-6” high split face CMU retraining wall with precision cap at the southwestern corner of the Project site. Site lighting improvements consist of light poles with step motion sensors distributed along sidewalks and bollard lights at the center of the Project site.

The Proposed Project is considered a project under the California Environmental Quality Act (Public Resource Code § 21000 et seq.: “CEQA”). The primary purpose of CEQA is to inform the public and decision makers as to the potential impacts of a project and to allow an opportunity for public input to ensure informed decision-making. CEQA requires all state and local government agencies to consider the environmental effects of projects over which they have discretionary authority. CEQA also requires each public agency to mitigate or avoid any significant environmental impacts resulting from the implementation of projects subject to CEQA.

Pursuant to Section 15367 of the CEQA Guidelines, the City of Orange is the Lead Agency for the Project. The Lead Agency is the public agency that has the principal responsibility for carrying out or approving a project. The City, as the Lead Agency for the Project, is responsible for preparing environmental documentation in accordance with CEQA to determine if approval of the discretionary actions requested and subsequent development of the Proposed Project would have a significant impact on the environment.

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1.2. Overview of CEQA Guidelines § 15183
This exemption analysis evaluates whether the potential environmental impacts of the Proposed Project are addressed in the City of Orange General Plan Program Environmental Impact Report (GP PEIR) (SCH #2006031117) pursuant to the California Environmental Quality Act (CEQA) Guidelines (CEQA Guidelines) Section 15183 (Exemption Checklist). California Public Resources Code (PRC) Section 21083.3 and State CEQA Guidelines § 15183 states that “projects which are consistent with the development density established by the existing zoning, community plan, or general plan policies for which an Environmental Impact Report (EIR) was certified shall not require additional environmental review, except as might be necessary to examine whether there are project-specific significant effects which are peculiar to the project or its site” (State CEQA Guidelines Section 15183(a) and PRC Section 21083.3(b)). The State CEQA Guidelines further state that “[i]f an impact is not peculiar to the parcel or to the project, has been addressed as a significant effect in the prior EIR, or can be substantially mitigated by the imposition of uniformly applied development policies or standards […] then an additional EIR need not be prepared for the project solely on the basis of that impact” (State CEQA Guidelines Section 15183(c)).”
(1) As set forth in State CEQA Guidelines Section 15183(d), the additional environmental review exemption applies to projects which meet the following conditions: The project is consistent with:
a. A community plan adopted as part of a general plan,
b. A zoning action which zoned or designated the parcel on which the project would be located to accommodate a particular density of development, or
c. A general plan of a local agency, and
(2) An EIR was certified by the lead agency for the zoning action, the community plan, or the general plan.

Additionally, Section 15183(e) states that a public agency shall limit its examination of environmental effects to those which the agency determines, in an initial study or other analysis:
(1) Are peculiar to the project or the parcel on which the project would be located,
(2) Were not analyzed as significant effects in a prior EIR on the zoning action, general plan, or community plan, with which the project is consistent, (3) Are potentially significant off-site impacts and cumulative impacts which were not discussed in the prior EIR prepared for the general plan, community plan, or zoning action, or
(4) Are previously identified significant effects which, as a result of substantial new information which was not known at the time the EIR was certified, are Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
TTM 0052-23, Zone Change, CUP 3203-23, Major Site Plan Review 1137-23, Design Review 5119-23

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determined to have a more severe adverse impact than discussed in the prior EIR.

The GP PEIR analyzed the impacts of buildout of the General Plan. As discussed in this analysis, the Proposed Project is consistent with the land uses identified for the Project Site in the General Plan. The Proposed Project site has a General Plan land use designation of Low Density Residential and is Single-Family Residential (R-1-10). The Proposed Project would establish a Planned Unit Development (PUD) and subdivide the lot into 11 parcels, each improved with single family residence, which is within the assumptions and land use and growth projections of the General Plan. As such, the GP PEIR adequately anticipated and analyzed the impacts of the Proposed Project, identified applicable Mitigation Measures necessary to reduce impacts of the Proposed Project, and the Proposed Project implements the applicable Mitigation Measures. The Proposed Project, therefore, qualifies for an exemption from additional environmental review as set forth in State CEQA Guidelines Section 15183.

Specifically, the Proposed Project qualifies for the exemption because the following findings can be made:

1. The Project is consistent with the development density established by existing zoning, community plan or general plan policies for which an EIR was certified. The Project Site is designated as Low Density Residential by the City of Orange General Plan and is zoned R1-10. The Project would establish a PUD and subdivide the lot into 11 parcels, each improved with a single-family residence. The Project Site has been designed to function as a traditional subdivision, while applying the flexible standards of the PUD. Each parcel within the Project would be at least 4,438 square feet and meet the development standards set forth in the Orange Municipal Code (OMC) Section 17.16.060.

2. There are no Project specific effects which are peculiar to the Project or its site, and which the GP PEIR failed to analyze as significant effects. The Proposed Project is similar to other properties in the area. All surrounding properties are designated for single-family residential. The Project Site does not support any peculiar environmental features, and the Proposed Project would not result in any peculiar effects. In addition, as explained in the Exemption Checklist below, Project impacts were adequately analyzed by the GP PEIR. The GP PEIR identified that the General Plan buildout would have significant and unavoidable environmental effects related to air quality, transportation/traffic, and climate change (greenhouse gas emissions). The GP PEIR also identified nine (10) environmental impact areas for which Mitigation Measures were required to reduce potential environmental impacts to a less than significant level:
(1) aesthetics, (2) biological resources, (3) cultural resources, (4) hazards Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
TTM 0052-23, Zone Change, CUP 3203-23, Major Site Plan Review 1137-23, Design Review 5119-23

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and hazardous materials, (5) hydrology/water quality, (6) noise, (7) public services and utilities, (8) transportation/traffic, (9) recreation, and (10) geology/soils.

3. There are no potentially significant off-site and/or cumulative impacts which the GP PEIR failed to evaluate. The Proposed Project is consistent with the land use characteristics of the development considered by the GP PEIR and would represent a small part of the growth that was forecasted for the build-out of the General Plan. The GP PEIR considered the incremental impacts of the Project, and as explained further in the Exemption Checklist below, no significant off-site or cumulative impacts that were not previously evaluated have been identified.

4. There is no substantial new information which results in more severe impacts than anticipated by the GP PEIR. As substantiated in the Exemption Checklist below, no new information has been identified which would result in a determination of a more severe impact than what had been anticipated by the GP PEIR.

5. The Project will undertake feasible Mitigation Measures specified in the GP PEIR. As explained in the Exemption Checklist below, the Proposed Project would undertake feasible Mitigation Measures specified in the GP PEIR.

These GP PEIR Mitigation Measures will be undertaken through Proposed Project design, compliance with regulations and ordinances, the Proposed Project’s conditions of approval, and City permit processing.

1.3. Documents Incorporated by Reference
The following reports and/or studies are applicable to development of the Project Site and are hereby incorporated by reference:
 City of Orange – 2010 General Plan, City of Orange, 2010, available at https://www.cityoforange.org/our-city/departments/community- development/general-plan.
 City of Orange General Plan Final Program Environmental Impact Report, City of Orange, 2010, available at https://www.cityoforange.org/our- city/departments/community-development/general-plan.
 City of Orange 2021-2029 Housing Element, City of Orange, adopted October 2023, available at https://www.cityoforange.org/our- city/departments/community-development/general-plan.
 Orange Municipal Code, available at http://orangecity- ca.elaws.us/code/coor.

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1.4. Contact Person
Any questions about the preparation of the Initial Study, its assumptions, or its conclusions should be referred to the following:

Attn:

City of Orange
Planning Division
300 E. Chapman Avenue
Orange, CA 92866
Phone: (714) 744-2225

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2. PROJECT SUMMARY AND ENVIRONMENTAL DETERMINATION

2.1 Project Summary

1. Project Title: Rancho Ridge Residential Development Project

2. Lead Agency Name: City of Orange
Address Planning Division
300 E. Chapman Avenue
Orange, CA 92866

3. Contact Person: David Blumenthal, AICP
[email protected]
(714) 313-3713

4. Project Location: East side of Rancho Santiago Boulevard South of East Bond Avenue
West of Ranchroad Drive
North of East Walnut Avenue

Site Acres: 1.92-acres

Site Addresses: 647 N. Rancho Santiago Boulevard
Orange, CA 92869

Topographic Quad (USGS 7.5”): Orange

Topographic Quad Coordinates: T4 South, R9 West

Latitude: 33°47'51.3"N, Longitude: 117°48'03.6"W

APN: 379-301-05

5. Project Sponsor’s Rancho Ridge, LLC
Name/Address: 11625 Wander Lane
Dallas, TX 75230

6. General Plan Low-Density Residential (LDR)
Designation:

7. Zoning Designation: Single-Family Residential (R1-10) Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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8. Description of Project:

The Project proposes to establish a Planned Unit Development (PUD) and subdivide the lot into 11 parcels, each improved with a single-family residence. The Project Site is located at 647 N. Rancho Santiago Blvd (APN 379-301-05). The lot and unit configuration were selected to allow the development to operate as a traditional subdivision. The Proposed Project would offer two unique floor plans consisting of three-bedrooms with a loft depending on the floor plan. Unit sizes vary from 2,419 square feet (sq. ft.) to 2,724 sq. ft. Each of the homes would be two-stories and include an attached two-car enclosed garage and a driveway in front of the garage.

Entitlements include the following: Tentative Tract Map (No. 0052-23), Conditional Use Permit (No. 3203-23), Zone Change, Major Site Plan Review (No. 1137-23) and Design Review (No. 5119-23).

9. Surrounding Land Uses:

Surrounding land uses are identified in Table 1 - Surrounding Land Use. The Project Site is currently unimproved, but historical uses have included agriculture and residential developments. All surrounding properties are designated Low Density Residential.

Table 1 - Surrounding Land Use
Direction Land Use Description
North Orange Hill Presbyterian Church and associated surface parking and Santiago Greenhouse
East Single-family residential homes
South Single-family residential homes and commercial services (debris removal service company and tree maintenance company)
West N Rancho Santiago Boulevard and single-family residential neighborhood beyond N Rancho Santiago Boulevard

10. Other Public Agencies Whose Approval is Required:

The following discretionary approvals are required for the proposed Project:

Federal Agencies:
 There are no federal agencies in which discretionary approvals are required.

Local Agencies:
 City of Orange:
o Adopt CEQA compliance documents.
o Approval of Tentative Tract Map No. 0052-23 to split existing parcel into 11 lots (APN 379-301-05)
Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
TTM 0052-23, Zone Change, CUP 3203-23, Major Site Plan Review 1137-23, Design Review 5119-23

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o Approval of Conditional Use Permit No. 3203-23 to allow for a Planned Unit Development that allows for an alternative to standard residential development wherein the existing General Plan densities
o Approval of Major Site Plan Review No. 1137-23
o Approval of Design Review No. 5119-23
o Approval of Zone Change to rezone the property from R-1-10 to R- 1-10 (PUD)
 Santa Ana Regional Water Quality Control Board:
o Approval of a National Pollutant Discharge Elimination System (NPDES) permit to ensure that construction site drainage velocities are equal to or less than the pre-construction conditions and downstream water quality is not worsened.

11. California Native American Consultation:

Assembly Bill 52 (AB 52), signed into law in 2014, amended CEQA and established new requirements for tribal notification and consultation. AB 52 applies to all projects for which a notice of preparation or notice of intent to adopt a negative declaration/mitigated negative declaration is issued after July 1, 2015. CEQA Compliance can be achieved through review and approval of an Exemption pursuant to CEQA Guidelines Section 15183. Therefore, Native American consultation was not required for this Project.

2.2 Organization of Environmental Analysis
This Initial Study is based on an Environmental Checklist Form (Checklist), as suggested in §15063(d)(3) of the State CEQA Guidelines, as amended, and includes a series of questions about the project for each of the listed environmental topics. The Checklist evaluates whether or not there would be significant environmental effects associated with the development of the project and provides Mitigation Measures, when required, to reduce impacts to a less than significant level.

Section 4 provides a discussion of the potential environmental impacts of the Proposed Project. The evaluation of environmental impacts follows the questions provided in the Checklist provided Appendix G to the State CEQA Guidelines.

Environmental effects are evaluated to determine if the Project would result in a potentially significant impact triggering additional review under CEQA Guidelines Section 15183. This CEQA Checklist provides an analysis in support of a determination of whether the Project would result in:

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 an equal or less severe impact than previously identified in the Orange General Plan (OGP) Final Program Environmental Impact Report (GP PEIR), or
 new impacts, or a substantial increase in the severity of a significant impact as disclosed in the GP PEIR.

The effect of the Proposed Project is categorized into one of the following five categories of possible determinations:

Project Peculiar
Impact that is
not Substantially
Mitigated by
Uniform Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the GP PEIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed in
the GP PEIR
Adverse Impact
More Severe Based
on Substantial New
Information
No New
Impact
 Items checked “Peculiar Impact that is Not Substantially Mitigated” indicates that the Project could result in a peculiar impact, including a physical change that belongs exclusively or especially to the Project or that is a distinctive characteristic of the Project or the Project Site and that peculiar impact is not substantially mitigated by the imposition of uniformly applied development policies or standards.
 Items checked “Significant Impact not Analyzed as Significant Effect in GP PEIR” indicates that the Project could result in a significant effect that was not analyzed as significant in the GP PEIR.
 Items checked “Potentially Significant Offsite or Cumulative Impact not Discussed in the GP PEIR” indicate the Project could result in a significant offsite or cumulative impact that was not discussed in the GP PEIR.  Items checked “Adverse Impact More Severe based on Substantial New Information” indicate that previously identified significant effects, which as a result of substantial new information which was not known at the time the GP PEIR was certified, are determined to have a more severe adverse impact than discussed in the GP PEIR with build-out of the Project.  Items checked “No New Impact” indicates that the potential impacts from the Project have been adequately analyzed in the GP PEIR or does not have a significant impact on the environment.

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2.3 Environmental Factors Potentially Affected
Based on the analysis in Section 4, the Proposed Project could potentially affect (“Potentially Significant”) the environmental factor(s) checked below. The following pages present a more detailed checklist and discussion of each environmental factor and identifies where Mitigation Measures would be necessary to reduce all impacts to less than significant levels.

Aesthetics Agriculture and Forestry
Resources Air Quality
Biological Resources Cultural Resources Energy
Geology and Soils Greenhouse Gas Emissions Hazards and Hazardous Materials
Hydrology and Water
Quality Land Use and Planning Mineral Resources
Noise Population and Housing Public Services
Recreation Transportation Tribal Cultural Resources
Utilities and Service
Systems Wildfire Mandatory Findings of
Significance

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2.4 Determination
On the basis of this initial evaluation, the following finding is made:

X
The Proposed Project WOULD NOT result in: 1) a peculiar impact that was not identified as a significant impact under the prior EIR; 2) a significant impact that was not analyzed as significant in the prior EIR; 3) a potentially significant offsite impact or cumulative impact not discussed in the prior EIR; or 4) a more severe impact due to substantial new information that was not known at the time the prior EIR. NO FURTHER ACTION is required and a Notice of Determination (Section 15094) will be filed indicating that the Proposed Project IS ELIGIBLE for an EXEMPTION under State CEQA Guidelines Section 15183.

The Proposed Project would result in: 1) a peculiar impact that was not identified as a significant impact under the prior EIR; 2) a significant impact that was not analyzed as significant in the prior EIR; 3) a potentially significant offsite impact or cumulative impact not discussed in the prior EIR; or 4) a more severe impact due to substantial new information that was not known at the time the prior EIR. I find that FURTHER ENVIRONMENTAL REVIEW is necessary to analyze those effects that are subject to CEQA, and therefore, this Project is NOT ELIGIBLE for an EXEMPTION under State CEQA Guidelines Section 15183.

Signature Date

Name Title

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3. PROJECT DESCRIPTION

3.1 Background
The Project Site is located at 647 N. Rancho Santiago Boulevard in the City of Orange (City), Orange County, California (APN: 379-301-05) (see Figure 1 – Regional Vicinity and Figure 2 – Site Location Map – Aerial View). Review of available historical aerial imagery, topographic maps, and historical documentation shows that the Project Site was first used for single-family residential around 1896-1898 and agricultural land sometime around 1938-1950.

In 1964, the Project Site contained two small structures that were likely single-family residences. Sometime before 1972, the building on site was redeveloped and expanded on the western portion of the site, while the eastern portion of the site remained undeveloped, and the property to the north developed the church building and plant nursery that stand today. The single-family homes across Rancho Santiago Blvd to the west were developed sometime between 1966 and 1972. The single-family homes to the east of the site were developed sometime between 1972 and 1980. Aerial photographs from 1980 show that the property gained an addition of a pool near the buildings, and either small buildings or storage containers on the eastern portion of the site. The site remained with this development, with small improvements to buildings, storage and shade coverings on the eastern portion of the site, and changes in landscaping until sometime before 2022, where historical images show the development to be demolished.

From 2022 until the present time, the site is left vacant with a concrete pad in the northwestern corner and a driveway in the southwestern corner of the site. and The remainder of the site covered by dirt, shrubs and a few trees along the western boundary.

The Project Site is currently comprised as a single parcel with a total acreage of

1.92-acres. As discussed above, the Project Site is currently vacant, but historical uses have included agricultural and single-family residential uses. The Project Site is designed to accommodate the Proposed Project of 11 subdivided parcels, each improved with a single-family residence.

Project Site Setting
The Project Site is approximately 323 feet south of the Bond Avenue centerline and is currently vacant, but historical uses have included agricultural and residential developments. The northern and eastern site boundaries are bound by a masonry wall, while the southern and western site boundaries are bound by a chain-linked fence. The western site boundary also contains two paved driveway entry points. Surrounding land uses include Orange Hill Presbyterian Church and Santiago Greenhouse to the north, N Rancho Santiago Boulevard and single- family residences to the west, single-family residences to the east, and single- family residences and a tree maintenance company to the south.

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Site Zoning
As shown in Figure 3 – General Plan Land Use Designation and Figure 4 – Zoning Map, the parcel is zoned Single-Family Residential (R1-10) and has an OGP land use designation of Low Density Residential. The Project proposes to utilize a Planned Unit Development (PUD) to propose a zone change from R-1-10 to R-1- 10 (PUD). According to the OGP, “Table LU-3 indicates the corresponding zone district that applies to each General Plan land use designation.” The Proposed Project would comply with all the development standards established in the zoning code for the PUD except the minimum lot area. The lot area has been modified for consistency with the General Plan land Use Designation Density.

Furthermore, the project would comply with the design guidelines established in the City of Orange Infill Residential Design Guidelines.

3.2 Project Characteristics
The Proposed Project would be to establish a Planned Unit Development (PUD) and subdivide the lot into 11 parcels, each improved with a single-family residence as shown in Figure 5 – Conceptual Site Plan. The lot and unit configuration were selected to allow the development to operate as a traditional subdivision. The Proposed Project would offer two unique floor plans consisting of 3-bedrooms with a loft depending on the floor plan. Unit sizes vary from 2,419 square feet to 2,724 square feet. Each of the homes would be two-stories and provide a two-car enclosed garage and a two-car driveway in front of the garage.

Each detached single-family residence would provide a 10’ minimum setback from the common driveway, 5’ setback from the side property line, and 20’ or 34’ rear property line. Access to the Project Site is located off of Rancho Santiago Boulevard. Access to each of the parcels would be provided through a 25-foot- wide common driveway easement that runs along the southern portion of the Project Site. A 30-foot wide Fire Department hammerhead that would meet the City’s standards is provided on the eastern side of the common driveway easement, which would also double for trash truck turn around. The 25-foot-wide common driveway also provides sufficient space to accommodate all necessary utilities for the units (utility easement would be recorded).

The Project Site is designated as Low Density Residential by the Orange General Plan and is zoned R-1-10. According to the General Plan, “Table LU-3 indicates the corresponding zone district that applies to each General Plan land use designation.” Furthermore, this development would be consistent with Land Use Policy 1.3, “Provide a range of housing densities and types to meet the diverse Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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needs and lifestyles of residents” by allowing a housing density that is consistent with the neighborhood and adding new units to the City’s housing stock.

The Proposed Project includes the following:

Utilities and Services:

Water services, including domestic water supply, sanitary sewer and recycled water services, would be provided by the Metropolitan Water District of Southern California (MWD).

The Southern California Gas Company has facilities in the area to service gas to the Proposed Project. Natural gas services are subject to change based on supply conditions and are designed to comply with federal agencies, environmental regulations, and local jurisdiction policy.

Electrical Infrastructure would be serviced by Southern California Edison. SCE may need to conduct utility studies to assess whether additions or modifications to the existing electrical infrastructure are required to serve the Proposed Project. Site plans, contracts and agreements, applicable fees, local permits, and required easement documents are necessary before SCE can schedule construction.

Both Cox Internet and AT&T have facilities to provide telecommunications and cable services.

Trash services would be served by CR&R Incorporated to supply trash can placements.

3.2.1 Construction Timing
The Proposed Project is expected to begin construction in 2025. Construction completion and operations would be expected sometime in 2027.

Construction activities include the following:

Demolition: Demolition would require the use of one concrete/industrial saw, one rubber-tired dozer, and one tractor/loader/backhoe for eight (8) hours per day.

The total estimated time for demolition is estimated to be 42 construction days.

Grading: Grading the Project Site would require the use of one grader and one rubber-tired dozer for 8 hours a day, and two tractors/loaders/backhoes for seven (7) hours per day. The total estimated time for grading the Project Site is 15 construction days.

Building Construction: Building construction of the 11 homes would be the longest part of the construction process, estimating a time frame of 422 construction days.

Building construction would require the use of one crane, one forklift, and one tractor/loader/backhoe for six (6) hours per day, and one generator set and three welders for 8 hours per day.

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Paving: The paving process would require the use of one cement and mortar mixer and one paver for 6 hours per day, one roller for 7 hours per day, and one paving equipment and one tractor/loader/backhoe for 8 hours per day. The total estimated time for paving is estimated to be 24 construction days.

Architectural Coating: The architectural coating would require one air compressor for 6 hours per day for 25 construction days.

The long-term energy demand for the project construction operations would not result in a wasteful or inefficient use of energy. The project construction operations would not conflict with or obstruct the State’s or Local plans for renewable energy or energy efficiency.

3.2.2 Best Management Practices During Construction
The following best management practices would be incorporated into the Proposed Project’s construction specifications to identity how the Proposed Project would conform to Federal, State, and Local regulations:
 Migratory Bird Treaty Act Compliance. Bird nesting season generally extends from February 1 through September 15 in southern California and specifically, April 15 through August 31 for migratory passerine birds. To avoid impacts to nesting birds (common and special status) during the nesting season, a qualified Avian Biologist will conduct pre‐construction Nesting Bird Surveys (NBS) prior to Project‐related disturbance to nestable vegetation to identify any active nests. If no active nests are found, no further action will be required. If an active nest is found, the biologist will set appropriate no‐work buffers around the nest which will be based upon the nesting species, its sensitivity to disturbance, nesting stage and expected types, intensity and duration of disturbance. The nests and buffer zones shall be field checked weekly by a qualified biological monitor. The approved no‐work buffer zone shall be clearly marked in the field, within which no disturbance activity shall commence until the qualified biologist has determined the young birds have successfully fledged and the nest is inactive.
 Accommodation for Unanticipated Cultural/Paleo Resources. In the event that evidence of archaeological resources is unearthed during construction activities, all work within 50 feet of the discovery will be halted or diverted until a qualified archaeologist can evaluate the nature and significance of the finds. No disturbance will occur in the vicinity of the find until the Project Site is evaluated by the archaeologist and the find is recorded or treated per the recommendations of the qualified archaeologist.

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 Public Resources Code (Human Remains). In the event that human remains are discovered, there shall be no disposition of such human remains, other than in accordance with the procedures and requirements set forth in California Health and Safety Code Section 7050.5 and Public Resources Code Section 5097.98. These code provisions require notification of the County Coroner and the Native American Heritage Commission, who in turn must notify those persons believed to be most likely descended from the deceased Native American for appropriate disposition of the remains.

Excavation or disturbance may continue in other areas of the Project Site that are not reasonably suspected to overlie adjacent remains or archaeological resources.
 National Pollution Discharge Elimination System. Because the Project Site is greater than 1 acre, the applicant is required by the Santa Ana Regional Water Quality Control Board to prepare a Stormwater Pollution Prevention Plan (SWPPP) to address water quality and runoff during construction to comply with the State of California General Construction Permit. The SWPPP will outline the source control and/or treatment control Best Management Practices (BMPs) to avoid or mitigate runoff pollutants at the construction site to the “maximum extent practicable.” All recommendations in the Plan shall be implemented during area grading and construction. The Proposed Project shall comply with each of the recommendations detailed in the Plan, and other such measure(s) as the City deems necessary to mitigate potential stormwater runoff impacts.
 South Coast Air Quality Management District (SCAQMD). During construction, the applicant is required to comply with various rules and regulations from the SCAQMD, including dust control and architectural coatings.

Based on the report by CalEEMod, the construction activities would have less than significant regional air quality impact and a less than significant localized impact.

3.3 Project Operations
The Proposed Project would fulfill the City’s Housing Element goal (Goal 1, Goal 2) to facilitate the development of high-quality neighborhoods and housing stock and to accommodate Orange’s Regional Housing Needs Allocation (RHNA). The Project Site in Orange is designed to accommodate the development of 11 two- story single-family homes that range in size from 2,425 square feet to 2,724 square feet.

The Proposed Project would include activities typical of residential development, such as landscape maintenance, daily vehicle trips for residents’ departure and arrival, street cleaning, and common open space. The GP PEIR anticipated a Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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population of 153,522 and total housing units to be 66,850 by 2030, using SCAG 2004 Growth Forecast. According to the U.S. Census Bureau, the City’s current (July 2023) population is 138,3371 and the average persons per household from 2018 through 2022 was 2.98. According to this data, the Proposed Project will increase the population by approximately 33 persons with the addition of 11 single-family dwellings.

Operation of the Proposed Project would require electricity for multiple purposes, including cooling, lighting, appliances, and various equipment. Project operation would require natural gas for various purposes, including water heating and natural gas appliances. Petroleum fuel consumption for the Proposed Project is associated with automobile and truck trips traveling to and from the Project Site.

3.4 Project Approvals
The following approvals and permits are required from the City of Orange to implement the Proposed Project:
 Adopt Initial Study/CEQA Guidelines Section 15183 Analysis with the determination that the analysis has been prepared in compliance with the requirements of CEQA.
 Approval of Tentative Tract Map No. 0052-3 to subdivide the parcel into 11 lots
 Approval of Conditional Use Permit No. 3203-23 to allow the Planned Unit Development (PUD) to provide an alternative to standard residential development wherein the existing General Plan densities  Zone Change to rezone the property from R-1-10 to R-1-10 (PUD)  Approval of Major Site Plan Review No. 1137-23
 Approval of Design Review No. 5119-23

1 U.S. Census Bureau QuickFacts: Orange city, California Rancho Ridge Residential Development
Initial Study/CEQA Analysis under CEQA § 15183 Exemption Figure 1: Regional Vicinity
Source: Google Earth

Project Location
-Not to Scale

Rancho Ridge Residential Development
Initial Study/CEQA Analysis under CEQA § 15183 Exemption Figure 2: Site Location
Source: Google Earth

Project Location
-Not to Scale

Rancho Ridge Residential
Initial Study/CEQA Analysis under CEQA § 15183 Exemption Figure 3: General Plan Designation
Source: City of Orange

Project Location
-Not to Scale

Rancho Ridge Residential
Initial Study/CEQA Analysis under CEQA § 15183 Exemption Figure 3: Zoning Map
Source: City of Orange

Project Location
-Not to Scale

Rancho Ridge Residential
Initial Study/CEQA Analysis under CEQA § 15183 Exemption Figure 5: Conceptual Site Plan
Source: William Hezmalhalch Architects, INC. (WHA)

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4. EVALUATION OF ENVIRONMENTAL IMPACTS
This analysis has been prepared to determine whether the Proposed Project would result in any new significant impacts or a substantial increase in the severity of previously identified significant impacts in the General Plan PEIR. 1) All answers must take account of the whole action involved, including offsite as well as onsite, cumulative as well as Project-level, indirect as well as direct, and construction as well as operational impacts.
2) A list of “Supporting Information Sources” must be attached and other sources used, or individuals contacted should be cited in the Narrative Summary for each section.
3) Response column heading definitions:
a) Potentially Significant Impact is appropriate if there is substantial evidence that an effect may be significant. If there are one or more “Potentially Significant Impact” entries when the determination is made, an Environmental Impact Report (EIR) is required.
b) Potentially Significant Unless Mitigation Incorporated applies where the incorporation of Mitigation Measures has reduced an effect from “Potentially Significant Impact” to a “Less Than Significant Impact”. The Mitigation Measures must be described, along with a brief explanation of how they reduce the effect to a less than significant level. c) Less Than Significant Impact applies where the Project creates no significant impacts, only “Less Than Significant impacts”. d) Impacts Analyzed in GP PEIR; No New Impact applies where the impacts for the category were analyzed in the GP PEIR and implementation of the Proposed Project would not result in any new impacts that were not analyzed in the GP PEIR.
e) No Impact applies where a Project does not create an impact in that category. A “No Impact” answer is adequately supported if the referenced information sources show that the impact simply does not apply to Projects like the one proposed (e.g., the Project falls outside of a fault rupture zone). A “No Impact” answer should be explained where it is based on Project-specific factors as well as general standards (e.g., the Project would not expose sensitive receptors to pollutants, based on a Project-specific screening analysis).
4) Earlier analyses may be used where, pursuant to a tiering, program EIR, Master EIR, or other California Environmental Quality Act (CEQA) process, an effect has been adequately analyzed in an earlier EIR or negative declaration (§ 15062(c)(3)(D)). In this case, a brief discussion should identify Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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the following:
a) Earlier Analysis Used. Identify and state where they are available for review.
b) Impacts Adequately Addressed. Identify which effects from the checklist were within the scope of and adequately analyzed in an earlier document pursuant to applicable legal standards, and state whether such effects were addressed by Mitigation Measures based on the earlier analysis.
c) Mitigation Measures. For effects that are “Less than Significant with Mitigation Measures Incorporated”, describe the Mitigation Measures which were incorporated or refined from the earlier document and the extent to which they address site-specific conditions for the Project. 5) Incorporate into the checklist any references to information sources for potential impacts (e.g., the General Plan, zoning ordinance). Reference to a previously prepared or outside document should, where appropriate, include a reference to the page or pages where the statement is substantiated.
6) The explanation of each issue should identify:
a) The significance criteria or threshold, if any, used to evaluate each question; and
b) The mitigation measure identified, if any, to reduce the impact to less than significant.

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4.1 Aesthetics and Visual Resources
Impact Analysis

X
c) In nonurbanized areas,
substantially degrade the existing
visual character or quality of
public views of the site and its
surroundings? (Public views are
those that are experienced from a
publicly accessible vantage
point). If the project is in an
urbanized area, would the project
conflict with applicable zoning
and other regulations governing
scenic quality?

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

X
General Plan PEIR Mitigation Measures
General Plan PEIR Mitigation Measure Applicable/Not Applicable

5.1-1 Upon adoption of the General Plan, the City will
initiate and update the Zoning Code. The update will
Mitigation Measure is not
applicable.

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General Plan PEIR Mitigation Measure Applicable/Not Applicable create zoning districts to implement policies in the
Elements for Land Use, Noise, Urban Design, and Cultural Resources. This and all future updates to the Zoning Code will include an active public participation process.

Specific revisions of the Zoning Code will be completed to address:
 A designation process for cultural resources to be
listed in the City’s local register, to include a broad range of historic resources, including separate or
individual buildings, structures, objects, and sites, as well as districts and archaeological resources;
 Adaptive reuse of potential and listed historic
resources. The City will consider provisions for
including Neighborhood Character Areas (NCAs)
as a zoning overlay. The following planning areas
may be considered for this zoning revision: the El
Modena, Cypress Street Barrio, and
Railroad/Packinghouse Corridor neighborhoods.
 Development interface with Santiago Creek, the
Santa Ana River, and other open space areas.
(Implementation Program I-1)
Until such time as the City adopts the Zoning Ordinance, all new development shall comply with the lighting, design, viewshed and related standards set forth in the current Zoning Code, or the standards established through a
development agreement or specific plan for a particular development project.

However, the Proposed
Project would comply with
the lighting, design,
viewshed, and related
standards set forth in the
Zoning Code.

5.1-2 Prepare new design criteria for public gathering
spaces, tourist commercial uses, rural development
character, viewshed protection and preservation, and
additional policies for mixed use development and transit- oriented development as needed. New design criteria
should also include landscape standards that provide
buffers such as open space, urban green zones, and other appropriate transitions between lower density, single-
family neighborhoods and higher density development.

Design criteria should also address standards for the
provision of community gathering spaces within private
development, incentives to provide accessible open
spaces in commercial and mixed-use corridors, and
Mitigation Measure is not
applicable.

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General Plan PEIR Mitigation Measure Applicable/Not Applicable guidelines for the preservation of visual points of interest throughout the community. (Implementation Program I-6)

5.1-3 Prepare, adopt, and implement a pedestrian-
oriented streetscape master plan as part of the City’s
decision to enhance the walkability of public spaces, with the goal of promoting multimodal transportation options.

This plan will include the City’s key commercial corridors, such as Tustin Street, Chapman Avenue, Main Street, and Katella Avenue. The master plan should integrate
concepts discussed for these corridors throughout the
General Plan related to pedestrian facilities, streetscapes, urban green zones, façade improvements, and signage.
(Implementation Program I-13)
Mitigation Measure is not
applicable.

5.1-4 Develop a Streetscape Improvement Program for
major and minor streetscapes, bikeways, and trails that includes standard plans and design criteria for unified lighting; paving materials and patterns; and landscaping such as street trees, median and slope planting, and
landscaped parkways.

The Streetscape Improvement Program also includes
development of specific standards to define and
designate the following City Scenic Highways:
 Jamboree Road
 Santiago Canyon Road
 Newport Boulevard
(Implementation Program I-14)
Mitigation Measure is not
applicable.

5.1-5 Update design guidelines to incorporate the
elements of community design character that reflect
Orange’s historic and cultural background. Require new
development to incorporate the elements of the
community’s character and design into its projects.

Determine how to retrofit the existing commercial,
industrial, institutional, and mixed-use areas to include the community character elements. Community character
elements can include, but are not limited to, architectural style, landscape style, streetscape, and signage.
(Implementation Program I-24)
Mitigation Measure is
applicable. The Proposed
Project would be built with
high-quality materials that
would be consistent with
the surrounding residential
land uses.

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General Plan PEIR Mitigation Measure Applicable/Not Applicable

5.1-6 Seek and develop appropriate incentives for project applicants and developers that provide public access to private green spaces in new, infill, and existing
development. Work to establish neighborhood identity
through the use of green spaces. When developed,
incorporate applicable incentives into the Zoning Code to facilitate the provisions of applicable green spaces.

Establish a program to transfer to the City, through land exchanges, purchases, or long term no-fee leases, land
that is not currently in productive use such as derelict land, tax delinquent land, surplus road and highway rights-of- way, and other land located adjacent to existing open
spaces, waterways, or trails. (Implementation Program I- 25)
Mitigation Measure is not
applicable.

5.1-7 Comply with all City procedures in the review of
proposed development projects and use the site plan
review process to ensure that applicable General Plan
policies and City standards and regulations are applied to proposals for specific development projects.
(Implementation Program III-2)
Mitigation Measure is
applicable. The Proposed
Project would comply with
all City procedures for
review processes. The
Proposed Project complies
with the applicable General
Plan policies and City
standards and regulations.

5.1-8 As part of the development application and review process, coordinate with SCE, Time Warner Cable, Cox
Communications Orange County, The Gas Company,
AT&T, cellular telephone service providers, and other local utilities to assess capacity and infrastructure needs to support new development or redevelopment activities.

Require that utilities be moved underground consistent
with the City’s Master Utility Undergrounding Plan.
(Implementation Program V-1)
Mitigation Measure is
applicable. The Proposed
Project would include
coordination with all
applicable utility providers
to assess capacity and
infrastructure needs.

5.1-9 Adopt, review, implement, and update as necessary the following master plans, standards, and guidelines:
 Scenic highway standards for Santiago Canyon
Road, Jamboree Road, and Newport Boulevard
 Historic Preservation Design Standards for Old
Towne
 Design guidelines and/or standards for large
complexes or districts of potential or listed historical resources
Mitigation Measure is not
applicable.

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General Plan PEIR Mitigation Measure Applicable/Not Applicable  Street Tree Master Plan
 Tustin Street Design Standards
 Design standards for areas where the General Plan
is changing land uses, including the Southwest
Project Area, Chapman Avenue, and South Main
Street
 Redevelopment Plan
(Implementation Program V-1)
Discussion
a) Have a substantial adverse effect on a scenic vista? b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? c) In nonurbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Narrative Summary: Impacts Analyzed in General Plan PEIR (a-d) Less Than Significant Impacts with Mitigation. The GP PEIR analyzed the aesthetic impacts associated with the implementation of the OGP. The GP PEIR identified that implementation of programmatic Mitigation Measures would reduce potential impacts to a less than significant level. Individual development projects would be required to undergo project-specific environmental review and Mitigation Measures would be identified to reduce any significant impacts associated with a project. Mitigation Measures 5.1-1 through 5.1-9 encourage the City to establish programs and updates to the OGP and Zoning Code to create standards, policies and procedures for new development projects to follow in order to maintain and improve community character and reduce impacts to scenic vistas and scenic resources. Proposed development under the OGP in some portions of the eastern planning area would change the nature of the scenic resources. Mitigation Measures 5.1-1 through 5.1-7 and 5.1-9 would reduce the potential impacts from buildout of the OGP to a less than significant level.

Mitigation Measure 5.1-8 ensures that current utilities and infrastructure have capacity to accommodate future development projects. In the urbanized portion of the planning area, OGP implementation would increase the density and intensity of development, that may result in the alteration of the visual character of unique neighborhoods. Mitigation Measures 5.1-1 through 5.1-9 Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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would reduce these potential impacts to a less than significant level by establishing design and development standards and guidelines for future development, including revisions of the Zoning Code and OGP. Additionally, new development associated with the OGP Buildout may increase light and glare in the community but would be reduced to a less than significant level with implementation of Mitigation Measures 5.1-1 through 5.1-4. Mitigation Measures

5.1-1 through 5.1-4 requires new development to follow the City’s applicable design criteria, zoning code revisions, master plans, programs, and guidelines.

Therefore, impacts related to scenic vistas, scenic resources, visual character, and light and glare are reduced to a less than significant level with implementation Mitigation Measures 5.1-1 through 5.1-9.

Impacts Associated with the Proposed Project:
a) Have a substantial adverse effect on a scenic vista? No New Impacts. A scenic vista is the view of an area that is visually or aesthetically pleasing from a certain vantage point, typically viewed from some distance away. Aesthetic components of a scenic vista include (1) scenic quality, (2) sensitivity level, and (3) view access. A scenic vista can be impacted by a development project having visual impacts by directly diminishing the scene quality of the vista or by blocking the view corridors or “vista” of the scenic resources. Important factors to determine whether a proposed project would have an effect on a scenic vista include the project’s proposed height, mass, and location relative to surrounding land uses and travel corridors. The Proposed Project does not contain a scenic vista; however, the City of Orange has scenic viewscape corridors along Santiago Canyon Road and Jamboree Road in Santiago Hills and East Orange. Portions of the City’s planning area contain scenic vistas or resources, such as Irvine Lakes, grassy valleys, rugged hillside, rock outcroppings, and window canyons, of which can be viewed from Santiago Canyon Road. The Proposed Project is not expected to impact these scenic resources or viewpoints.

The Proposed Project is located approximately 540 feet west of the El Modena Open Space. The OGP mentions the El Modena Open Space as one of the many ecological and biological resources part of the Central and Coastal Orange County Natural Communities Conservation Plan (NCCP) Habitat Reserve (Natural Resources Element, NR-9, NR-33). The Proposed Project proposes to develop 11 two-story dwellings on a vacant site. There are one-to-two-story single-family residential homes in between the Project Site and El Modena Open Space area.

The Proposed Project does not propose any features that would impact any scenic vistas. Additionally, the Proposed Project would adhere to GP PEIR Mitigation Measures 5.1-1 through 5.1-9, which require new developments to adhere to the City’s Zoning Code and any other applicable design standards.

Therefore, GP PEIR Mitigation Measures 5.1-1 through 5.1-9 would reduce the any Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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impacts on scenic vistas to a less than significant level. The Proposed Project is not located on or immediately adjacent to any scenic vistas. Therefore, the Proposed Project would not result in a new significant impact or in a substantial increase in the severity of the impacts identified in the GP PEIR, and no new mitigation is required.
b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? No New Impacts. The GP PEIR Mitigation Measure 5.1-4 designates Jamboree Road, Santiago Canyon Boulevard, and Newport Boulevard as City Scenic Highways to preserve the scenic nature of the open space adjacent to the road.

The Project Site is located approximately 2.2-miles west of Jamboree Road, one mile south of Santiago Canyon Boulevard, 1.6-mile west of Newport Boulevard.

The Proposed Project does not propose any features that would impact the City Scenic Highways. As discussed in threshold a, the Proposed Project is not expected to impact the City’s viewscape corridors, including rock outcroppings.

The Proposed Project does not substantially damage any scenic resources and scenic highways, and no new impacts would occur and no new mitigation would be required.
c) In nonurbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
No New Impacts. The Project Site is located in an urbanized area, zoned as Single- Family Residential (R-1-10), and has a OGP land use designation of Low Density Residential. The Proposed Project intends for the Project Site to remain Single- Family Residential with a PUD overlay. The Proposed Project would comply with the R-1-10 and PUD standards, as applicable.

Although the Proposed Project would substantially alter the existing character of the Project Site by changing it from vacant to residential structures, it would not degrade the aesthetic quality of the Project Site surroundings. The buildings would be aesthetically pleasing with neutral color tones, architectural pop-out elements, and on-site improvements. The Proposed Project would provide landscaping throughout the Project Site consisting of trees, shrubs, and groundcover. The Proposed Project would be in conformance with surrounding properties as well as zoning and other regulations governing scenic quality.

The Proposed Project would comply with several General Plan policies regarding scenic quality and aesthetics:

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Table 2 – General Plan Policies (Scenic Quality and Aesthetics) Policy Project Compliance
Goal LU-1: Meet the present and future needs of all residential and business sectors with a diverse and balanced mix of land uses
Policy LU-1.3: Provide a range of housing
densities and types to meet the diverse
needs and lifestyles of residents
The Proposed Project would provide a
different housing density than surrounding
properties to diversify the types of housing
within the area.

Policy LU-1.4: Ensure that new
development reflects existing design
standards, qualities, and features that are
in context with nearby development.

The Proposed Project includes similar
design standards and features to
surrounding development, developed
with aesthetically pleasing neutral color
tones, landscaped areas and
architectural pop-out elements.

Goal UD-6: Encourage contextually appropriate infill development projects and property renovations
Policy UD-6.2: Ensure that new infill
development contributes positively to the
quality of the surrounding corridor or
neighborhood, including the potential to
provide additional park space, and
minimize the visibility of on-site parking
The Proposed Project would improve the
quality of the land as well as provide
additional usable open space. The
attached garages minimize the visibility of
on-site parking.

Policy UD-6.5: Provide logical transitions
between higher intensity development
within the City’s established commercial,
office, and institutional corridors and
nearby single-family neighborhoods.

Scale, massing, and the location of
services within these corridors should
respond sensitively to adjacent residential
uses.

The Proposed Project proposes Low
Density Residential development in a
predominantly Low Density Residential
area, but varies with Single Family zoning
requirements, such as density and
development standards, creating more
ability to transition to higher intensity of
development to surrounding areas.

Goal NR-7: Protect significant view corridors, open space, and ridgelines within the urban environment.

Policy NR-7.3: Encourage the
development of landscaped medians
and parkway landscaping along arterial
streets in public and private projects, and
encourage the state to provide freeway
landscaping.

All frontages of the Project Site, including
along Rancho Santiago Blvd., would be
landscaped. There are pedestrian
connections from Rancho Santiago Blvd.
into the Project Site that are landscaped.

The Proposed Project entry via Rancho
Santiago Blvd also includes an entry
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monument and entry driveway with
enhanced paving.

Source: Orange General Plan – Land Use Element and Urban Design Element Compliance with the General Plan goals and policies will ensure the Project does not conflict with applicable regulations governing scenic quality. Therefore, the impact is less than significant, and no new mitigation is required. d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
No New Impacts. The Project Site is located on a Single Family Residential (R-1-10) zoned parcel, which is currently vacant and not emitting any light. The Project Site is in an urbanized area and surrounded by primarily residential and commercial uses. All lighting would be consistent with the requirements of the OMC Section

17.12.030 – Lighting. Generally, the standards state that lighting on any premises shall be directed, controlled screened or shaded so that direct glare and reflections are contained within the boundaries of the parcel, not to shine directly on surrounding premises. Lighting shall be controlled to prevent glare and direct light of any public sidewalks or thoroughfares. All lighting fixtures shall be appropriate in scale, intensity, and height to the use served. As such, the Project would not create a new source of substantial light or glare that would adversely affect day or nighttime view in the area and impacts are anticipated to be less than significant, and no new mitigation is required. There are no new impacts beyond what is analyzed in the GP PEIR.

Conclusion
The Proposed Project would not result in a new significant impact or in a substantial increase in the severity of the aesthetic impacts previously identified in the GP PEIR, and no mitigation would be required. Implementation of the Proposed Project would not contribute to a project specific or cumulatively considerably adverse impact. The Proposed Project would not result in any peculiar impacts or any new significant impacts that were not already discussed in the GP PEIR. Accordingly, no further review is required. With regards to the issue area of Aesthetics, the following findings can be made:

1. No peculiar impacts to the Project or its site have been identified.

2. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

3. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

4. No Mitigation Measures contained within the GP PEIR would be required because Project-specific impacts would be less than significant. GP PEIR uniformly applied development policies and Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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standards have been implemented through the Proposed
Project.

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4.2 Agriculture and Forestry Resources
Impact Analysis

CEQA THRESHOLDS
Project
Peculiar
Impact that
is not
Substantiall
y Mitigated
by Uniform
Applied
Policies
Significant
Impact not
Analyzed
as
Significant
in the GP
PEIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed
in the GP
PEIR
Adverse
Impact
More
Severe
Based on
Substantial
New
Information
No
New
Impact
from
GP
PEIR
II. AGRICULTURE AND FORESTRY RESOURCES: In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board.

Would the project:
a) Convert Prime Farmland, Unique
Farmland or Farmland of Statewide
Importance (Farmland), as shown
on the maps prepared pursuant to
the Farmland Mapping and
Monitoring Program of the
California Resources Agency, to
non-agricultural use?

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

X
c) Conflict with existing zoning for,
or cause rezoning of, forest land (as
defined in Public Resources Code
section 12220(g)), timberland (as
defined by Public Resources Code
section 4526), or timberland zoned
Timberland Production (as defined
by Government Code section
51104(g))?

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

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

X
General Plan PEIR Mitigation Measures
General Plan PEIR Mitigation Measure Applicable/Not Applicable No GP PEIR Mitigation Measures were required. -
Discussion
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to nonagricultural use?
b) Conflict with existing zoning for agricultural use, or a Williamson Act contract?
c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))? d) Result in the loss of forest land or conversion of forest land to non-forest use? e) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to nonagricultural use or the conversion of forest land to non-forest use? Narrative Summary: Impacts Analyzed in the GP PEIR (a-d) Less than Significant Impact. According to the OGP, there are four different areas located within the City’s planning area that are considered Important Farmland.

Location 1 is designated by the Department of Conservation as Farmland of Statewide Importance and Unique Farmland, and is located at the intersection of Chapman Avenue and Jamboree Road. The OGP designates Location 1 as Public Facilities and Institutions (PFI), allowing for development of public and institutional facilities, schools, and major utility easements and properties.

Although this location is designated as Farmland of Statewide Importance and Unique Farmland, previous development and grading of the property have Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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substantially decreased the possibility of using the Project Site for agricultural production in the future. Location 2 is designated Unique Farmland and is currently being used as a potted plant nursery. Location 3 contains Unique Farmland designated as open space. The Important Farmland in this area is currently being used as a plant nursery, not under active cultivation. Location 4 is also designated as open space, where the Important Farmland in this location is currently being used as a plant nursery and contains a row of greenhouses.

Implementation of the OGP would not alter the designation of location 2, 3 or 4, nor result in the loss of the land for future agricultural use. No conversion of farmland to nonagricultural use would occur with the implementation of the General Plan. Additionally, no land within the planning area is currently under the Williamson Act contract. No Mitigation Measures have been identified as there are no significant impacts to agricultural resources.

Impacts Associated with the Proposed Project (a-d):

No New Impacts. The Proposed Project involves the subdivision of the existing parcel into 11 individual lots to develop 11 single-family homes and associated garages, landscaping, common open space, and driveways. According to the California Department of Conservation (DOC) California Important Farmland Finder (CIFF), the Project Site is designated as rural residential land and is not designated as Prime Farmland, Farmland of Statewide Importance, or Unique Farmland. The Proposed Project would not result in the conversion of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to non- agricultural uses. The Project Site is not currently zoned for agricultural uses and does not propose to rezone any forest land, timberland, or timberland zoned Timberland Production. According to the DOC’s California Williamson Act Enrollment Finder, the Project Site also does not contain land subject to a Williamson Act contract (Figure 6 – Agricultural Designation Map). Although the Project Site was historically used for agricultural Project Site Agricultural Designation Map fields from at least 1946 to sometime before 1963, the Project Site has since been developed for residential uses and is not currently zoned for timberland uses or subject to use as forest land or timberland production. No new impacts related to conflict with existing for forest land, timberland, or timberland production would occur. Additionally, no new impacts related to loss of, or conversion of farmland or forest land to nonagricultural uses would occur.

Therefore, no mitigation would be required.

Conclusion
The Proposed Project would not result in any impacts to agricultural or forestry resources beyond those identified in the previously certified GP PEIR. Therefore, no mitigation is required. The Project would not result in any new significant impacts or in a substantial increase in the severity of impacts evaluated in the GP Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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PEIR that would render Section 15183 inapplicable to the Project. With regards to the issue area of Agricultural and Forestry Resources, the following findings can be made:

1. No peculiar impacts to the Project or its site have been identified.

2. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

3. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

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4.3 Air Quality
Ganddini performed an Air Quality Assessment for the Proposed Project to assess potential impacts to air quality (Appendix A – Rancho Ridge Infill Project Air Quality, Global Climate Change, and Energy Impact Analysis, City of Orange, Ganddini Group, March 31, 2023).

Regulatory Setting
Air pollutants are regulated at the national, state, and regional level. The United States Environmental Protection Agency (EPA) regulates at the national level under the Clean Air Act of 1970. It is responsible for setting and enforcing the National Ambient Air Quality Standards (NAAQS) for atmospheric pollutants. The California Air Resources Board (CARB), which is a part of the California Environmental Protection Agency, is responsible for the coordination and administration of both federal and state air pollution control programs within California. In this capacity, the CARB conducts research, sets the California Ambient Air Quality Standards (CAAQS), compiles emission inventories, establishes emission standards, develops suggested control measures, provides oversight of local programs, and prepares the State Implementation Plan. The South Coast Air Quality Management District (SCAQMD) is responsible for comprehensive air pollution control in the South Coast Air Basin (SCAB). The SCAQMD develops rules and regulations, establishes permitting requirements for stationary sources, inspects emission sources, and enforces such measures through educational programs or fines, when necessary. The SCAQMD is directly responsible for reducing emissions from stationary, mobile, and indirect sources.

There are six common air pollutants, called criteria pollutants, which were identified in the Clean Air Act of 1970.
• Ozone (O3)
• Nitrogen Dioxide (NO2)
• Carbon Monoxide (CO)
• Sulfur Dioxide (SO2)
• Lead (Pb)
• Particulate Matter (PM10 and PM2.5)
The EPA and CARB designate air basins where ambient air quality standards are exceeded as “nonattainment” areas. If standards are met, the area is designated as an “attainment” area. If there is inadequate or inconclusive data to make a definitive attainment designation, they are considered “unclassified.” National nonattainment areas are further designated as marginal, moderate, serious, severe, or extreme as a function of deviation from standards.

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The Project Site is in the City of Orange, which is part of the SCAB region that includes the non-desert portions of Los Angeles, Riverside, and San Bernardino Counties, and all of Orange County. The SCAQMD’s 2022 Air Quality Management Plan (AQMP) assesses the attainment status of the SCAB. The 2022 AQMP builds upon measures already in place from previous AQMPs. It also includes a variety of additional strategies such as regulation, accelerated deployment of available cleaner technologies (e.g., zero emission technologies, when cost-effective and feasible, and low NOx technologies in other applications), best management practices, co-benefits from existing programs (e.g., climate and energy efficiency), incentives, and other Clean Air Act measures to achieve the 2015 8-hour ozone standard. The 2022 AQMP was approved and adopted by CARB on January 26, 2023.

Environmental Setting
The South Coast Air Basin is a 6,600-square-mile coastal plain bounded by the Pacific Ocean to the southwest and the San Gabriel, San Bernardino, and San Jacinto Mountains to the north and east. The ambient concentrations of air pollutants are determined by the amount of emissions released by sources and the atmosphere’s ability to transport and dilute such emissions. Natural factors that affect transport and dilution include terrain, wind, atmospheric stability, and sunlight. Therefore, existing air quality conditions in the area are determined by such natural factors as topography, meteorology, and climate, in addition to the amount of emissions released by existing air pollutant sources.

Atmospheric conditions such as wind speed, wind direction, and air temperature gradients interact with the physical features of the landscape to determine the movement and dispersal of air pollutants. The topography and climate of southern California combine to make the Basin an area of high air pollution potential. The Basin is a coastal plain connecting broad valleys and low hills, bounded by the Pacific Ocean to the west and high mountains around the rest of the perimeter. The general region lies in the semi-permanent high-pressure zone of the eastern Pacific, resulting in a mild climate tempered by cool sea breezes with light average wind speeds.

The usually mild climatological pattern is disrupted occasionally by periods of extremely hot weather, winter storms, or Santa Ana winds. During the summer months, a warm air mass frequently descends over the cool, moist marine layer produced by the interaction between the ocean’s surface and the lowest layer of the atmosphere. The warm upper layer forms a cap over the cool marine layer and inhibits the pollutants in the marine layer from dispersing upward. In addition, light winds during the summer further limit ventilation. Furthermore, sunlight triggers Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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the photochemical reactions that produce ozone. The region experiences more days of sunlight than any other major urban area in the nation except Phoenix2.

Local Air Quality
The air quality at any site is dependent on the regional air quality and local pollutant sources. Regional air quality is determined by the release of pollutants throughout the air basin. Area sources, including architectural coatings and consumer products subcategories, are the major contributor to VOC emissions.

Mobile sources, stationary point source, and stationary area source categories are the top contributors to NOx, SOx, and PM2.5 emissions, respectively3.

Estimates of the existing emissions in the Basin provided in the 2022 AQMP indicate that collectively, mobile sources account for 46 percent of the VOC, 85 percent of the NOx emissions, 89 percent of the CO emissions and 29 percent of directly emitted PM2.5, with another 18 percent of PM2.5 from road dust. Stationary sources are responsible for most of the SOx emissions in the Basin, with the point source category (larger facilities subject to AER requirements) contributing 49 percent of total SOx emissions. Non-vehicle related area sources, such as commercial cooking are the predominant source of directly emitted PM2.5 emissions, contributing 41 percent of total emissions.

The SCAQMD has divided the South Coast Air Basin into fourteen general forecasting areas and 38 Source Receptor Areas (SRA) for monitoring and reporting local air quality. The SCAQMD provides daily reports of the current air quality conditions in each general forecast area and SRA. The monitoring areas provide a general representation of the local meteorological, terrain, and air quality conditions within the SCAB.

The Project Site is located in the Central Orange County Air Monitoring Source Receptor Area (SRA 17). Data for the project-specific air quality analysis was taken from the Anaheim-Pampas Lane monitoring station (Anaheim Station). The Anaheim Station is located approximately 8.33 miles northwest of the Project Site at 1630 W Pampas, Anaheim.

2 2022 Air Quality Management Plan, South Coast Air Quality Management District (2022). Accessed on August 3, 2024. https://www.aqmd.gov/docs/default-source/clean-air-plans/air-quality-management-plans/2022-air- quality-management-plan/final-2022-aqmp/final-2022-aqmp.pdf?sfvrsn=16 3 Ibid.

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Impact Analysis

CEQA THRESHOLDS
Project Peculiar
Impact that is not
Substantially
Mitigated by
Uniform Applied
Policies
Significan
t Impact
not
Analyzed
as
Significan
t in the

GP PEIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed
in the GP
PEIR
Adverse Impact
More Severe
Based on
Substantial
New
Information
No
New
Impact
III. AIR QUALITY:

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

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

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

X
c) Expose sensitive
receptors to substantial
pollutant concentrations?

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

X
General Plan PEIR Mitigation Measures
General Plan PEIR Mitigation Measure Applicable/Not Applicable

5.3-1 Comply with all provisions of CEQA. In addition to thresholds that may be established or adopted by the City in the future, utilize the following thresholds and/or
Mitigation Measure is
applicable. However, it
should be noted that the
Proposed Project would
adhere to the latest
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General Plan PEIR Mitigation Measure Applicable/Not Applicable procedures for CEQA analysis of proposed projects,
consistent with policies adopted within the General Plan:
 Circulation
o LOS D (volume to capacity [V/C] ratio less
than or equal to 0.90) shall be the lowest
acceptable level of service for both
roadway segments and peak-hour
intersection movements.
o Orange County’s Congestion Management
Plan (CMP) specifies LOS E (V/C ratio less
than or equal to 1.00) as the operating
standard for roadways on the CMP highway
system.
o Projects that increase V/C by 0.01 or more on
affected roadway segments or intersections
experiencing LOS E or F conditions without
the proposed project are considered to
create significant impacts, and mitigation is
required.

All future development proposals shall be reviewed by the City for potential regional and local air quality impacts per CEQA. If potential impacts are identified, mitigation will be required to reduce the impact to a level less than
significant, where technically and economically feasible. (Implementation Program III-1)
provisions of CEQA, which
no longer utilizes LOS to
determine significance of
transportation impacts (SB
743). Vehicle Miles Traveled
(VMT) is used in place of
LOS.

5.3-2 Require major employers of 100 persons or more to institute TDM Plans. Such plans establish incentives to encourage employees to carpool, take public
transportation, bicycle, or use some means other than
private automobiles to get to and from work.
(Implementation Program III-5)
Mitigation Measure is not
applicable.

5.3-3 The City strongly encourages new development and
major renovation projects to employ green building
techniques and materials. Encourage proposed
development projects throughout the City to use
Leadership in Energy and Environmental Design (LEED)
Standards developed by the U.S. Green Building Council
or similar third-party verified program. Encourage building orientations and landscaping that enhance natural
lighting and sun exposure. Prepare guidelines for
sustainable development to encourage incorporation of
these practices in new development. These guidelines will Mitigation Measure is
applicable. The Proposed
Project would comply with
State Title 24 building
construction standards,
Energy Star conservation
standards, and any
applicable mandatory
regulations and standards.

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General Plan PEIR Mitigation Measure Applicable/Not Applicable include measures to maximize soil permeability to address related storm water and surface-water runoff issues.

Require compliance with State Title 24 building
construction standards and Energy Star conservation
standards for all development projects.

Climate change Mitigation Measures identified in the
General Plan EIR shall be incorporated as implementation programs and applied to new development projects upon
adoption of the General Plan. (Implementation Program
III-11)

5.3-4 Use public education activities to accomplish the following objectives:
 Educate residents regarding air and water quality,
including the effects of urban
 runoff;
 Raise public awareness about the importance of
“green building” techniques; and
 Educate the public regarding the benefits of
recycling and waste reduction.

Coordinate education activities and make materials
available to residents. Utilize all available media including forums, flyers, brochures, email, videos, interpretive
displays, workshops, and the City’s website and cable
television channel to accomplish these objectives. Fully utilize the resources of the Orange Public Library to
disseminate this information. Explore partnerships with local schools and educators to develop various educational
programs related to historic preservation, personal and community safety, and environmental awareness.
(Implementation Program IV-3)
Mitigation Measure is not
applicable.

5.3-5 Participate in regional efforts to implement TDM
requirements and support implementation of the employer TDM provisions of the SCAQMD AQMP by working with the
SCAQMD to identify employers within Orange most
suitable for participation in the TDM programs to achieve major reduction of VMT. (Implementation Program IV 6)
Mitigation Measure is not
applicable.

5.3-6 Work with SCAQMD and SCAG to implement the
AQMP and meet all federal and state air quality standards for pollutants. Participate in any future amendments and updates to the AQMP. (Implementation Program V-10)
Mitigation Measure is
applicable. The Proposed
Project would comply with
all applicable regulations
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General Plan PEIR Mitigation Measure Applicable/Not Applicable and rules of the SCAQMD
and the AQMP.

5.3-7 The City shall require each project applicant to
implement the following measures to reduce the exposure of sensitive receptors to TACs from mobile sources, as a condition of project approval:
 Activities involving idling trucks shall be oriented as far away from and downwind of existing or
proposed sensitive receptors as feasible.
 Strategies shall be incorporated to reduce the idling time of main propulsion engines through alternative
technologies such as IdleAire, electrification of truck parking, and alternative energy sources for TRUs to
allow diesel engines to be completely turned off.
 Proposed developments shall incorporate site plans
that move sensitive receptors as far as feasibly
possible from major roadways (100,000+ average
daily trips).
 Projects containing sensitive receptors (such as
residences, schools, day care centers, and medical
facilities) on sites within 500 feet of a freeway must
demonstrate that health risks relating to diesel
particulates would not exceed acceptable health
risk standards prior to project approval.

Mitigation Measure is
applicable. The Proposed
Project shall implement the
following measures to
reduce the exposure of
sensitive receptors to TACs
from mobile sources.

Discussion
a) Conflict with or obstruct implementation of the applicable air quality plan? Narrative Summary: Impacts Analyzed in the GP PEIR (a)
Significant and Unavoidable Impact. The GP PEIR discusses the OGP's impact with the Air Quality Management Plan (AQMP). In preparation of the AQMP, SCAQMD and the Southern California Association of Governments (SCAG) relied on population growth projects in the region to forecast, inventory, and allocate regional emissions from land use and development-related sources. For the purposes of analyzing consistency with the AQMP, the GP PEIR assumed that if the General Plan would accommodate population growth substantially greater than anticipated in the AQMP, then the OGP would conflict with the AQMP. According to SCAG projections, the population in Orange would increase to 153,522 persons in 2030. The OGP, however, could accommodate a population of 194,543 beyond 2030. The GP PEIR states that the General Plan buildout would result in an increase of approximately 23,478 dwelling units, 35.7 million square feet of Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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nonresidential building area over existing conditions, and a net population increase of approximately 57,844 persons.

The GP PEIR states that the OGP would result in emissions in excess of thresholds for criteria air pollutants and precursors for which the region is in nonattainment and would increase population (and thus VMT) beyond that anticipated by SCAG. Therefore, the OGP would conflict with SCAQMD air quality planning efforts (OGP, page 5.3-28).

The GP PEIR assumed that all trips and associated emissions would be new to the City. The GP PEIR assessed air quality short-term impacts and long-term impacts from future development allowed by the General Plan. The GP PEIR relies on the significance criteria established by CARB and SCAQMD. Construction-related emissions of criteria air pollutants (e.g. PM10) and ozone precursors (ROG and NOx) were assessed in accordance with methodologies recommended by CARB and SCAQMD. Emissions of criteria air pollutants and ozone precursors associated with new growth under the OGP were treated as new to the City as a conservative (worst-case) assumption.

Mitigation Measure 5.3-6 requires the City to work with the SCAQMD and SCAG to ensure consistency with the AQMP. The OGP intended to accommodate growth primarily through land use focus areas in already developed areas of the City. Many of the focus areas are adjacent to existing transit services and within walking distance of commercial services. Additionally, the development in these areas would primarily be mixed use development. These factors could lead to a reduction in VMT. However, even with implementation of these goals, policies, and programs, and Mitigation Measure 5.3-6 anticipated population and development consistent with the OGP under the proposed project could lead to operational (mobile-source and area-source) emissions that exceed thresholds.

Therefore, this impact would be significant and unavoidable.

Impacts Associated with the Proposed Project (a):

No New Impacts. The Proposed Project would not conflict with or obstruct implementation of the SCAQMD Air Quality Management Plan (AQMP). The AQMP establishes thresholds for criteria pollutants. Projects that exceed any of the indicated daily thresholds should be considered as having an individually and cumulatively significant air quality impact and are not in compliance with the AQMP. The primary purpose of the air quality plan is to bring an area that does not attain federal and state air quality standards into compliance with those standards pursuant to the requirements of the Clean Air Act and California Clean Air Act. A Proposed Project should be considered to be consistent with the AQMP if it furthers one or more policies and does not obstruct other policies. The SCAQMD CEQA Handbook identifies two key indicators of consistency:

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Criterion 1: Whether the project will result in an increase in the frequency or severity of existing air quality violations or cause or contribute to new violations or delay timely attainment of air quality standards or the interim emission reductions specified in the AQMP.

Criterion 2: Whether the project will exceed the assumptions in the AQMP, or increments based on the years of project buildout and phase.

Based on the air quality modeling analysis contained in Appendix A and included in Tables 4 through 8 below, neither short-term construction impacts, nor long-term operations impacts would result in significant impacts based on the SCAQMD regional and local thresholds of significance. Therefore, the Proposed Project is not projected to contribute to the exceedance of any air pollutant concentration standards and is found to be consistent with the AQMP for Criterion 1.

Regarding Criterion 2, the AQMP incorporates land use assumptions from local general plans and regional growth projections developed by SCAG to estimate stationary and mobile air emissions associated with projected population and planned land uses, namely SCAG’s 2020 Regional Transportation Plan/Sustainable Communities Strategy (RTP). If the proposed land use is consistent with the local general plan, then the impact of the project is presumed to have been accounted for in the AQMP. This is because the land use and transportation control sections of the AQMP are based on the SCAG regional growth forecasts, which incorporates projections from local general plans.

The Project Site is designated as Low Density Residential in the General Plan and is zoned R-1-10. The Project proposes 11 single-family homes on approximately

1.93-acres. The Project proposes to establish a PUD to update the Project Site’s zoning from R-1-10 to R-1-10 (PUD). The Proposed Project will comply with all the development standards established in the zoning code for the PUD except the minimum lot area. The lot area has been modified for consistency with the General Plan land use designation density. The Project is not requesting an amendment to the zoning map to rezone the property. In accordance with California Government Code Section 65589.5(j)(4), “For purposes of this section, a proposed housing development project is not inconsistent with the applicable zoning standards and criteria, and shall not require a rezoning, if the housing development project is consistent with the objective general plan standards and criteria but the zoning for the Project Site is inconsistent with the general plan. If the local agency has complied with paragraph (2), the local agency may require the proposed housing development project to comply with the objective standards and criteria of the zoning which is consistent with the general plan, however, the standards and criteria shall be applied to facilitate and accommodate development at the density allowed on the Project Site by the general plan and proposed by the proposed housing development project.” The California Department of Housing and Community Development (HCD) Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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reaffirmed that cities could not require a rezone/reclassification in the Housing Accountability Act Technical Assistance Advisory, issued on September 15, 2020.

The project would comply with the R-1-10 and PUD standards, as applicable.

Furthermore, the SCAQMD acknowledges that strict consistency with all aspects of the AQMP is not required in order to make a finding of no conflict. Rather, a project is considered to be consistent with the AQMP if it furthers one or more policies and does not obstruct other policies. The project would implement contemporary energy-efficient technologies and regulatory/operational programs required per Title 24, CALGreen and City standards. Generally, compliance with SCAQMD emissions reductions and control requirements also act to reduce project air pollutant emissions. In combination, project emissions- reducing design features and regulatory/operational programs are consistent with and support overarching AQMP air pollution reduction strategies. Project support of these strategies promotes timely attainment of AQMP air quality standards and would bring the project into conformance with the AQMP.

Therefore, the Proposed Project is not anticipated to exceed the AQMP assumptions for the Project Site and is found to be consistent with the AQMP for the second criterion.

Based on the above, the Proposed Project would not result in an inconsistency with the SCAQMD AQMP. A less than significant impact would occur, and no mitigation would be required. No new significant or peculiar impacts from what is analyzed in the GP PEIR are found and the Proposed Project would not result in a new significant impact or in a substantial increase in the severity of the impacts identified in the GP PEIR.
b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
Narrative Summary: Impacts Analyzed in the GP PEIR (b)
Potentially Significant Impact. Short-Term Impacts: Construction-related emissions are described as short-term or temporary in duration and have the potential to represent a significant impact with respect to air quality. The OGP identifies future land uses and does not contain specific development proposals. Buildout of the OGP is dependent on individual housing decisions, employment opportunities, provision of services for housing and supporting commercial uses, land use decisions of the City and other public agencies, regional transportation planning decisions, the decisions of financial institutions related to development projects, and other similar factors. Therefore, construction-related emissions associated with the General Plan implementation are speculative and cannot be determined broadly. Construction-related activities would result in emissions of criteria air pollutants and ozone precursors from site preparation (e.g., excavation, grading, and clearing); exhaust from off-road equipment, material Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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delivery trucks, and worker commute vehicles; vehicle travel on paved and unpaved roads; and other miscellaneous activities (e.g. building construction, asphalt paving, application of architectural coatings and trenching for utility installation). Emissions of ozone precursors are associated primarily with exhaust from off-road construction equipment, worker commute trips, and other construction-related activities.

The GP PEIR conducted modeling that assumed a 20-year planning horizon and compared the estimated emissions from buildout of the OGP with the applicable SCAQMD significance thresholds. Based on the modeling conducted, construction-related activities would result in emissions of ROG, NOX, PM10, and PM2.5 that exceed SCAQMD’s significance thresholds. SCAB is already in nonattainment for these pollutants. Thus, construction-related emissions of ozone precursors could violate or contribute substantially to an existing or projected air quality violation, and/or expose sensitive receptors to substantial pollutant concentrations. The GP PEIR concludes that because of the large amount of development and potential for simultaneous construction of multiple sites, the nonattainment status of the SCAB, and modeled emissions that exceed applicable thresholds, implementation of the OGP could result in a cumulatively considerably net increase of any criteria pollutant for which the project region is non-attainment under SCAQMD air quality standards.

Compliance with OGP policies, relevant SCAQMD rules, and implementation of Mitigation Measures 5.3-1 and 5.3-7 would reduce short-term, construction- related emissions, but not to a less than significant level. Construction-related emissions of criteria air pollutants and precursors would still exceed significance thresholds; for this reason such emissions could violate or contribute substantially to an existing or projected air quality violation, and/or expose sensitive receptors to substantial pollutant concentrations. As a result, this impact would remain significant and unavoidable. Individual development projects would be required to undergo project-specific environmental review. If project-level significant impacts are identified, specific Mitigation Measures would be required.

Long-Term Impacts: The General Plan PEIR modeled area- and mobile-source emissions using URBEMIS 2007 Version 9.2.4 to estimate emissions for land use development projects based on proposed land use types and zones, trip generation increases, and default settings and parameters attributable to analysis period and site location (OGP PEIR, page 5.3-23). Based on the modeling conducted for the General Plan, operational activities would result in emissions of ROG, NOx, CO, PM10, and PM2.5 that exceed the SCAQMD’s applicable thresholds. Thus, operational emissions of these ozone precursors and particulate matter could violate or contribute substantially to an existing or projected air quality violation, and/or expose sensitive receptors to substantial pollutant concentrations. This is a potentially significant impact.

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The General Plan could accommodate stationary sources of pollutants that would be required to obtain permits to operate in compliance with SCAQMD rules. The permit process would ensure that these sources would be equipped with the required emission controls, and that individually, these sources would not cause a significant environmental impact. There is no available methodology to reliably estimate these emissions; nonetheless, the emissions from these sources would be additive to the estimated area-source and mobile-source emissions described above. The OGP contains numerous goals, policies, and implementation programs intended to improve air quality, such as encouraging the use of regional rail and transit to relieve traffic congestion. Compliance with the OGP policies and implementation of Mitigation Measures 5.3-1 through 5.3-7 would reduce operational air quality impacts at a programmatic level, but not to a less than significant level. As a result, this impact would remain significant and unavoidable. Individual development projects would be required to undergo project-specific environmental review. If project-level significant impacts are identified, specific Mitigation Measures would be required.

Impacts Associated with the Proposed Project (b)
No New Impacts. Air pollution is largely a cumulative impact resulting from emissions generated over a large geographic region. The nonattainment status of regional pollutants is a result of past and present development, and the SCAQMD develops and implements plans for future attainment of ambient air quality standards. Based on these considerations, project-level thresholds of significance for criteria pollutants are used to determine whether a project’s individual emissions would have a cumulatively considerable contribution to air quality. If a project’s emissions exceeded the SCAQMD’s significance thresholds, it would be considered to have a cumulatively considerable contribution.

Conversely, projects that do not exceed the project-specific thresholds are generally not considered to be cumulatively significant.

Short-Term Impacts: The maximum construction-related criteria pollutant emissions are shown below in Table 3. Table 3 shows that none of the Proposed Project’s emissions would exceed regional thresholds. Therefore, a less than significant regional air quality impact would occur from construction of the Project.

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Table 3 – Construction-Related Regional Pollutant Emissions Activity
Pollutant Emissions (pounds/day)
ROG NOX CO SO2 PM10 PM2.5
Maximum Daily Emissions1,2 9.81 16.50 17.40 0.03 3.76 2.09 SCAQMD Thresholds 75 100 550 150 150 55
Exceeds Thresholds? No No No No No No
Source: CalEEMod Version 2022.1.1.6
Notes:

1. On-site emissions from equipment operated on-site that is not operated on public roads. On-site demolition and grading PM10 and PM2.5 emissions show compliance with SCAQMD Rule 403.

2. Construction, painting, and paving phases may overlap.

Construction-related air emissions may have the potential to exceed the State and Federal air quality standards in the project vicinity, even though these pollutant emissions may not be significant enough to create a regional impact to the SCAB. The Proposed Project has been analyzed for the potential local air quality impacts created from: construction-related fugitive dust and diesel emissions; from toxic air contaminants; and from construction-related odor impacts. As shown in Table 4, the maximum number of acres disturbed in a day would be 2 acres during grading. The local air quality emissions from construction were analyzed using SCAQMD’s Mass Rate Localized Significant Threshold (LST) Look-up Tables and methodology.

Table 4 – Maximum Number of Acres Disturbed Per Day
Activity Equipment Number Acres/8hr-day Total Acres
Demolition
Rubber Tired Dozers 1 0.5 0.5
Crawler Tractors1 1 0.5 0.5
Subtotal for Phase - - 1
Grading
Graders 1 0.5 0.5
Rubber Tired Dozers 1 0.5 0.5
Crawler Tractors1 2 0.5 1
Subtotal for Phase - - 2
Source: SCAQMD Fact Sheet for Applying CalEEMod to Localized Significance Thresholds, 2011b.

Notes:

1. Tractor/loader/backhoe is a suitable surrogate for a crawler tractor per SCAQMD staff.

Table 5 shows the on-site emissions from the CalEEMod model for the different construction phases and the LST emissions thresholds. As shown in Table 5, none of the analyzed criteria pollutants would exceed the local emissions thresholds at the nearest sensitive receptors. Therefore, the Proposed Project does not result in a cumulatively considerably increase of any criteria pollutant and does not result Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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in any additional increase beyond what is already analyzed in the GP PEIR.

Therefore, the Proposed Project does not result in any new impacts beyond what is analyzed in the GP PEIR. Potential impacts associated with construction emissions would be less than significant, and no mitigation would be required, and the Proposed Project impacts would not be substantially greater than those identified in the GP PEIR.

Table 5 – Local Construction Emissions at the Nearest Receptors Activity
On-Site Pollutant Emissions (pounds/day)
NOX CO PM10 PM2.5
Demolition 13.20 12.20 0.58 0.53
Grading 15.90 15.40 3.50 2.02
Building Construction 9.44 10.10 0.37 0.34
Paving 4.41 6.48 0.18 0.71
Architectural Coating 0.86 1.13 0.02 0.02
SCAQMD Thresholds 115 715 6 4
Exceeds Threshold? No No No No
Source: Calculated from CalEEMod and SCAQMD’s Mass Rate Look-up Tables for 2-acres, to be conservative, at a distance of 25 meters in SRA 17 Central Orange County.

Notes:

1. The nearest sensitive receptors to the Project include the single-family residential uses located adjacent to the east and south and approximately 60-feet (~18 meters) to the west of the Project Site; therefore, the 25-meter threshold was used.

The Project would disturb up to a maximum of 2 acres a day during grading (see Table 5).

Long-Term Impacts: The on-going operation of the Proposed Project would result in a long-term increase in air quality emissions due to project-generated vehicle trips and on-going use of the Proposed Project. The worst-case summer or winter criteria pollutant emissions created from the Project’s long-term operations have been calculated. Operational activities associated with the Proposed Project would result in emissions of ROG, NOx, CO, SO2, PM10, and PM2.5, however, none are above the SCAQMD thresholds as shown in Table 7. The results show that none of the SCAQMD regional thresholds would be exceeded. Therefore, a less than Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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significant regional air quality impact would occur from operation from the Project.

Table 6 - Regional Operational Pollutant Emissions
Activity Pollutant Emissions (lbs/day)1
ROG NOx CO SO2 PM10 PM2.5
Maximum Daily Emissions 1.17 0.51 2.90 0.01 0.22 0.06
SCAQMD Threshold 55 55 550 150 150 55
Exceeds Threshold? No No No No No No
Source: CalEEMod Version 2022.1.1.6; the higher of either summer or winter emissions.

Since the Proposed Project would not introduce any substantial stationary sources of emissions, CO is the benchmark pollutant for assessing local area air quality impacts from post-construction motor vehicle operations. No violations of the state and federal CO standards are projected to occur, based on the magnitude of traffic the Proposed Project is anticipated to generate. The Project would only generate approximately 100 daily vehicle trips. The 1992 Federal Attainment Plan for Carbon Monoxide (1992 CO Plan) showed that an intersection which has a daily traffic volume of approximately 100,000 vehicles per day would not violate the CO standard. Therefore, as the Proposed Project includes only up to 100 vehicle trips per day, the intersection volumes would fall far short of 100,000 vehicles per day, and no CO “hot spot” modeling was performed. No significant long-term impact on local air quality is anticipated with the on-going use of the Project.

Project-related air emissions from on-site sources such as architectural coatings, landscaping equipment, on-site usage of natural gas appliances as well as the operation of vehicles on-site may have the potential to exceed the State and Federal air quality standards in the project vicinity, even though these pollutant emissions may not be significant enough to create a regional impact to the Air Basin. According to SCAQMD LST methodology, LSTs would apply to the operational phase of a project, if the project includes stationary sources, or attracts mobile sources (such as heavy-duty trucks) that may spend long periods queuing and idling at the Project Site; such as industrial warehouse/transfer facilities. The Proposed Project involves the development of the site with a residential use and does not include such uses. Therefore, due to the lack of stationary source emissions, no long-term localized significance threshold analysis is warranted.

The Project Site is located in an area that is out of attainment for ozone, PM10, and PM2.5. The greatest cumulative impact on the quality of regional air cell would be the incremental addition of pollutants mainly from increased traffic Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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volumes from residential, commercial, and industrial development and the use of heavy equipment and trucks associated with the construction of these projects.

Air quality would be temporarily degraded during construction activities that occur separately or simultaneously. However, in accordance with the SCAQMD methodology, projects that do not exceed the SCAQMD criteria or can be mitigated to less than criteria levels are not significant and do not add to the overall cumulative impact. Project operations would generate emissions of NOx, ROG, CO, PM10, and PM2.5, which would not exceed the SCAQMD regional or local thresholds and would not be expected to result in ground level concentrations that exceed the NAAQS or CAAQS.

Therefore, operation of the Proposed Project would not result in a cumulatively considerable net increase for nonattainment of criteria pollutants or ozone precursors. Therefore, potential impacts associated with regional air quality would be less than significant, and no mitigation would be required. No new impacts from what is analyzed in the GP PEIR are found.
c) Expose sensitive receptors to substantial pollutant concentrators? Narrative Summary: Impacts Analyzed in the GP PEIR (c)
Significant and Unavoidable. With implementation of the General Plan, new or modified toxic air contaminants (TACs) could be placed near existing sensitive receptors, and new sensitive receptors could be developed near existing sources of TACs.

Construction-Related Emissions: Construction-related activities would result in short-term emissions of diesel PM from the exhaust of offroad heavy-duty diesel equipment for site preparation (e.g., excavation, grading, and clearing), paving, application of architectural coatings; and other miscellaneous activities.

However, emission standards in the Clean Air Act and SCAQMD rules and regulations mitigate TACs, which would also reduce particulate matter exhaust emissions. The GP PEIR concludes that because “the use of off-road heavy-duty diesel equipment would be temporary and would combine with the highly dispersive properties of diesel PM, further reductions in exhaust emissions would occur, and construction-related activities would be typical to similar development-type projects, and construction-related TAC emissions would not expose sensitive receptors to substantial concentrations of TACs. It is also important to note that compliance with the construction dust mitigation requirements would also reduce particulate matter exhaust emissions. As a result, this impact would be less than significant” (OGP, page 5.3-29).

Operational Emissions: The General Plan anticipates construction of light industrial and commercial land uses, which may potentially include stationary sources of TACs, such as dry-cleaning establishments, gasoline-dispensing facilities, and diesel-fueled backup generators. These types of stationary sources, in addition to Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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any other stationary sources that may emit TACs, would be subject to SCAQMD’s rules and regulations. Given compliance with applicable rules and regulations, operation of stationary sources would not result in the exposure of sensitive receptors to TACs at levels exceeding SCAQMD’s significance thresholds, and this impact would be less than significant. Furthermore, the stationary sources of TAC emissions in the City would be required to be permitted and regulated to prevent new land use compatibility conflicts. Therefore, there would be no incompatibility of proposed land uses with existing sources of TAC emissions. This impact would also be less than significant. However, because of uncertainty with respect to determination and location of tenants, frequency of diesel-fueled trucks visiting the proposed land uses, and distances between trucking activities and sensitive receptors at final buildout of the General Plan and associated mobile emissions of diesel exhaust, this impact would be potentially significant. Implementation of Mitigation Measures 5.3-1 through 5.3-7 would reduce the exposure of sensitive receptors to on road mobile source emissions, but not to a less than significant level. This impact would remain significant and unavoidable.

Impacts Associated with the Proposed Project (c)
No New Impacts. Those who are sensitive to air pollution include children, elderly, and persons with preexisting respiratory or cardiovascular illnesses. For purposes of CEQA, the SCAQMD considers a sensitive receptor to be a location where a sensitive individual could remain for 24 hours, such as residences, hospitals, or convalescent facilities (South Coast Air Quality Management District 2008).

Commercial and industrial facilities are not included in the definition because employees do not typically remain on-site for 24 hours.

As discussed under threshold b, project-related construction and operational air emissions may have the potential to exceed the State and Federal air quality standards in the vicinity of the Project Site, even though these pollutant emissions would not be significant enough to create a regional impact to the SCAB. In order to assess local air quality impacts the SCAQMD has developed Localized Significance Thresholds (LSTs) to assess the Proposed Project-related air emissions.

LSTs represent the maximum emissions from a project that are not expected to cause or contribute to an exceedance of the most stringent applicable federal or state ambient air quality standard. LSTs are developed based on the ambient concentrations of four applicable air pollutants for source receptor area (SRA-17) – Central Orange County.

The nearest sensitive receptors to the Project Site are the single-family residential uses located adjacent to the east and south and approximately 60 feet (~18 meters) to the west (across Rancho Santiago Boulevard) of the Project Site. In addition, Enderby Field/Santiago Charter Middle School is located approximately 215 feet south of the Project Site. Other air quality sensitive land uses are located further from the Project Site and would experience lower impacts. The nearest Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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existing sensitive receptors are located along the western and southern boundaries of the Project Site, less than 25 meters (82 feet) from potential areas of on-site construction and operational activity. Although receptors are located closer than 25 meters (82 feet) to the Project Site, SCAQMD LST methodology states that projects with boundaries located closer than 25 meters (82 feet) to the nearest receptor should use the LSTs for receptors located at 25 meters (82 feet).

As shown in Table 5 above, none of the analyzed criteria pollutants would exceed the local emissions thresholds at the nearest sensitive receptors.

Construction
The greatest potential for toxic air contaminant emissions would be related to diesel particulate emissions associated with heavy equipment operations during construction of the Project. According to the Office of Environmental Health Hazard Assessment (OEHHA) and the SCAQMD Health Risk Assessment Guidance for Analyzing Cancer Risks from Mobile Source Diesel idling Emissions for CEQA Air Quality Analysis (August 2003), health effects from TACs are described in terms of individual cancer risk based on a lifetime (i.e., 30-year) resident exposure duration.

Given the temporary and short-term construction schedule (approximately 24 months), the project would not result in a long-term exposure as a result of Project construction. Furthermore, construction-based particulate matter (PM) emissions including diesel exhaust emissions do not exceed any local or regional thresholds.

The Proposed Project would comply with the CARB Air Toxics Control Measure that limits diesel powered equipment and vehicle idling to no more than five minutes at a location, and the CARB In-Use Off-Road Diesel Vehicle Regulation; compliance with these requirements would minimize emissions of TACs during construction. The Proposed Project would also comply with the requirements of SCAQMD Rule 1403 if asbestos is found during the renovation and construction activities. Therefore, impacts from TACs during construction would be less than significant.

Operations
Operational emissions are calculated within CalEEMod. The program is largely based on default settings which are automatically populated throughout the model based on the imputed land use. Southern California Edison averages for utility emissions were utilized for the calculations throughout the model. CalEEMod utilized the proposed land use and then estimates worst-case air quality emissions from trip generations built into the model and includes vehicle emission rates from Emission Factors 2021. The data provided in Table 6 above shows that the on- going operations of the Proposed Project would not exceed SCAQMD local operational thresholds of significance.

Potential impacts associated with exposing sensitive receptors to substantial pollutant concentrations during construction or from operation of the Proposed Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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Project would be less than significant, and no mitigation would be required.

Therefore, the on-going operations of the Proposed Project would create a less than significant operations-related impact to local air quality due to on-site emissions and no mitigation would be required. No new significant or substantially greater impacts from what is analyzed in the GP PEIR are found. d) Result in other emissions (such as those leading to odors adversely affecting a substantial number of people)?
Narrative Summary: Impacts Analyzed in the GP PEIR (d)
Less Than Significant Impact. According to the GP PEIR, the General Plan does not have the potential to create objectionable odors. Therefore, this issue is not discussed further in the GP PEIR (OGP, page 5.3-17). Additionally, minor sources of odors associated with the General Plan would be associated with the construction of proposed land uses. Odors associated with diesel fumes and other minor sources would be temporary and would disperse rapidly with distance from the source; therefore, construction-generated and mobile-source odors would not result in the frequent exposure of receptors to objectionable odor emissions.

As a result, short-term construction-related and long-term mobile-source related odors would be less than significant. A less than significant impact associated with short-term and long-term odor impacts would occur. No mitigation would be required.

Impacts Associated with the Proposed Project (d)
No New Impacts. The occurrence and severity of potential odor impacts depend on numerous factors. The nature, frequency, and intensity of the source; the wind speeds and direction; and the sensitivity of receiving location each contribute to the intensity of the impact. Although offensive odors seldom cause physical harm, they can be annoying and cause distress among the public and generate citizen complaints.

Potential sources that may emit odors during construction activities include the application of materials such as asphalt pavement. The objectionable odors that may be produced during the construction process are short-term in nature and the odor emissions are expected to cease upon the drying or hardening of the odor producing materials. Due to the short-term nature and limited amounts of odor producing materials being utilized, no significant impact related to odors would occur during construction of the Proposed Project. Diesel exhaust and VOCs would be emitted during construction of the project, which are objectionable to some; however, emissions would disperse rapidly from the Project Site and therefore should not reach an objectionable level at the nearest sensitive receptors.

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odor impacts that may result from construction activities. Moreover, construction- source odor emissions would be temporary, short-term, and intermittent in nature and would not result in persistent impacts that would affect substantial numbers of people. Potential construction-source odor impacts are therefore considered less than significant.

The Proposed Project does not propose any uses or activities that would result in potentially significant operational-source odor impacts. Potential sources that may emit odors during the on-going operations of the Proposed Project would include odor emissions from the intermittent diesel delivery truck emissions and trash storage areas. Due to compliance with SCAQMD’s Rule 402, no significant impact related to odors would occur during the on-going operations of the Proposed Project. Potential operational-source odor impacts are therefore considered less than significant. No new impacts from what is analyzed in the GP PEIR are found.

Conclusion
The air quality impacts of the Proposed Project would be less than significant, and no Project-specific mitigation is required. The Project would not result in any new significant impacts or in a substantial increase in the severity of impacts evaluated in the GP PEIR that would render Section 15183 inapplicable to the Proposed Project. With regards to the issue area of Air Quality, the following findings can be made:

1. No peculiar impacts to the Project or its site have been identified.

2. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

3. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

4. No new Mitigation Measures would be required because Project- specific impacts would be less than significant. GP PEIR Mitigation Measures have been implemented.

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4.4 Biological Resources
Impact Analysis

CEQA THRESHOLDS
Project
Peculiar
Impact that
is not
Substantiall
y Mitigated
by Uniform
Applied
Policies
Significa
nt
Impact
not
Analyze
d as
Significa
nt in the

Would the project:
a) Have a substantial adverse effect,
either directly or through habitat
modifications, on any species identified
as a candidate, sensitive, or special
status species in local or regional plans,
policies, or regulations, or by the
California Department of Fish and
Wildlife or U.S. Fish and Wildlife Service?
X
b) Have a substantial adverse effect on
any riparian habitat or other sensitive
natural community identified in local or
regional plans, policies, regulations or
by the California Department of Fish
and Wildlife or U.S. Fish and Wildlife
Service?
X
c) Have a substantial adverse effect on
state or federally protected wetlands
(including, but not limited to, marsh,
vernal pool, coastal, etc.) through
direct removal, filling, hydrological
interruption, or other means
X
d) Interfere substantially with the
movement of any native resident or
migratory fish or wildlife species or with
established native resident or migratory
wildlife corridors, or impede the use of
native wildlife nursery sites?
X
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e) Conflict with any local policies or
ordinances protecting biological
resources, such as a tree preservation
policy or ordinance?
X
f) Conflict with the provisions of an
adopted Habitat Conservation Plan,
Natural Community Conservation Plan,
or other approved local, regional, or
state habitat conservation plan?
X
General Plan PEIR Mitigation Measures
General Plan PEIR Mitigation Measure Applicable/Not Applicable

5.4-1 Analyze development proposals for potential
impacts to significant ecological and biological
resources. Require appropriate mitigation for all
significant impacts if impact avoidance is not possible.

Mitigation measures for habitat and species may
include, but are not limited to, avoidance,
enhancement, restoration, or a combination of any of
the three. (Implementation Program III-13)
Mitigation Measure is not
applicable.

5.4-2 Continue to coordinate with state and federal
wildlife agencies in an effort to protect rare or
endangered species of plants and animals. Require that
all development activities adhere to state and federal
legislation that protects all sensitive plants and animals.

Coordinate with these agencies for City efforts to restore portions of Santiago Creek, to develop bike trails and
pathways adjacent to Santiago Creek, to recognize the
archaeological significance of Santiago Creek, and to
integrate natural landscape components within the
design of projects adjacent to waterways.
(Implementation Program V-11)
Mitigation Measure is not
applicable.

5.4-3 Prior to making land use decisions, the City will utilize available methods to estimate increases in
pollutant loads and flows resulting from projected future development.

The City will follow the most current National Pollutant Discharge Elimination System (NPDES) Permit and
County of Orange Drainage Area Master Plan and the
City Drainage Area Management Plan to ensure that
the City complies with applicable state and federal
regulations. Applicants for new development and
redevelopment projects shall prepare and submit plans
Mitigation Measure is
applicable. The Proposed
Project would follow all
applicable provisions listed
in the NPDES. A Preliminary
Hydrology Analysis and a
Preliminary Water Quality
Management Plan
(PWQMP) were prepared
for the Proposed Project.

The PWQMP and Hydrology
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General Plan PEIR Mitigation Measure Applicable/Not Applicable to the City, as well as implement plans demonstrating
accomplishment of the following:
 Use structural and nonstructural best
management practices (BMPs) to mitigate
projected increases in pollutant loads and flows;
 Control the velocity of pollutant loading flows
during and after construction;
 Limit areas of impervious surfaces and preserve
natural areas;
 Limit directly connected areas of impervious
surfaces;
 Use natural treatment systems such as wetlands
and bioswales to treat storm runoff where
technically and economically feasible;
 Provide on-site infiltration and runoff and
temporary on-site retention areas;
 Limit disturbance of natural water bodies, natural
drainage systems, and highly erodible areas; and
 Use pollution prevention methods, source
controls, and treatment using small collection
strategies located at, or as close as possible to,
the source.

In addition, applicants for large development projects
are required to prepare and implement plans that meet
site predevelopment hydrologic conditions and to
control runoff on-site where technically feasible.
(Implementation Program III-8)
Study list BMPs and
treatment systems for the
Project Site.

5.4-4 Comply with all provisions of the NPDES permit, and support regional efforts by the Santa Ana Regional
Water Quality Control Board (RWQCB) to improve and
protect surface water quality. (Implementation Program
V-9)
Mitigation Measure is
applicable. The Proposed
Project would comply with
all provisions of the NPDES
permit.

5.4-5 Support compliance with the Central Orange
County NCCP/HCP. Participate in any future update to
the NCCP/HCP. Coordinate with the Fire Department
and related agencies to ensure consideration of NCCP
habitat areas when planning fuel modification zones.
(Implementation Program V-13)
Mitigation Measure is not
applicable.

5.4-6 Continue to work with local and regional open
space preservation organizations and state and federal
agencies to identify and conserve urban open space
and protect lands accessible for public use. Pursue
grants and other resources to plan for open space
preservation and, as appropriate, purchase properties
Mitigation Measure is not
applicable.

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General Plan PEIR Mitigation Measure Applicable/Not Applicable to be included in the open space system. Use
conservation easements where feasible as part of the
City’s open space acquisition program.
(Implementation Program V-14)
Discussion
a) Would the project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?
Narrative Summary: Impacts Analyzed in the GP PEIR (a)
Less Than Significant with Mitigation. The GP PEIR evaluated the potential for implementation of the OGP to impact biological resources in the City. According to the GP PEIR, the majority of development allowed by the OGP would occur through infill, redevelopment, and intensification in the OGP land use focus areas.

Development in these areas is not expected to affect sensitive species as these areas are already urbanized. The GP PEIR discusses that grading, excavation, and construction activities associated with the buildout of the OGP in the eastern portion of the City’s planning area may potentially impact sensitive species and their habitats. Development within these areas may reduce existing habitat for some special status plant and wildlife species due to increases in lighting, noise, pets, and fragmentation of wildlife habitat. These factors may also disrupt wildlife movement along established corridors.

Three species (coastal California gnatcatcher, coastal cactus wren, and orange- throated whiptail lizard) were designated as “target species” by the NCCP/HCP to be used as umbrella species to guide the design of a permanent habitat system within the Central and Coastal Subregion. Areas designated as NCCP Habitat Reserve as needed by the three species are designated by the OGP as Open Space or Recreational Commercial consistent with the NCCP. According to the GP PEIR, development in these sensitive areas is not expected under the implementation of the OGP. The GP PEIR discusses the City’s and Irvine Company’s participation in the Orange County Central/Coastal NCCP process as a signatory to the implementation agreement provides the means to mitigate the direct and indirect impacts to the 39 species and four covered habitats identified within designated development sites in the NCCP/HCP area and allows development to proceed in areas not designated as “Reserve” and “Non- Reserve Open Space.” The specific impact to sensitive species from future development in the City’s planning area cannot be determined at the Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
TTM 0052-23, Zone Change, CUP 3203-23, Major Site Plan Review 1137-23, Design Review 5119-23

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programmatic level of analysis because no precise development projects that would follow the General Plan update were known at the time of the GP PEIR and OGP. Therefore, impacts at this program level of analysis are determined to be potentially significant.

With adherence to and implementation of the proposed policies and regulations, and implementation of Mitigation Measures 5.4-1 and 5.4-2, program-level impacts to sensitive species would be less than significant. Individual development projects would be required to undergo project-specific environmental review. If project-level significant impacts are identified, specific Mitigation Measures would be required.

Impacts Associated with the Proposed Project (a):

No New Impacts. A General Biological Technical Report was prepared for the Proposed Project by Noreas (Appendix B – Rancho Ridge Infill Project General Biological Technical Report by Noreas, January 2023). The Biological Report examines the Project Site and the results of baseline biological resources surveys and habitat assessments for the Proposed Project. The Proposed Project proposes development within areas either already developed or in a non-native plant community that does not support special-status species. The Biological Report’s pedestrian survey determined that greater than 99% of the Project Site was comprised of developed, disturbed, and/or non-native land cover types. The Project is not collocated with any United States Fish and Wildlife Service (USFWS) designated critical habitat, nor were any special status species detected. No nesting birds, remnant raptor nests, or bat guano were detected within the Project Site either. The Project Site’s developed and disturbed land cover has substantially decreased its value as suitable breeding, nesting, and foraging habitat for native species.

Additionally, the Project Site was assessed for its potential to support special-status species. No Federal or State listed plant species and special-status species were observed within the Biological Report’s study area. The study area does not include any USFWS-designated critical habitat for plants or wildlife. The Biological Report concluded that the Project Site does not include substantive habitat requirements necessary to support special-status flora or special-status wildlife.

Therefore, the Proposed Project would not have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or United States Fish and Wildlife Service.

The Proposed Project may require the removal of vegetation, shrubs, or trees that could provide potential nesting habitat for common urban birds, and migratory BCC birds protected by the Migratory Bird Treaty Act (MBTA), Migratory Bird Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
TTM 0052-23, Zone Change, CUP 3203-23, Major Site Plan Review 1137-23, Design Review 5119-23

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Protection Act (MBPA), and the Fish and Wildlife Code. While the Project Site’s developed and disturbed land cover have substantially decreased its value as suitable breeding, nesting, and foraging habitat for native species and plants, the following mitigation measure is recommended for implementation to further reduce any direct and indirect impacts on wildlife species. If present at the time of vegetation removal there could be direct impacts on active nests, eggs, or young. To avoid direct and indirect impacts to active bird nests, eggs, or young, preconstruction nesting bird surveys and monitoring is required as described in Regulatory Compliance Mitigation Measure BIO-1. With the implementation of the mitigation measure, there would be no presumption that the Proposed Project would result in the loss of individual species, nor that it would adversely affect local or regional populations of them.

Regulatory Compliance Mitigation Measure BIO-1: Preconstruction Nesting Bird Survey

 Training of all field staff on applicable - or relevant, and appropriate local, state, and federal regulatory agency requirements, environmental laws, and regulations associated with working around biological resources.  No personnel working within Project limits will “take” or destroy plants, animals, or active nests (or eggs) of birds that are protected under the Federal or State Endangered Species Acts and Migratory Bird Treaty Act (MBTA).
 No personnel working within Project limits will handle - or relocate, flora or fauna.
 If possible, ground disturbing activities and vegetation removal (including tree trimming) should be timed to occur outside the typical avian nesting season (March 15th through September 1st).
 If ground disturbing activities or vegetation removal (including tree trimming) are scheduled during the bird nesting season (March 15th through September 1st), a pre-activity clearance survey for nesting birds should be conducted prior to the onset of ground disturbance. The survey should be conducted by a qualified biologist with prior experience conducting nesting bird surveys for construction projects. The study area should include the Project Site and suitable habitat within a 300-foot buffer, or a buffer size determined by the qualified biologist based on level of proposed disturbance and access. If no occupied nests are found, no additional measures are required.
 If active nests are found the biologist will map the location and document the species and nesting stage. An activity exclusion buffer will be established around occupied nests as determined by the qualified biologist and based on the species sensitivity to disturbance and the type and duration of the disturbance. The buffer zone should be maintained during Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
TTM 0052-23, Zone Change, CUP 3203-23, Major Site Plan Review 1137-23, Design Review 5119-23

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physical ground disturbing undertakings. Once the nesting has ended, the buffer may be removed.
b) Would the project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?
c) Would the project have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
Narrative Summary: Impacts Analyzed in the GP PEIR (b-c) Less Than Significant with Mitigation. The GP PEIR states that protection of riparian habitat and wetlands would occur during standard procedures for environmental review of land development projects and City infrastructure improvements in areas where riparian habitat and wetlands could be impacted. Much of the land directly adjacent to riparian areas in the City is designated as Open Space or Open Space Park in the OGP.

The specific impact to riparian habitat and wetlands from future development in the planning area cannot be determined at this General Plan level of analysis because no precise land development projects that rely on land use changes proposed as part of the General Plan update are known at this time. Therefore, impacts at this program level of analysis are determined to be potentially significant. With adherence to and implementation of the proposed policies and regulations, and implementation of Mitigation Measures 5.4-3 and 5.4-4, program- level impacts to riparian habitat and wetlands would be less than significant.

Individual development projects would be required to undergo project-specific environmental review. If project-level significant impacts are identified, specific Mitigation Measures would be required.

Impacts Associated with the Proposed Project (b-c):

No New Impacts. As discussed under threshold a, the Biological Report prepared for the Proposed Project did not detect any riparian or riverine habitats or any obvious indicators of a well-defined water conveyance bed, bank, or channel within the Project Site. According to the Biological Report, the topographic suggests that the Project Site lacks waters which are typically subject to the Clean Water Act, or Fish and Game Code Section 1600 jurisdiction. Furthermore, the National Wetland Inventory has no records of special aquatic resources within the Project Site. The Biological Report characterizes the Project Site as disturbed upland. Therefore, the Proposed Project would not have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Game or USFWS.

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d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? Narrative Summary: Impacts Analyzed in the GP PEIR (d):

Less Than Significant with Mitigation. The OGP is designed to be consistent with the NCCP/HCP, which provides a permanent habitat system within the Central and Coastal subregion by designating areas as NCCP Habitat Reserve. The Habitat Reserve was designed to provide long-term protection for habitat required by native and migratory coastal sage scrub-dependent species (GP PEIR, page 5.4-23). The OGP has designated portions of the City’s planning area as Non-Reserve Open Space and Open Space. The specific impact to native and migratory species from future development in the City’s planning area cannot be determined at the programmatic level of analysis because no precise land development projects that rely on land use changes proposed as part of the OGP are known at the time of the GP PEIR and OGP. Therefore, impacts at this program level of analysis are determined to be potentially significant. With adherence to and implementation of the proposed policies and regulations, and implementation of Mitigation Measures 5.4-1 and 5.4-2, program-level impacts to areas of species, corridors, or nursery sites will be less than significant. Individual development projects would be required to undergo project-specific environmental review. If project-level significant impacts are identified, specific Mitigation Measures would be required.

Impacts Associated with the Proposed Project (d):

No New Impacts. According to the Biological Report, the Project Site’s developed and disturbed land cover has substantially decreased its value as suitable breeding, nesting, and foraging habitat for native species. The Project Site was determined to be comprised of developed, disturbed, or non-native habitats.

Furthermore, the Project Site has limited (if any) value as a low-quality migration corridor, or overland dispersal habitat for wildlife, because it is severely movement constrained by the surrounding residential, industrial, and commercial developments, and public infrastructure. The Project Site does not feature any special status-species, wetlands, or habitats. Therefore, the Project does not interfere substantially with the movement of any native resident or migratory fish or wildlife species or with the established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites.

Therefore, no new impacts associated with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or associated with impeding the use of native wildlife nursery sites would occur beyond what is already analyzed in the GP PEIR.

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e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? Narrative Summary: Impacts Analyzed in the GP PEIR (e):

Less Than Significant. The City’s participation in the NCCP program, its Master Street Tree Plan, and the Tree Preservation Ordinance are the primary local measures to protect biological resources. The Master Street Tree Plan and the Tree Preservation Ordinance monitor the potential for impacts to existing trees that provide roosting and nesting habitat for native and migratory birds throughout the City. The OGP does not alter these existing documents as a result of any land use changes proposed by the OGP. Increased densities proposed to be allowed in the existing urbanized areas provide opportunity for redevelopment of existing properties currently developed with lower intensity residential or commercial uses.

Redevelopment activities may potentially put existing trees at risk of removal.

However, the Master Street Tree Plan and the Tree Preservation Ordinance, together with the City’s existing development review and CEQA compliance procedures, provide an effective means to monitor potential impacts to native and migratory birds and to avoid significant impacts during redevelopment.

Therefore, the GP PEIR concludes that potential conflicts with local measures protecting biological resources would be less than significant.

Impacts Associated with the Proposed Project (e):

No New Impacts. The Proposed Project would adhere to all applicable regulations set forth in the City’s Master Street Tree Plan and Tree Preservation Ordinance.

According to the GP PEIR, the City’s Master Street Plan and Tree Preservation Ordinance, as well as the City’s participation in the NCCP program, are the primary measures to protect biological resources. The Project would adhere to these local policies and does not propose any development in any NCCP designated areas. Therefore, the Proposed Project does not conflict with any local policies or ordinances protecting biological resources, and no new impacts associated with conflict of local policies or ordinances protecting biological resources would occur.
f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation plan?
Narrative Summary: Impacts Analyzed in the GP PEIR (f):

Less than Significant with Mitigation. The City is subject to the Orange County Central/Coastal NCCP Subregional Plan, which satisfies the federal, state, and local project-specific mitigation requirements for the species and habitats addressed in the NCCP/HCP. The coastal California gnatcatcher, coastal cactus wren, and orange-throated whiptail lizard, all of which are currently on the federal list of threatened or endangered species, were designated as “target species” Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
TTM 0052-23, Zone Change, CUP 3203-23, Major Site Plan Review 1137-23, Design Review 5119-23

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by the NCCP/HCP and sufficient coastal sage scrub and other essential habitat are protected to benefit a much broader range of coastal sage scrub-related species. Areas within the City’s planning area that are designated as NCCP Habitat Reserve are also designated as Open Space or Recreational Commercial by the OGP to be consistent with the NCCP.

The OGP is consistent with the NCCP/HCP and includes implementation programs to continue efforts to identify and conserve lands suitable for inclusion in the open space Reserve system and for collection of “in-lieu” fees to the Nature Reserve of Orange County (NROC) for the native areas that would be removed due to development. This continued participation in the NCCP/HCP implementation programs would reduce any significant impact on local habitat conservation planning efforts. However, as development in and adjacent to existing natural areas located in the urbanized portion of the City continues, direct and indirect impacts to natural areas interface planning could occur and would be potentially significant. With adherence to and implementation of the proposed policies and regulations, and implementation of Mitigation Measures 5.4-5 and 5.4-6, program- level impacts to habitat conservation planning would be less than significant.

Impacts Associated with the Proposed Project (f):

No New Impacts. The Proposed Project is not located in any NCCP designated areas nor is the Project Site located on any areas designated as Open Space or Recreational Commercial by the OGP. The Project Site is located on a site that is designated as Low Density Residential and zoned as R-1-10. The surrounding uses are developed with residential, commercial, and church uses. The Proposed Project does not feature any special status species, habitats, or wetlands and would adhere to the City’s applicable regulations and standards for development. Therefore, the Proposed Project does not conflict with the adopted NCCP/HCP, and no impacts would occur.

Conclusion
The Proposed Project would not result in any new or substantially greater impacts beyond those identified in the previously certified GP PEIR. Additionally, no new information of substantial importance that was not known and could not have been known at the time the GP PEIR was certified is available that would change the prior finding of less than significant impact with mitigation incorporated. With regards to the issue area of Biological Resources, the following findings can be made:

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1. No peculiar impacts to the Proposed Project or its site have been identified.

2. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

3. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

4. Feasible Mitigation Measures contained within the GP PEIR apply to the Proposed Project. With mitigation, Project-specific impacts are less than significant.

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4.5 Cultural Resources
Impact Analysis

Would the project:
a) Cause a substantial adverse
change in the significance of a
historical resource as defined in
15064.5?
X
b) Cause a substantial adverse
change in the significance of an
archaeological resource pursuant
to 15064.5?
X
c) Disturb any human remains,
including those interred outside of
formal cemeteries?
X
General Plan PEIR Mitigation Measures
General Plan PEIR Mitigation Measure Applicable/Not Applicable

5.5-1 Comply with all provisions of CEQA. In addition to thresholds that may be established or adopted by the City in the future, use the following thresholds and/or
procedures for CEQA analysis of proposed projects,
consistent with policies adopted within the General Plan:
 Historic and Cultural Resources
o “Historical resource” for the purposes of
CEQA shall mean “historic district” in the
case of a contributor to a historic district.
o Historic resources listed in the City’s Historic
Register shall have a presumption of
Mitigation Measure is
applicable. The Proposed
Project’s CEQA analysis
adheres to the provisions of
CEQA.

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General Plan PEIR Mitigation Measure Applicable/Not Applicable significance pursuant to CEQA Statute
§21084.1 and shall be treated as historical
resources under CEQA.
o The historical significance of an
archaeological historic resource is evaluated
using the criteria of Public Resource Code
§5024.1 and CEQA Guidelines, §15064.5 et
seq.
(Implementation Program III-1)

5.5-2 Apply to the OHP for inclusion in the Certified Local Government (CLG) program. Successful application
includes several requirements:
 Enact appropriate historic preservation regulations
through an adopted historic preservation
ordinance.
 Establish an adequate and qualified historic
preservation review commission.
 Maintain a system for the survey and inventory of
historic properties.
 Provide for adequate public participation in the
historic preservation program.
 Satisfactorily perform the responsibilities delegated to the CLG.
(Implementation Program I-16)
Mitigation Measure is not
applicable.

5.5-3 Create the Historic Register, which will serve as the local register of historical resources under CEQA.

Automatically include all resources previously designated, listed, or determined eligible for listing within the NRHP or California Register.
 Establish a process for handling voluntary requests
for listing in the Historic Register. Support
coordination with property owners of potential
historic resources identified in the Orange Inventory,
so that such potential historic resources can more
readily be listed in the Historic Register.
 Establish a process for listing in the Historic Register those buildings, structures, objects, sites, or districts that meet the criteria.
 Establish procedures to remove historic resources
from the Historic Register.

Mitigation Measure is not
applicable.

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General Plan PEIR Mitigation Measure Applicable/Not Applicable  Establish procedures for listing archaeological
resources in the Historic Register. Employ
appropriate criteria for evaluating potential
significance of such archaeological resources as
historical resources or unique archaeological
resources under CEQA. Encourage voluntary listing
of eligible archaeological resources.
(Implementation Program I-17)

5.5-4 Pursue historic landmark district designation for three Eichler Homes tracts. Notify property owners in three Eichler tracts including Fairhaven, Fairhills, and Fairmeadow of the intent to list each of the three tracts separately as local historic districts and follow established procedures for Historic Register listing of each. (Implementation Program I-18)
Mitigation Measure is not
applicable.

5.5-5 Continue to maintain an accessible and periodically updated inventory of potential resources. All surveyed
properties will be included in the Orange Inventory, and the Orange Inventory will be a valuable planning tool to be used in evaluating possible impacts a proposed project might have on previously evaluated potential and
identified historic resources. Surveys and survey updates may be conducted by qualified preservation professionals in accordance with Secretary of Interior Standards criteria.

Properties that have attained 45 years of age and are
located within a designated historic district or NCA shall be subject to survey prior to issuance of any permit for
alteration or demolition.

Survey other areas where potential for historic resources may exist. Identify smaller character areas where
concentrations of potential or listed historic resources reflect unique senses of time and place.

Use the Orange Inventory to identify potential historic resources for purposes of CEQA, NHPA, and NEPA review
of proposed projects. Only if potential historic resources in the Orange Inventory are listed in or eligible for listing in the California Register for CEQA or the NRHP for the NHPA and NEPA shall they have a presumption of significance
pursuant to CEQA Statute §21084.1 and be treated as
historical resources under CEQA.

Mitigation Measure is not
applicable.

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General Plan PEIR Mitigation Measure Applicable/Not Applicable Potential historic resources identified in the Orange
Inventory may be listed in the Historic Register if they meet criteria for listing in the California Register. (Implementation Program I-19)

5.5-6 Actively pursue grants, loans, and other incentives to encourage historic preservation. Consider implementing
conservation easements.

Develop a revolving loan program for maintenance and
rehabilitation work, consistent with design standards, on listed historic resources and on resources that are
contributors to listed historic districts.

Develop a voluntary conservation easement program to
preserve listed historic resources and contributors to listed historic districts. Provide a potential tax benefit to property owners. Establish a partnership with local preservation organizations to accept, hold, and manage conservation
easements on historic resources. (Implementation Program I-20)
Mitigation Measure is not
applicable.

5.5-7 Explore establishing a commemorative plaque
program to allow public recognition of properties listed in the Historic Register. Develop and administer standards and guidelines for properties eligible for the
commemorative plaque program. (Implementation
Program I-21)
Mitigation Measure is not
applicable.

5.5-8 Officially recognize the Historic Context Statement prepared in tandem with the General Plan Update.

Periodically update the Statement to add recent historical events. Officially recognize the recent completed
historical and archaeological resources survey prepared in tandem with the updated General Plan. Update and
maintain the inventory using the City’s Geographic
Information System (GIS). (Implementation Program I-22) Mitigation Measure is not
applicable.

5.5-9 Designate El Modena, Cypress Street Barrio, the
Railroad/Packinghouse Corridor, and Orange Park Acres
as NCAs by establishing an NCA overlay zone and
appropriate standards and regulations in the Zoning
Code. (Implementation Program I-23)
Mitigation Measure is not
applicable.

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General Plan PEIR Mitigation Measure Applicable/Not Applicable

5.5-10 Require cultural resources inventories of all new development projects in areas identified with medium or high potential for archaeological or cultural resources.

Where a preliminary site survey finds medium to high
potential for substantial archaeological remains, the City shall require a mitigation plan to protect the resource before issuance of permits. Mitigation may include:
 Ensuring that a qualified archaeologist is present
during initial grading or trenching (monitoring);
 Redesigning the project to avoid archaeological
resources (this is considered the strongest tool for
preserving archaeological resources);
 Capping the site with a layer of fill; and/or
 Excavating and removing the archaeological
resources (recovery) and implementing curation in
an appropriate facility under the direction of a
qualified archaeologist (interpretation).

Alert applicants for permits within early settlement areas to the potential sensitivity. If significant archaeological resources are discovered during construction or grading activities, such activities shall cease in the immediate area of the find until a qualified archaeologist can determine the significance of the resource and recommend
alternative mitigation.

If an archaeological inventory survey is required, the final stage is the preparation of a professional report detailing the findings and recommendations of the records search
and field survey. The final report containing site forms, site significance, and Mitigation Measures should be submitted immediately to the Orange Community Development
Department. All information regarding site locations,
Native American human remains, and associated funerary
objects should be in a separate confidential addendum,
and not be made available for public disclosure. The final written report should be submitted to the appropriate
regional archaeological Information Center within three months after work has been completed. The City shall
ensure that project applicants contact the Native
American Heritage Commission for a Sacred Lands File
Check and a list of appropriate Native American contacts for consultation concerning the Project Site and to assist in Mitigation Measure is
applicable. As discussed
below, the Proposed
Project would adhere to all
federal, state, and local
regulations as well as GP
PEIR Mitigation Measures

5.1-1 through 5.5-14 to
protect archaeological
resources. The Proposed
Project includes best
management practices in
the event that
archaeological resources
are unearthed during
construction.

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General Plan PEIR Mitigation Measure Applicable/Not Applicable crafting the Mitigation Measures. (Implementation
Program III-10)

5.5-11 Establish the Archaeological Resources
Management Report (ARMR Preservation Bulletin) as the
standard report format for all documentation and accept reports only from registered professional archaeologists knowledgeable in Native American cultures and/or
historical archaeology (qualified archaeologists).
(Implementation Program III-14)
Mitigation Measure is not
applicable.

5.5-12 Continue to use the Secretary’s Standards as a basis for design review. Update the City’s Demolition Ordinance to include that any approved demolition permit for listed historic resources shall be automatically subject to a delay before the permit for demolition may be issued. The
property owner will strive to develop alternatives to
demolition that will preserve the historic resources.

The Community Development Director shall appoint a City of Orange Preservation Officer (Preservation Officer). In lieu of such appointment, the Director shall serve as
Preservation Officer. (Implementation Program III-15)
Mitigation Measure is not
applicable.

5.5-13 The City will continue to support efforts by
California’s OHP to administer federal and state-
mandated historic preservation programs in California,
including the following:
 California Historical Landmarks;
 California Points of Historical Interest;
 California Register of Historical Resources;
 National Register of Historic Places;
 Secretary of Interior Standards; and
 CEQA.

The Mills Act is another preservation tool created by the California legislature, enabling cities to enter into historical property agreements with owners of qualifying properties that result in reductions to the owners’ property taxes. The agreements provide a benefit that ensures preservation
and guarantees authentic rehabilitations and a high level of maintenance of historic resources. The City will continue to encourage use of the Mills Act provisions by private property owners. (Implementation Program V-16)
Mitigation Measure is not
applicable.

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General Plan PEIR Mitigation Measure Applicable/Not Applicable

5.5-14 Develop partnerships with local history and
preservation organizations to prepare Historic Context
Statement updates, undertake new surveys, and update
surveys. Partner with local history and preservation
organizations to develop a citywide interpretive program, including signs, plaques, exhibits, and other similar
elements, to increase awareness of the City’s history and its historic resources. (Implementation Program V-17)
Mitigation Measure is not
applicable.

Discussion
a) Cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5?
Narrative Summary: Impacts Analyzed in the GP PEIR (a)
Less Than Significant Impact with Mitigation. The OGP’s Cultural Resources and Historic Preservation Element identifies several resources intended for designation within the City, including historic districts, Neighborhood Character Areas (NCAs), and individual resources. Under implementation of the OGP, the growth projected to occur within the City’s planning area would occur primarily through infill development and adaptive reuse, primarily in the OGP land use focus areas.

Land use policies in the OGP provide opportunities for adaptive reuse of historic buildings as a way to preserve the integrity of historic resources while accommodating growth. Historic resources could be vulnerable to unchecked development activities and infrastructure or other public works improvements and could result in damage to or demolition of historic resources. This is a potentially significant impact.

However, the GP PEIR states that there are a number of federal, state, and local regulations in place to protect historic resources in the City. The proposed policies listed in the OGP include a variety of regulations and incentives aimed at preserving both publicly and privately owned historic and cultural resources. An example of a policy is to maintain an accessible inventory of designated and potential historic resources. According to the GP PEIR, implementation of the existing regulations and the OGP policies would adequately control and regulate activities with the potential to impact historic resources. With adherence to and implementation of the OGP policies and regulations as well as implementation of Mitigation Measures 5.5-1 through 5.5-9, and 5.5-12 through 5.5-14, program-level impacts to historic resources would be less than significant. Individual development projects would be required to undergo project-specific environmental review. If project-level significant impacts are identified, specific Mitigation Measures would be required (GP PEIR, page 5.5-23).

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Impacts Associated with the Proposed Project (a)
No New Impacts. According to the GP PEIR Figure 5.5-3, the Project Site is not located in any area that is considered a resource recommended for designation.

The Proposed Project is not located in any historic district or NCA and is not considered an individual resource (GP PEIR, page 5.5-18). Additionally, the City has a Historic Preservation Viewer map online that shows if a site is located within any historic district or are considered to be a historic resource or eligible to be one. According to the viewer, the Project Site is not located within any historic districts nor is it considered a historic resource site. The nearest historic resource is the Jones Estate located approximately 0.38-mile southeast of the Project Site.

The Project Site is also not mapped as a historic place according to the National Park Service (NPS) National Register of Historic Places map viewer. The Proposed Project does not cause a substantial adverse change in the significance of a historic resource pursuant to PRC §15064.5. Therefore, there are no impacts associated with historic resources, and no mitigation is required. b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5?
c) Disturb any human remains, including those interred outside of formal cemeteries?
Narrative Summary: Impacts Analyzed in General Plan PEIR (b-c) Less Than Significant Impact with Mitigation. The GP PEIR indicated a potential for archaeological resources, including human remains, to exist in or near the City.

Development pursuant to the OGP has the potential to impact known or unknown archaeological and paleontological resources. Specifically, the development of residential or urban land uses, roads, and infrastructure (e.g. storm water, wastewater, or domestic/recycled water lines) may impact buried archaeological and paleontological resources, including human remains, located throughout undeveloped portions of the City. The GP PEIR includes a figure that lists areas within the City that are of historical archaeological sensitivity overlap. Therefore, implementation of the OGP could result in potentially significant impacts to archaeological resources. However, the GP PEIR states that there are a number of federal, state, and local regulations in place to protect cultural resources in the City. Implementation of these existing regulations largely controls activities with the potential to impact cultural resources, including archaeological resources. The GP PEIR states that the OGP includes a variety of proposed policies aimed at preserving cultural resources, such as identifying, designating, and protecting historically and culturally significant archaeological resources or sites (GP PEIR, page 5.5-23). With adherence to proposed policies and regulations, and implementation of Mitigation Measures 5.5-1, 5.5-10 and 5.5- 11, program-level impacts to archaeological resources, including archaeological resources, paleontological resources, and disturbance of human remains, would Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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be less than significant. Individual development projects would be required to undergo project specific environmental review. If project-level significant impacts are identified, specific Mitigation Measures would be required under CEQA.

Impacts Associated with the Proposed Project (b-c)
No New Impacts. According to the GP PEIR, the development of residential or urban land uses, roads, and infrastructure may impact buried archaeological and paleontological resources, including human remains, located throughout undeveloped portions of the City. There is also potential for unknown and previously undisturbed archaeological, paleontological, and human remains to be found within the developed areas of the City. However, previously excavated areas are generally considered to have a low potential for archaeological resources (GP PEIR, page 5.16-9). Figure 5.5-2 of the GP PEIR shows areas of historical and archaeological sensitivity within the City’s planning area. According to the figure, the Project Site is potentially located within the Grijalva Adobe Canal historical archaeology sensitive area of the Spanish/Mexican Period (1800- 1870). Therefore, the Proposed Project has potential to impact archaeological resources. However, the Proposed Project would adhere to all federal, state, and local regulations as well as GP PEIR Mitigation Measures 5.5-1 through 5.5-14 to protect archaeological resources.

As part of the Project’s BMPs, in the event that evidence of archaeological resources is unearthed during construction activities, all work within 50 feet of the discovery would be halted or diverted until a qualified archaeologist can evaluate the nature and significance of the finds. No disturbance would occur in the vicinity of the find until the Project Site is evaluated by the archaeologist and the find is recorded or treated per the recommendations of the qualified archaeologist. In accordance with Section 7050.5 of the California Health and Safety Code, if human remains are found, the County Coroner shall be notified within 24 hours of the discovery. No further excavation or disturbance of the site or any nearby area reasonably suspected to overlie adjacent remains shall occur until the County Coroner has determined, within two working days of notification of the discovery, the appropriate treatment and disposition of the human remains. If the remains are determined to be Native American, the Coroner shall notify the NAHC in Sacramento within 24 hours. In accordance with California PRC, Section 5097.98, the NAHC must immediately notify those persons it believes to be the Most Likely Descendant (MLD) from the deceased Native American.

The MLD shall complete their inspection within 48 hours of being granted access to the site. The MLD would then determine, in consultation with the property owner, the disposition of the human remains.

Additionally, the Project Site has historically been developed for residential uses.

The Proposed Project proposes to construct 11 single-family residential dwellings.

Therefore, no new impacts than what has already been analyzed in the GP PEIR Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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are anticipated to occur in regard to archaeological resources. The Proposed Project would follow standard unanticipated discovery regulatory measures for archaeological resources. No Mitigation Measures are required. With implementation of the required regulatory measures below, impacts to archaeological and historical resources would be less than significant.

Conclusion
Implementation of recommended regulatory measures would reduce the potential impacts of the Proposed Project associated with Cultural Resources to less than significant. The Proposed Project does not result in any new significant impacts peculiar to the project or property, a substantial increase in the severity of the impacts evaluated in the GP EIR, or potentially significant off-site or cumulative impacts that would render Section 15183 inapplicable to the project.

With regards to the issue area of Cultural Resources, the following findings can be made:

1. No peculiar impacts to the Project or its site have been identified.

2. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

3. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

4. Feasible Mitigation Measures and uniformly applied development policies and standards contained within the GP PEIR apply to the Proposed Project. Standard regulatory practices provide protection for archaeological resources and reduce potential impacts to less than significant.

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4.6 Energy
Impact Analysis

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

X
General Plan PEIR Mitigation Measures
General Plan PEIR Mitigation Measure Applicable/Not Applicable

5.12-13 As part of the development application and
review process, coordinate with SCE, Time Warner Cable, Cox Communications Orange County, The Gas Company,
AT&T, cellular telephone service providers, and other local utilities to assess capacity and infrastructure needs to support new development or redevelopment activities.

Require that utilities be moved underground consistent
with the City’s Master Utility Undergrounding Plan.
(Implementation Program V-1)
Mitigation Measure is
applicable. The Proposed
Project would coordinate
with local utilities to assess
capacity and infrastructure
needs.

5.12-14 The City strongly encourages new development
and major renovation projects to employ green building
techniques and materials. Encourage proposed
development projects throughout the City to incorporate LEED Standards developed by the U.S. Green Building
Council or an equivalent program. Encourage building
orientations and landscaping that enhance natural
Mitigation Measure is
applicable. The Proposed
Project would comply with
the City’s Municipal Code,
applicable design
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General Plan PEIR Mitigation Measure Applicable/Not Applicable lighting and sun exposure. Prepare guidelines for
sustainable development to encourage incorporation of
these practices in new development. These guidelines
would include measures to maximize soil permeability to address related stormwater and surface-water runoff
issues. Require compliance with State Title 24 building construction standards and Energy Star conservation
standards for all development projects. (Implementation Program III-11)
standards, and Title 24
standards.

Discussion
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
Narrative Summary: Impacts Analyzed in the GP PEIR (a)
Significant and Unavoidable. The City certified the GP PEIR before the above checklist items were added to the State CEQA Guidelines. However, the topic of energy is addressed in the GP PEIR Section 5.12 – Public Services and Utilities and Section 5.15 – Climate Change. Development pursuant to the General Plan land use policy would result in the consumption of energy resources, including nonrenewable resources, through activities such as fuel consumed by construction vehicles and equipment. Fossil fuels are typically used for construction vehicles and other equipment during site clearing, grading, paving, and building. This use would have an irreversible effect on such resources. The buildout of the General Plan represents a long-term commitment to the consumption of energy resources.

The consumption of energy in the studied existing buildings is estimated to have emitted approximately 352,050 metric tons of carbon dioxide-equivalent (MTCO2e). Energy consumption in the same building types under buildout of the General Plan is expected to result in approximately 643,996 MTCO2e per year.

Overall, greenhouse gas emissions associated with building energy consumption under future development capacity of the General Plan would increase by about 83 percent relative to existing conditions (GP PEIR, page 5.15-21).

Water consumption associated with various activities under the OGP is embedded with energy by virtue of the amount of energy consumed in collecting, extracting, conveying, treating, and distributing water to end users, and treating and disposing of wastewater. According to the GP PEIR, the existing demand for the embodied energy of water is estimated to result in 58,797 MTCO2e per year, while projected demand for the embodied energy of water at Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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buildout of the OGP would be 59,297 MTCO2e per year, an increase of less than one percent relative to existing conditions (GP PEIR, page 5.15-22). Existing GHG emissions from VMT, building energy consumption, and the embodied energy of water consumption were estimated to be approximately 2,072,493 MTCO2e in 2004, while the GHG emissions under the buildout of the OGP in 2030 are projected to be approximately 3,519,569 MTCO2e.

Overall, while the GP PEIR was certified before the checklist items related to energy were added to State CEQA Guidelines, the GP PEIR discusses an overall significant environmental impact due to the buildout of the OGP in regard to energy and energy consumption. Therefore, implementation of the OGP would have a significant and unavoidable impact in regard to energy.

Impacts Associated with the Proposed Project (a)
No New Impacts. The Proposed Project would not result in potentially significant environmental impacts due to wasteful, inefficient, or unnecessary consumption of energy resources, during Project construction or operation. The three main types of energy expected to be consumed by the Proposed Project include electricity, natural gas, and petroleum products in the form of gasoline and diesel fuel. The Proposed Project’s electricity would be provided by Southern California Edison (SCE). SCE is an investor-owned public utility operating as a subsidiary of Edison International. As of 2022, SCE’s energy comes from 8.4% Nuclear, 0.1% Biomass and Waste, 5.5% Geothermal, 15.1% Solar, 9.4% Wind, 15.2% Natural Gas,

0.8% Eligible Hydroelectric, 3.3% Large Hydroelectric, and 42% unspecified sources. Natural gas would be provided to the Proposed Project by Southern California Gas (SoCalGas). Project-related vehicle trip energy consumption would be predominantly gasoline and diesel fuel. Gasoline and other vehicle fuels are commercially provided commodities and would be available to the patrons and employees of the Proposed Project via commercial outlets.

Information from the CalEEMod version 2022.1.1 output (Appendix A) was utilized to generate estimates of the Proposed Project’s electricity, natural gas, and fuel consumption for construction and operational aspects of the Proposed Project.

Construction Energy
Construction of the Proposed Project would include demolition, site preparation, grading, building construction, paving, and application of architectural coatings.

The Proposed Project is anticipated to start construction no sooner than September 2024 with completion estimated by 2026. It is anticipated to be operational in 2026. The modeling assumed 13 residential units.

As mentioned previously, electrical service would be provided by SCE. The total electricity usage from the Proposed Project’s construction related activities is estimated to be approximately 20,192 kWh.

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The Proposed Project’s construction phase would consume electricity and fossil fuels as a single energy demand, meaning that once construction is completed, their use would cease. This includes gasoline and diesel fuel usage for auto and truck trips during construction and operation, and off-road equipment usage during construction, which is anticipated to be completed in one phase.

Proposed Project construction would represent a “single event” diesel fuel demand and would not require on‐going or permanent commitment of diesel fuel resources once construction is completed. The Proposed Project’s estimated energy consumption during construction is provided in Appendix A. In summary, the usage was estimated as follows: Proposed Project construction activities would consume an estimated 40,886 gallons of diesel fuel, while construction worker trips would consume an estimated 1,965 gallons of fuel. For vendor and hauling trips, an estimated 1,208 gallons of fuel would be consumed.

Construction equipment used over the approximately 14-month construction phase would conform to CARB regulations and California emissions standards.

There are no unusual project characteristics or construction processes that would require the use of equipment that would be more energy intensive than is used for comparable activities; or equipment that would not conform to current emissions standards (and related fuel efficiencies). Equipment employed in construction of the project would therefore not result in inefficient, wasteful, or unnecessary consumption of fuel.

The Proposed Project would utilize construction contractors which practice compliance with applicable CARB regulation regarding retrofitting, repowering, or replacement of diesel off-road construction equipment. Additionally, CARB has adopted the Airborne Toxic Control Measure to limit heavy-duty diesel motor vehicle idling in order to reduce public exposure to diesel particulate matter and other Toxic Air Contaminants. Compliance with these measures would result in a more efficient use of construction-related energy and would minimize or eliminate wasteful or unnecessary consumption of energy. Idling restrictions and the use of newer engines and equipment would result in less fuel combustion and energy consumption.

Additionally, as required by California Code of Regulations Title 13, Motor Vehicles, section 2449(d)(3) Idling, limits idling times of construction vehicles to no more than five minutes, thereby minimizing or eliminating unnecessary and wasteful consumption of fuel due to unproductive idling of construction equipment. Enforcement of idling limitations is realized through periodic site inspections conducted by County building officials, and/or in response to citizen complaints.

Therefore, potential impacts associated with wasteful, inefficient, or unnecessary consumption of energy resources during construction of the Proposed Project would be less than significant, and no mitigation would be required.

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Operations
Energy consumption in support of or related to project operations would include transportation energy demands (energy consumed by employee and patron vehicles accessing the Project Site) and facilities energy demands (energy consumed by building operations and site maintenance activities).

The Proposed Project would generate a maximum of 100 trips per day and consume an estimated 10,140 gallons of fuel per year (Appendix C – Rancho Ridge Infill Project Transportation Study Screening Assessment, Ganddini Group, Inc., December 19, 2022). Trip generation and VMT generated by the Proposed Project are consistent with other similar residential land uses of similar scale and configuration. That is, the Proposed Project does not propose uses or operations that would inherently result in excessive and wasteful vehicle trips and VMT, nor associated excess and wasteful vehicle energy consumption. Furthermore, the California Energy Commission reports the state of California consumed approximately 3.6 billion gallons of diesel and 13.6 billion gallons of gasoline in 2022. The increase in fuel consumption from the Proposed Project is insignificant in comparison to the State’s demand. Therefore, project transportation energy consumption would not be considered wasteful, inefficient, or otherwise unnecessary.

Building operation and site maintenance (including landscape maintenance) would result in the consumption of electricity (provided by SCE) and natural gas (provided by SoCalGas). The annual natural gas and electricity demands are provided in the CalEEMod output in Appendix A. The estimated electricity demand for the Proposed Project is approximately 89,637 kWh per year. By comparison, the residential sector of Orange County consumed approximately 7,272 million kWh of electricity in 20214. In addition, the estimated natural gas consumption for the Proposed Project is approximately 498,360 kBTU per year. In 2021, the non-residential sector of Orange County consumed approximately 362 million terms of gas5. Therefore, the increase in both electricity and natural gas demand from the Proposed Project is insignificant compared to the County’s 2021 residential sector demand.

Energy use in buildings is divided into energy consumed by the built environment and energy consumed by uses that are independent of the construction of the building such as in plug-in appliances. In California, the California Building Standards Code Title 24 governs energy consumed by the built environment, mechanical systems, and some types of fixed lighting. Non-building energy use, or “plug-in” energy use can be further subdivided by specific end-use

4 Electricity Consumption by County (ca.gov), California Energy Commission. Accessed November 30, 2024. 5 Gas Consumption by County (ca.gov), California Energy Commission. Accessed on November 30, 2024.

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(refrigeration, cooking, appliances, etc.). The Proposed Project would be required to comply with Title 24 standards.

The Proposed Project would implement the mandatory requirements of California’s Building Efficiency Standards (Title 24, Part 6) to reduce energy consumption. California’s building standards are some of the strictest in the nation and the Proposed Project’s compliance with the Building Code would ensure that wasteful, inefficient, or unnecessary consumption of energy is minimized. The California Building Code is designed to reduce the amount of energy needed to heat or cool a building, reduce energy usage for lighting and appliances, and promote usage of energy from renewable sources. The Proposed Project’s energy demands in total would be comparable to other residential projects of similar scale and configuration. Therefore, the Proposed Project’s facilities’ energy demands, and energy consumptions would not be considered inefficient, wasteful, or otherwise unnecessary. The Proposed Project’s energy demand and energy consumption would not be considered inefficient, wasteful, or otherwise unnecessary, and no project-specific mitigation would be required. The Proposed Project’s impact is considered less than significant. The Proposed Project would not result in any new or substantially greater impacts from what is analyzed in the GP PEIR are found.
b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
Narrative Summary: Impacts Analyzed in the GP PEIR (b)
Less than Significant Impact. The City certified the GP PEIR before the above checklist items were added to the State CEQA Guidelines. However, the topic of energy is addressed in the GP PEIR Section 5.12 – Public Services and Utilities and Section 5.15 – Climate Change. The GP PEIR discusses adherence to state and local plans, such as the California Renewable Energy Portfolio Standard Program, SB 107, the California Green Building Initiative, Air Resources Board, and SCAQMD rules and regulations. The OGP is required to comply with state and local plans for renewable energy or energy efficiency and does not propose any additional standards that would conflict with or obstruct a state or local plan for renewable energy or energy efficiency.

Impacts Associated with the Proposed Project (b)
No New Impacts. The Proposed Project would comply with the California Green Building Standard Code requirements for energy efficient buildings and appliances in compliance with the State’s Energy Plan and Title 24 CCR energy efficiency standards and energy efficiency programs.

An individual project does not have the ability to comply or conflict with Pavley (AB 1493) regulations because they are intended for agencies and their adoption of procedures and protocols for reporting and certifying GHG emission reductions Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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from mobile sources. However, the vehicles associated with the Proposed Project would be required to comply with federal and state fuel efficiency standards.

The Proposed Project would be required to meet or exceed the energy standards established in the California Green Building Standards Code, Title 24, Part 11 (CALGreen). CALGreen Standards require new buildings to reduce water consumption, employ building commissioning to increase building system efficiencies, divert construction waste from landfills, and install low pollutant- emitting finish materials.

Additionally, the Proposed Project is not expected to conflict with or obstruct a state or local plan for renewable energy or energy efficiency. The Proposed Project would purchase electricity through SCE which is subject to the requirements of California Senate Bill 100 (SB 100). SB 100 is the most stringent and current energy legislation in California, requiring that renewable energy resources and zero-carbon resources supply 100% of retail sales of electricity to California end-use customers and 100% of electricity procured to serve all state agencies by December 31, 2045. The Project would not engage in wasteful or inefficient uses of energy and aims to achieve energy conservations goals within the State of California. Notwithstanding, the Proposed Project proposes residential uses and would not have any long-term effects on an energy provider’s future energy development or future energy conservation strategies.

Therefore, the Proposed Project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency, and no mitigation would be required.

Conclusion
The energy impacts of the Proposed Project would be less than significant, and no Project-specific mitigation is required. With regards to the issue of Energy, the following findings can be made:

1. No peculiar impacts to the Project or its site have been identified.

2. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

3. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

4. No Mitigation Measures contained within the GP PEIR would be required because Project-specific impacts would be less than significant.

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4.7 Geology and Soils
Impact Analysis

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

X
 Strong seismic ground shaking? X
 Seismic-related ground failure,
including liquefaction? X
 Landslides? X
b) Result in substantial soil erosion or
the loss of topsoil? X
c) Be located on a geologic unit or soil
that is unstable, or that would become
unstable as a result of the project, and
potentially result in on- site or off-site
landslide, lateral spreading,
subsidence, liquefaction or collapse?
X
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X
General Plan PEIR Mitigation Measures
General Plan PEIR Mitigation Measure Applicable/Not Applicable

5.6-1 Pursuant to state law, geologic and/or
geotechnical studies are required for proposed new
development projects located in areas identified as
susceptible to landslides and liquefaction, and for areas within an Earthquake Fault Zone or within 150 feet of an active or potentially active fault. Binding mitigation
strategies must be adopted.

Compliance with the recommendations set forth in site-
specific geologic and/or geotechnical studies will be
made a condition of approval for new development. In
addition, the City may require applicants to incorporate measures to stabilize and maintain slopes on a site-by- site basis, such as, but not limited to, proper planting, irrigation, retaining walls, and benching.
(Implementation Program III-9)
Mitigation Measure is
applicable. The Project has
prepared a Preliminary
Geotechnical Investigation
(Appendix D – Preliminary
Geotechnical Investigation,
Proposed Residential
Development, 647 North
Rancho Santiago
Boulevard, Albus &
Associates, August 2022).

The Geotechnical
Investigation includes
recommendations for
earthwork.

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General Plan PEIR Mitigation Measure Applicable/Not Applicable

5.6-2 The City will implement the following action to
ensure that land use planning and real estate processes fully account for the presence of seismic hazards in
Orange.

Work with the County of Orange and California
Geological Survey to monitor and compile information
on faults within the Orange planning area.

Mitigation Measure is not
applicable.

5.6-3 The City shall use open space easements and
other regulatory techniques to prohibit development
and avoid public safety hazards where the threat from
seismic hazards cannot be mitigated.

Mitigation Measure is not
applicable.

5.6-4 The City will maintain erosion protection measures in areas susceptible to erosion. The City shall require all future development to implement erosion protection
during construction in compliance with NPDES
requirements.

Mitigation Measure is
applicable. The Project
includes BMPs that are in
compliance with NPDES
requirements.

Discussion
a) Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
 Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42.

Narrative Summary: Impacts Analyzed in the GP PEIR (a)
Less Than Significant with Mitigation. The GP PEIR states that the City’s planning area contains two possibly active faults, both of which could result in surface fault rupture during a seismic event. No Alquist-Priolo fault zones are located in the City.

The OGP’s focus areas where changes in land use and new development are anticipated are not in the vicinity of the faults. However, various land uses occur near the faults including residential development. No OGP land use changes are proposed and redevelopment of these areas under the proposed OGP is not anticipated. However, if new development adjacent to faults occurred under the OGP, it would have the potential to expose additional people and/or structures to hazards in the event of fault rupture. This is considered a potentially significant impact.

However, the OGP has policies and regulations in place to protect residents and businesses from seismic hazards and other geologic constraints, including earthquake preparedness and emergency response programs. Adherence to Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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federal, state, and local regulations; adherence to policies in the OGP, and implementation of Mitigation Measures 5.6-1 through 5.6-4 would reduce potential seismic effects of fault rupture to a less than significant level at the program level of analysis. Individual development projects would be required to undergo project-specific environmental review. If project-level significant impacts are identified, specific Mitigation Measures would be required under CEQA.

Impacts Associated with the Proposed Project (a)
No New Impacts. According to the Geotechnical Investigation, there are no active faults known to project through or immediately adjacent to the Project Site and the Project Site does not lie within an “Earthquake Fault Zone” as defined by the State of California in the Earthquake Fault Zoning Act. Accordingly, there is little probability of surface rupture due to faults beneath the Project Site. There are, however, several faults located in sufficiently close proximity to the Project Site. The closest known active faults to the Project Site are the Elsinore fault located 6.87 miles away from the Project Site, San Joaquin Hills fault located approximately 7.66 miles away from the Project Site, and Puente Hills (Coyote Hills) fault located approximately 7.91 miles away from the Project Site. Therefore, potential for ground rupture due to an earthquake beneath the Project Site is considered low and no mitigation would be required. No new impacts from what is analyzed in the GP PEIR are found.
 Strong seismic ground shaking?
Narrative Summary: Impacts Analyzed in the GP PEIR (a)
Less than Significant Impact with Mitigation. The GP PEIR states that the City’s planning area is located within a seismically active region of southern California near large regional faults capable of generating strong earthquakes with high- intensity ground shaking. The potential for earthquakes along these faults to affect the planning area varies according to the intensity of the seismic event and the distance of the fault from the planning area. In general, greater earthquake intensity and closer proximity to the fault producing the earthquake would increase the intensity of ground shaking. The entire planning area is at risk for damage caused by ground shaking. Development under the OGP has the potential to expose additional people and/or structures to the hazards caused by ground shaking. This is considered a potentially significant impact.

Adherence to federal, state, and local regulations described under the Regulatory Setting (such as Building Code requirements for earthquake design); adherence to policies in the OGP and implementation of Mitigation Measures 5.6- 1 through 5.6-3 would reduce the seismic effects of ground shaking to a less than significant level at the program level of analysis. Individual development projects would be required to undergo project-specific environmental review. If project- Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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level significant impacts are identified, specific Mitigation Measures would be required under CEQA.

Impacts Associated with the Proposed Project (a)
No New Impacts. The Project Site is not situated within a currently established Alquist-Priolo Earthquake Fault Zone. However, the Project Site is situated in a seismically active area that has historically been affected by generally moderate to occasionally high levels of ground motion. The Project Site lies in relatively close proximity to several seismically active faults; therefore, the Proposed Project would likely experience similar moderate to occasionally high ground shaking from these fault zones, as well as some background shaking from other seismically active areas of the southern California region. The Proposed Project is required to be constructed consistent with all applicable seismic design standards contained in the current California Building Code (CBC), including Section 1613A Earthquake Loads, which would reduce impacts associated with ground shaking and seismic activity. Design and construction in accordance with the current CBC requirements and the Geotechnical Investigation’s recommendations as well as the City’s Mitigation Measures are anticipated to address impacts related to potential ground shaking. Therefore, potential impacts associated with adverse effects to people or structures from seismic ground shaking would be less than significant, and no mitigation would be required. The Proposed Project would not result in any new or substantially greater impacts from what is analyzed in the GP PEIR.
 Seismic-related ground failure, including liquefaction? Narrative Summary: Impacts Analyzed in the GP PEIR (a)
Less than Significant Impact with Mitigation. Liquefaction areas pose potential land use constraints, with the severity of damage to structures varying based on the type and magnitude of liquefaction failure. Portions of the City’s planning area along the Santa Ana River and Santiago Creek and developed areas adjacent to these waterways have been designated significant liquefaction hazard areas (GP PEIR, 5.6-16). In the event of a major earthquake, buildings in these areas that are not anchored to bedrock material could suffer damage or failure, resulting in property loss and potential harm to persons within said buildings. Portions of all focus areas within the OGP are located within areas identified as liquefaction hazard areas, with the exception of the West Chapman Avenue/Uptown Orange focus area. The OGP allows development to occur in the vicinity of areas identified as liquefaction hazard areas. However, the level of development is likely to be more limited in these areas as a result of liquefaction hazards. Development under the OGP in liquefaction areas has the potential to expose additional people and/or structures to the hazards caused by liquefaction. This is considered a potentially significant impact.

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Adherence to federal, state, and local regulations; adherence to policies in the OGP mentioned above; and implementation of Mitigation Measures 5.6-1 through 5.6-4 requiring site- specific geotechnical studies and project-level mitigation addressing liquefaction would reduce the effects of liquefaction to a less than significant level at the program level of analysis. Individual development projects would be required to undergo project-specific environmental review. If project-level significant impacts are identified, specific Mitigation Measures would be required under CEQA.

Impacts Associated with the Proposed Project (a)
No New Impacts. Liquefaction is a seismic phenomenon in which loose, saturated, granular soils behave similarly to a fluid when subject to high-intensity ground shaking. Liquefaction occurs when three general conditions exist: 1) shallow groundwater; 2) low density non-cohesive (granular) soils; and 3) high-intensity ground motion. Liquefaction is typified by a buildup of pore-water pressure in the affected soil layer to a point where a total loss of shear strength occurs, causing the soil to behave as a liquid. Effects of liquefaction on level ground include settlement, sand boils, and bearing capacity failures below structures. The Geotechnical Investigation for the Proposed Project found that the Project Site is not mapped for State-designated zones of potentially liquefiable soils.

Groundwater was also not encountered to the maximum depth of 51.5 feet drilled during the geotechnical investigation site exploration. As a result, the Geotechnical Investigation concluded that the potential for liquefaction to occur beneath the Project Site is considered very low. Additionally, the City requires all new development projects to follow recommendations listed in the projects’ geotechnical investigation reports. The Proposed Project would adhere to the Geotechnical Investigation’s recommendations which further reduce the potential for liquefaction. Therefore, potential impacts associated with adverse effects to people or structures from seismic-related ground failure, including liquefaction, would be less than significant, and no mitigation would be required.

No new impacts from what is analyzed in the GP PEIR are found.  Landslides?
Narrative Summary: Impacts Analyzed in the GP PEIR (a)
Less than Significant Impact with Mitigation. The GP PEIR states that buildout of the OGP allows development to occur in the vicinity of areas identified as landslide hazard areas. The low hills of the northern and eastern portions of the planning area have been designated as susceptible to earthquake-induced landslides and currently contain open space as well as existing residential development.

Buildings, roadways, utilities, persons, and the like located within or below these hazard areas could be subject to severe damage or injury in the event of an earthquake-induced landslide. However, the GP PEIR states that the OGP focus areas where OGP land use changes are proposed, and new development is Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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anticipated are not within landslide areas. However, if new development occurs in landslide areas under the OGP, it has the potential to expose additional people and/or structures to earthquake-induced landslides. This is considered a potentially significant impact.

Adherence to federal, state, and local regulations such as building code requirements described under the Regulatory Setting section; adherence to policies in the OGP mentioned above; and implementation of Mitigation Measures 5.6-1 through 5.6-4 requiring site specific geotechnical studies and project-level mitigation for projects in landslide areas would reduce the seismic effects of earthquake-induced landslides to a less than significant level at the program level of analysis. Individual development projects would be required to undergo project specific environmental review. If project-level significant impacts are identified, specific Mitigation Measures would be required under CEQA.

Impacts Associated with the Proposed Project (a)
No New Impacts. According to the Geotechnical Investigation, there are no known landslides or other slope instability issues impacting the Project Site. The Project Site is relatively level; therefore, geologic hazards associated with landsliding are not anticipated. Additionally, according to the United States Geological Survey (USGS) U.S. Landslide Inventory and Susceptibility Map viewer, the Project Site is not designated as an area susceptible to landslides.

Consequently, the potential for the existence of landslides is considered less than significant. No new impacts from what is analyzed in the GP PEIR are found. b) Would the project result in substantial soil erosion or the loss of topsoil? Narrative Summary: Impacts Analyzed in the GP PEIR (b)
Less than Significant Impact with Mitigation. The eastern portion of the City’s planning area is susceptible to soil erosion due to the hilly topography. The urbanized portion of the City could also be susceptible to erosion from wind and stormwater runoff associated with development activities. Development under the OGP has the potential to increase soil erosion if undertaken without erosion control. This is considered a potentially significant impact. According to the GP PEIR, adherence to federal, state, and local regulations (such as NPDES requirements for a SWPPP and compliance with the City’s grading ordinance); adherence to the OGP policies; and implementation of Mitigation Measure 5.6-4 requiring development activities to implement erosion control measures during construction would reduce the effects of erosion t o a less than significant level at the program level of analysis. Individual development projects would be required to undergo project-specific environmental review. If project-level significant impacts are identified, specific Mitigation Measures would be required under CEQA.

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Impacts Associated with the Proposed Project (b)
No New Impacts. According to the Geotechnical Investigation, the Project Site has soils that have a Very High expansion potential. Therefore, the Geotechnical Investigation includes recommendations that are designed to adapt to the Project Site’s soil conditions. During Project construction when soil is exposed, temporary soil erosion may occur which could be exacerbated by rainfall. To control the potential for soil erosion, wind, dust, and water quality impacts, the Proposed Project is required to comply with the City’s policies and regulations, including the City’s Erosion Control, Sediment Control, and Water Quality Notes, as well as the GP PEIR Mitigation Measures 5.6-1 through 5.6.4. The Proposed Project would implement erosion control measures, including SCAQMD rules relating to dust control (such as SCAQMD Rule 403), and rules to protect water quality including preparing a Stormwater Pollution Prevention Plan (SWPPP) to be approved by the Santa Ana Regional Water Quality Control Board (SARWQCB).

Compliance with Federal, State, and Local regulations would ensure potential impacts are less than significant. Therefore, potential impacts associated with soil erosion, or the loss of topsoil would be less than significant, and no mitigation would be required. No new impacts from what is analyzed in the GP PEIR are found.
c) Would the project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse?
Narrative Summary: Impacts Analyzed in the GP PEIR (c)
Less than Significant Impact with Mitigation. Landslides that occur naturally represent potential hazards to property and persons in hillside areas of the City.

Buildings, roadways, utilities, persons, and infrastructure located within or below these hazard areas could be subject to severe damage or injury in the event of the emergency, The OGP allows development to occur in the vicinity of areas identified as landslide hazard areas. Additionally, the City includes several abandoned and closed landfills. Areas that have a past use of landfill may contain unstable geology and soils. OGP Plan land use focus areas where land use changes are proposed and new development is anticipated, are not within the eastern portion of the City’s planning area, which is exposed to landslides.

Only one of the focus areas overlaps abandoned landfills along Santiago Creek.

The OGP designates this area as Open Space – Park. However, a commercial overlay has been applied to this area, which allows for future development potential for commercial purposes. The level of development is likely to be more limited in the area where unstable geologic units could be present due to the former landfill use. Development within hillside areas or on abandoned landfill sites under the OGP has the potential to expose additional people and/or structures Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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to landslides, subsidence, or lateral spreading from unstable geology. This is a potentially significant impact. Adherence to federal, state, and local regulations; adherence to policies in the OGP mentioned above; and implementation of Mitigation Measures 5.6-1 through 5.6-4 would reduce the seismic effects of unstable geologic units to a less than significant level at the program level of analysis. Individual development projects would be required to undergo project specific environmental review. If project-level significant impacts are identified, specific Mitigation Measures would be required under CEQA.

Impacts Associated with the Proposed Project (c)
No New Impacts. Impacts related to liquefaction and landslides are discussed under threshold a. Landsliding and liquefaction are not anticipated at the Project Site. The Project Site is relatively level. Groundwater was not encountered to the maximum depth of 51.5 feet drilled during the geotechnical site exploration.

Additionally, the Project Site is not mapped for State-designated zones of liquefiable soils or landslide potential. Therefore, there are no impacts related to the potential for the existence of landslides and liquefaction. No new impacts from what is analyzed in the GP PEIR are found, and no new mitigation is required. d) Would the project be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property?
Narrative Summary: Impacts Analyzed in the GP PEIR (d)
Less than Significant Impact. According to the GP PEIR, much of Orange County contains soil with expansive characteristics. The OGP allows development to occur primarily in the land use focus areas, but also in portions of the eastern portion of the City’s planning area, and areas that have not reached their full development potential. Therefore, development could occur in areas with expansive soil characteristics. However, the GP PEIR states that adherence to federal, state, and local regulations such as Building Code requirements for foundations, standard engineering techniques, and policies in the OGP reduce the hazards associated with expansive soils. Therefore, there is a less than significant impact in regard to expansive soil. Individual development projects would be required to undergo project-specific environmental review. If project- level significant impacts are identified, specific Mitigation Measures would be required under CEQA.

Impacts Associated with the Proposed Project (d)
Less than Significant Impact. The Geotechnical Investigation found that the near- surface soils onsite are generally anticipated to possess a Very High expansion potential. The Geotechnical Investigation requires additional testing for soil expansion prior to construction of foundations and other concrete work to confirm these conditions. The available methods for expansive soils are chemical Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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treatment, removal and replacement, and moisture conditioning (pre-wetting) and compaction control. Among the listed methods in the Geotechnical Report, moisture conditioning and compaction is listed as the most suitable method.

Compacting the material wet side of optimum and at a lower density but with adequate strength reduces the expansion potential. The Geotechnical Investigation lists recommendations for the Project Site in order to adapt to the Project Site’s expansive soils. GP PEIR Mitigation Measure 5.6-1 requires new development projects to follow recommendations listed in the geotechnical report as a Condition of Approval. Therefore, implementation of the GP PEIR Mitigation Measures would reduce the Proposed Project’s impacts to expansive soils to less than significant, and no new mitigation is required. e) Would the project have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water?
Narrative Summary: Impacts Analyzed in the GP PEIR (e)
No Impacts. Most properties within the corporate City limits are currently served by a public sewage collection system maintained by the City (GP PEIR, page 5.6- 19). The majority of development under the OGP would occur in areas already served by public sewage collection systems. Applications for new septic systems are approved by the City based on geotechnical analyses demonstrating appropriate soils. Soils incapable of inadequately supporting the use of septic tanks or alternative wastewater disposal systems have not been identified in the City’s planning area. Existing properties within unincorporated islands in Orange County that fall within the planning area that may be on septic systems would likely be converted to sewer upon incorporation. No impacts posed by soils with septic tank limitations are expected. Therefore, the use of septic tanks or alternative wastewater disposal systems would not be required as part of the implementation of the OGP, and no significant impacts would occur.

Impacts Associated with the Proposed Project (e)
No New Impacts. The Proposed Project would not involve the installation of septic tanks or alternative wastewater disposal systems. Therefore, no impacts to soils associated with septic tanks or alternative wastewater disposal systems would occur, and no mitigation would be required.
f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Narrative Summary: Impacts Analyzed in the GP PEIR (f)
Less than Significant Impact. The GP PEIR states that development pursuant to the buildout of the OGP has the potential to impact unknown archaeological and paleontological resources. Ground-disturbing activities, such as construction Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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associated with infill, redevelopment, and/or expansion of infrastructure, have the potential to impact buried paleontological resources. Thus, development of land pursuant to the General Plan has the potential to impact significant known and unknown paleontological resources. However, the majority of new development anticipated under the General Plan would involve infill and redevelopment of existing developed areas. There is potential for unknown and previously undisturbed archaeological, paleontological, and human remains to be found within the developed areas of the City’s planning area as redevelopment activities occur. Because the majority of these projects would consist of infill and redevelopment, this grading would occur on previously graded surfaces.

Previously excavated areas are generally considered to have a low potential for archaeological resources, since the soil containing such resources has been removed. Sites that have been minimally excavated in the past (e.g., undeveloped parcels, vacant lots, and lots containing surface parking; undeveloped areas around historic buildings; under buildings with post, pier, slab, or shallow wall foundations without basements, etc.) have the greatest likelihood of encountering paleontological resources. This is a potentially significant impact.

According to the GP PIER, there are numerous federal, state, and local regulations that protect cultural, archaeological, and paleontological resources in the City.

By implementing OGP policies; applying program-level mitigation at the General Plan level of analysis, the Old Towne Design Standards, Secretary of Interior Standards for Rehabilitation; and utilizing the site development permit and CEQA processes for individual projects, the potential impact to these cultural resources would be reduced to a less than significant level with Mitigation Measures 5.5-1 through 5.5-10.

Impacts Associated with the Proposed Project (f)
No New Impacts. Project-specific impacts are less than significant with mitigation and uniformly applied development policies incorporated. It is unlikely that the Proposed Project would directly or indirectly destroy a unique paleontological resource or site or unique geologic feature because significant portions of the Project Site have been disturbed by grading in previous developments. Although no impacts to paleontological resources are anticipated, since grading activities have a potential for encountering inadvertent resources in the Project Site, the applicant would be required to comply with MM GEO-1. With implementation of MM GEO-1, the impacts related to paleontological or geologic sites or resources would be less than significant.

Mitigation Measures: MM GEO-1: Unanticipated Discovery of Cultural Resources Should archaeological resources (sites, features, or artifacts) be exposed during construction activities for the proposed project, all construction work occurring within 100 feet of the find shall immediately stop until a qualified archaeologist, meeting the Secretary of the Interior’s Professional Qualification Standards, can Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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evaluate the significance of the find and determine whether or not additional study is warranted. Depending upon the significance of the find, the archaeologist may simply record the find and allow work to continue. If the discovery proves significant under CEQA, additional work such as preparation of an archaeological treatment plan, testing, or data recovery may be warranted.

Conclusion
The Proposed Project is required to comply with mitigation measure MM GEO-1 to ensure that Project-specific impacts would be less than significant. Potential impacts identified for the Proposed Project would not be greater than what were identified in the GP PEIR; therefore, the Proposed Project would not create a new significant impact or a substantial increase in the severity of previously identified impacts. With regards to the issue of Geology and Soils, the following findings can be made:

1. No peculiar impacts to the Project or its site have been identified.

2. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

3. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

4. Feasible Mitigation Measures and uniformly applied development policies and standards contained within the GP PEIR apply to the Proposed Project. With implementation of MM GEO-1, Project- specific impacts would be less than significant.

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4.8 Greenhouse Gas Emissions
Impact Analysis

CEQA THRESHOLDS
Project
Peculiar
Impact that
is not
Substantiall
y Mitigated
by Uniform
Applied
Policies
Significan
t Impact
not
Analyzed
as
Significan
t in the

GP PEIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed in
the GP PEIR
Adverse
Impact
More
Severe
Based on
Substanti
al New
Informati
on
No
New
Impac
t from
GP
PEIR
VIII. GREENHOUSE GAS EMISSIONS: Would the project:
a) Generate greenhouse gas
emissions, either directly or indirectly,
that may have a significant impact on
the environment?

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

X
General Plan PEIR Mitigation Measures
General Plan PEIR Mitigation Measure Applicable/Not Applicable

5.15-1 Within 24 months of adoption of the General Plan and certification of the EIR, the City shall establish a global climate change action plan that includes a baseline
inventory of all GHG emissions associated with all
residences, businesses, industries, agriculture, municipal operations, and other sources within the City limits;
establishment of a GHG emissions reduction target;
development of enforceable, feasible GHG emissions
reduction measures to meet the established target; and
performance monitoring of the GHG emissions reduction
measures to occur every 3 years to ensure the emissions reductions are being achieved. (Implementation Program
I-35)
Mitigation Measure is not
applicable.

5.15-2 Within 12 months of the effective date of the OGP, City staff shall submit to the City Council an ordinance that requires and/or provides incentives for: (1) specified new residential development to comply with a specified green Mitigation Measure is not
applicable. However, the
Proposed Project would
comply with the most
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General Plan PEIR Mitigation Measure Applicable/Not Applicable building program or show that its development provides
comparable effectiveness to such a program; and (2)
specified non-residential development of a specified size comply with a specified green building program or show
that its development provides comparable effectiveness
to such a program.
recent Building Code and
Energy Code.

Discussion
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Narrative Summary: Impacts Analyzed in the GP PEIR (a)
Significant and Unavoidable. The City certified the GP PEIR before the above checklist items were added to State CEQA Guidelines. However, the topic of greenhouse gas is addressed in GP PEIR Section 5.15 – Climate Change. The GP PEIR states that the mass of GHG emissions generated by an individual development project under a general plan, such as the OGP, would be so minute that the concentration of GHGs in the atmosphere would essentially stay the same in comparison to GHG emissions produced by activities elsewhere in the world (GP PEIR, page 5.15-19 & 20). Implementation of the OGP would generate GHG emissions, including CO2, CH4, and N2O primarily associated with VMT, electricity and natural gas consumption of buildings, energy embodied in water consumption (i.e. the electricity required to extract, convey, treat, and distribute treated water to the Project Site), and construction activities associated with future development activities under the OGP. Furthermore, increased GHG emissions associated with the OGP could potentially impede implementation of the state’s mandatory requirement under AB 32 to reduce statewide GHG emissions to 1990 level by 2020 (GP PEIR, page 5.15-20). Therefore, buildout of the OGP could potentially conflict with the state mandatory requirement. Buildout of the OGP would increase overall GHG emissions by 52 percent from 2004 to 2030.

Increased solid waste generation and the associated management and disposal in landfills under the OGP are also anticipated to result in increased GHG emissions associated with the release of landfill gas; GHG emissions would also result from the collection of solid waste and transport to the landfill. Because implementation of the OGP would result in an approximately 52 percent increase in GHG emissions from approximately 2,072,493 MTCO2e in 2004 to approximately 3,159,568 MTCO2e under buildout of the OGP in 2030, and also exceed the City’s threshold of the emission of 10,000 metric tons per year CO2e equivalent for an individual project’s contribution to the global GHG emissions environment, this is a potentially significant impact.

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Adherence to and implementation of regulations, General Plan policies, and implementation of Mitigation Measures 5.15-1 through 5.15-2, would reduce GHG emissions, but not to a less than significant level. This impact would remain significant and unavoidable. Individual development projects would be required to undergo project-specific environmental review. If project-level significant impacts are identified, specific Mitigation Measures would be required under CEQA.

Impacts Associated with the Proposed Project (a)
No New Impacts. An Air Quality, Global Climate Change, and Energy Impact Analysis by Ganddini, dated March 31, 2023 (Appendix A), was prepared for the Proposed Project and analyzes GHG emissions associated with the Proposed Project. SCAQMD published the Interim CEQA Greenhouse Gas (GHG) Significance Thresholds, December 2008, to assist local agencies with determining the impact of a project’s GHG emissions. SCAQMD’s objective in providing the GHG guidelines is to establish a performance standard that would ultimately contribute to reducing GHG emissions below 1990 levels, and thus achieve the requirements of the California Global Warming Solutions Act (AB 32).

In the absence of a formal threshold established by the State, SCAQMD’s interim GHG threshold has been established for use by lead agencies in determining significance of GHG emissions in CEQA. SCAQMD guidance describes a five- tiered approach for determining significance. Tier 3 is the primary method used for development projects of the Proposed Project’s size. The Tier 3 approach limits the amount of GHG emissions from residential and commercial development projects to 3,000 metric tons of CO2 equivalents per year (MTCO2e/yr). If the project exceeds 3,000 MTCO2e/yr, then the impact is considered significant, and Mitigation Measures would be required to reduce emissions below the threshold.

The Proposed Project is anticipated to generate GHG emissions from area sources, energy usage, mobile sources, waste disposal, water usage, and construction equipment. Greenhouse gas emissions were calculated for on-site and off-site construction and operations activity using CalEEMod 2022.1.1.6 (Appendix A). Table 7 – Project-Related Greenhouse Gas Emissions shows the construction greenhouse gas emissions, including equipment and worker vehicle emissions for all phases of construction. Construction emissions are averaged over 30 years and added to the long-term operational emissions, pursuant to SCAQMD recommendations. Because impacts from construction activities occur over a relatively short period of time, they contribute a relatively small portion of the overall lifetime project GHG emissions. However, SCAQMD recommends that construction emissions be amortized over a 30-year project lifetime and added to the overall project operational emissions. Table 7 shows that the total for the Proposed Project’s emissions (without credit for any reductions from sustainable design and/or regulatory requirements) would be 149.53 MTCO2e per year.

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According to the SCAQMD threshold of significance, a cumulative global climate change impact would occur if the GHG emissions created from ongoing operations of the Proposed Project would exceed the SCAQMD threshold of 3,000 MTCO2e per year for all land uses. Therefore, operation of the Proposed Project would not create a significant cumulative impact to global change. Therefore, potential impacts associated with the generation of greenhouse gas emissions would be less than significant.

Table 7 – Project-Related Greenhouse Gas Emissions
Category
Greenhouse Gas Emissions (Metric Tons/Year)
Bio-CO2 NonBio-CO2 CO2 CH4 N2O C2Oe
Maximum Annual Operations 1.08 137.00 138.00 0.12 0.01 142.00 Construction1 0.00 7.50 7.50 0.00 0.00 7.53
Total Emissions 1.08 144.50 145.50 0.12 0.01 149.54
SCAQMD Draft Screening Threshold 3,000
Exceeds Threshold? No
Source: CalEEMod Version 2022.1.1.6
Notes:

1. Construction GHG Emissions CO2e based on a 30 year amortization rate. b) Would the project conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases? Narrative Summary: Impacts Analyzed in GP PEIR (b)
Significant and Unavoidable. Increased GHG emissions associated with the General Plan could potentially impede implementation of the state’s mandatory requirement under Assembly Bill 32 to reduce statewide GHG emissions to 1990 levels by the same year. Therefore, the incremental GHG emissions associated with development under the General Plan would cause a cumulatively considerable incremental contribution to significant cumulative impacts when viewed in connection with worldwide GHG emissions.

Impacts Associated with the Proposed Project (b)
No New Impacts. As shown in Table 8 – Project Consistency with CARB Scoping Plan Policies and Measures, the Proposed Project is consistent with the applicable strategies within the AB 32 Scoping Plan. The principal overall State plan and policy is AB 32, which focuses on reducing GHG emissions in California to 1990 levels by 2020. This goal is further supplemented by SB 32 and Executive Order B- Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
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30-15, which established a reduction target of at least 40 percent below 1990 emissions by 2030, and Executive Order S-3-05, which established a reduction target of at least 80 percent below 1990 emissions by 2050.

A specific requirement of AB 32 was to prepare a Climate Change Scoping Plan for achieving the maximum technologically feasible and cost-effective GHG emission reduction by 2020. The CARB Board approved a Climate Change Scoping Plan in December 2008 and updated the plan in 2014, approved a new Climate Change Scoping Plan in 2017, and the most recent Climate Change Scoping Plan in 2022. As the 2022 Scoping Plan builds upon previous versions, project consistency with applicable strategies of the 2008, 2017, and 2022 Plan are assessed in Table 8.

Table 8 – Project Consistency with CARB Scoping Plan Policies and Measures 2008 Scoping Plan Measures to Reduce
Greenhouse Gas Emissions
Project Compliance with Measure
California Light-Duty Vehicle Greenhouse
Gas Standards – Implement adopted
standards and planned second phase of
the program. Align zero- emission vehicle,
alternative and renewable fuel and
vehicle technology programs with long-
term climate change goals.

No Conflict. These are CARB enforced
standards; vehicles that access the
Project Site (that are required to comply
with the standards) would comply with the
strategy.

Energy Efficiency – Maximize energy
efficiency building and appliance
standards; pursue additional efficiency
including new technologies, policy, and
implementation mechanisms. Pursue
comparable investment in energy
efficiency from all retail providers of
electricity in California.

No Conflict. The Proposed Project would
be compliant with the current Title 24
standards.

Low Carbon Fuel Standard – Develop and
adopt the Low Carbon Fuel Standard.

No Conflict. These are CARB enforced
standards; vehicles that access the
Project Site (that are required to comply
with the standards) would comply with the
strategy.

Vehicle Efficiency Measures – Implement
light-duty vehicle efficiency measures.

No Conflict. These are CARB enforced
standards; vehicles that access the
Project Site (that are required to comply
with the standards) would comply with the
strategy.

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Medium/Heavy-Duty Vehicles – Adopt
medium and heavy-duty vehicle
efficiency measures.

No Conflict. These are CARB enforced
standards; vehicles that access the
Project Site (that are required to comply
with the standards) would comply with the
strategy.

Green Building Strategy – Expand the use
of green building practices to reduce the
carbon footprint of California’s new and
existing inventory of buildings.

No Conflict. The California Green Building
Standards Code (proposed Part 11, Title
24) was adopted as part of the California
Building Standards Code in the CCR. Part
11 establishes voluntary standards, which
are mandatory in the 2019 edition of the
Code, on planning and design for
sustainable site development, energy
efficiency (in excess of the California
Energy Code requirements), water
conservation, material conservation, and
internal air contaminants. In addition, the
2022 edition of the Code took effect
January 1, 2023. The Proposed Project
would be subject to these mandatory
standards.

High Global Warming Potential Gases –
Adopt measures to reduce high global
warming potential gases.

No Conflict. CARB identified five measures
that reduce HFC emissions from vehicular
and commercial refrigeration systems;
vehicles that access the Project Site that
are required to comply with the measures
would comply with the strategy.

Recycling and Waste – Reduce methane
emissions at landfills. Increase waste
diversion, composting, and commercial
recycling. Move toward zero waste.

No Conflict. The Proposed Project would
participate in the City’s existing waste,
organics, and recycling program.

Water – Continue efficiency programs
and use cleaner energy sources to move
and treat water.

No Conflict. The Proposed Project would
comply with all applicable City
ordinances and CAL Green requirements.
2017 Scoping Plan Recommended
Actions to Reduce Greenhouse Gas
Emissions
Project Compliance with Recommended
Action
Implement Mobile Source Strategy:

Further increase GHG stringency on all
No Conflict. These are CARB enforced
standards; vehicles that access the
Project Site (that are required to comply
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light-duty vehicles beyond existing
Advanced Clean Car regulations.
with the standards) would comply with the
strategy.

Implement Mobile Source Strategy: At
least 1.5 million zero emission and plug-in
hybrid light-duty electric vehicles by 2025
and at least 4.2 million zero emission and
plug-in hybrid light-duty electric vehicles
by 2030.

No Conflict. These are CARB enforced
standards; vehicles that access the
Project Site (that are required to comply
with the standards) would comply with the
strategy.

Implement Mobile Source Strategy:

Innovative Clean Transit: Transition to a
suite of to-be-determined innovative
clean transit options. Assumed 20 percent
of new urban buses purchased beginning
in 2018 will be zero emission buses with the
penetration of zero-emission technology
ramped up to 100 percent of new sales in
2030. Also, new natural gas buses, starting
in 2018, and diesel buses, starting in 2020,
meet the optional heavy-duty low-NOX
standard.

No Conflict. These are CARB enforced
standards; vehicles that access the
Project Site (that are required to comply
with the standards) would comply with the
strategy.

Implement Mobile Source Strategy: Last
Mile Delivery: New regulation that would
result in the use of low NOX or cleaner
engines and the deployment of increasing
numbers of zero-emission trucks primarily
for class 3-7 last mile delivery trucks in
California. This measure assumes ZEVs
comprise 2.5 percent of new Class 3–7
truck sales in local fleets starting in 2020,
increasing to 10 percent in 2025 and
remaining flat through 2030.

No Conflict. These are CARB enforced
standards; vehicles that access the
Project Site (that are required to comply
with the standards) would comply with the
strategy.

Implement SB 350 by 2030: Establish
annual targets for statewide energy
efficiency savings and demand reduction
that will achieve a cumulative doubling of
statewide energy efficiency savings in
electricity and natural gas end uses by
2030.

No Conflict. These are CARB enforced
standards; vehicles that access the
Project Site (that are required to comply
with the standards) would comply with the
strategy.

By 2019, develop regulations and
programs to support organic waste landfill
reduction goals in the SLCP and SB 1383.

No Conflict. The Proposed Project would
be required to comply with City programs
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which comply with the 75 percent
reduction required by 2020 per AB 341.
2022 Scoping Plan Priority Key Actions
and Recommendations
Project Compliance with Recommended
Actions
100 percent of light-duty vehicle sales are
ZEVs by 2035.

Not Applicable. This action is in regard to
vehicle sales, with an aim to have 100
percent of light-duty vehicle sales be ZEVs
by 2035. The Proposed Project is a multi-
family residential development and would
not interfere with such policymaking.

VMT per capita reduced 25 percent
below 2019 levels by 2030 and 30 percent
below 2019 levels by 2045.

No Conflict. The Proposed Project would
not result in an unmitigated impact to
VMT. The Project is a 93-unit residential
development located in close proximity to
existing roadways and residential and
commercial uses. Therefore, the Proposed
Project would be anticipated to
contribute to a reduction in VMT per
capita.

All electric appliances in new construction
beginning 2026 (residential) and 2029
(commercial).

For existing residential buildings, 80
percent of appliance sales are electric by
2030 and 100 percent of appliance sales
are electric by 2035 (appliances replaced
at end of life). For existing commercial
buildings, 80 percent of appliance sales
are electric by 2030 and 100 percent of
Not Applicable. This action is in regard to
appliance sales and the Proposed Project
would not interfere with such
policymaking. Furthermore, although this
action is not necessarily applicable on a
project-specific basis, the Proposed
Project is subject to the California Green
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appliance sales are electric by 2045
(appliances replaced at end of life)
Building Standards Code (proposed Part
11, Title 24) which was adopted as part of
the California Building Standards Code in
the CCR. Part 11 establishes voluntary
standards, which are mandatory in the
2019 edition of the Code, on planning and
design for sustainable site development,
energy efficiency (in excess of the
California Energy Code requirements),
water conservation, material
conservation, and internal air
contaminants. In addition, the 2022
edition of the Code took effect January 1,
2023. The Proposed Project would be
subject to these mandatory standards.

The Proposed Project would not conflict with the goals of AB-32, SB-32, or the CARB Scoping Plan as shown above; therefore, the Proposed Project would not conflict with an applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of greenhouse gases and impacts are considered to be less than significant, and no mitigation would be required.

Conclusion
The Proposed Project is consistent with the goals and objectives of AB 32, SB-32, the CARB Scoping Plan and the SCAQMD’s 3,000 MTCO2e per year threshold for all land uses. Therefore, the Proposed Project would not conflict with any applicable plan, policy, or regulation of an agency adopted for the purpose of reducing the emissions of GHGs. The Greenhouse Gas Emissions impacts of the Proposed Project would be less than significant, and no Project-specific mitigation would be required. With regards to the issue of Greenhouse Gas, the following findings can be made:

1. No peculiar impacts to the Project or its site have been identified.

2. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

3. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

4. No new Mitigation Measures would be required because Project- specific impacts would be less than significant. GP PEIR Mitigation Measures have been implemented.

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4.9 Hazards and Hazardous Materials
Impact Analysis

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

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

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

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

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

X
General Plan PEIR Mitigation Measures
General Plan PEIR Mitigation Measure Applicable/Not Applicable

5.7-1 Continue to assess risks associated with
hazardous materials and develop Mitigation
Measures accordingly. Identify hazardous
material release sites and responsible parties
and ensure that the sites are appropriately
remediated. (Implementation Program I-29)
Mitigation Measure is applicable.

The Project conducted a Phase I ESA
to assess risks with hazardous
materials.

5.7-2 Continue to work with the Orange County
Airport Land Use Commission to increase safety
and reduce noise associated with aircraft
overflights and helicopter operations within the
City by achieving the following objectives:
 Work with the FAA and local airports
(John Wayne Airport, Long Beach Airport,
Los Alamitos Army Air Base) to determine
appropriate aircraft altitude standards
for aircraft flying over the City, taking into
account public health and safety.
 Continue to regulate the siting and
operation of heliport/helistops through
the Conditional Use Permit Process in
conjunction with the Orange County
Mitigation Measure is not applicable.

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General Plan PEIR Mitigation Measure Applicable/Not Applicable Airport Land Use Commission and
Caltrans Division of Aeronautics.
 Work with the heliport/helistop operators
(police, fire, hospital, and private) to
implement flight profiles, and operating
parameters for noise control.
(Implementation Program V-17)

5.7-3 The City shall maintain, equip, and update
the Emergency Operations Center on an
ongoing basis to improve public safety and
agencies response. (Implementation Program II-
5)
Mitigation Measure is not applicable.

5.7-4 The City shall continually update building
and fire codes to:

Ensure that new development and retrofitted
development reduce potential damage from
earthquakes, floods, fire, wind, liquefaction, and
other natural hazards. (Implementation Program
I-9)
Mitigation Measure is applicable.

The Proposed Project would comply
with all applicable standards set
forth in the latest versions of the
Building Code and Fire Code.

5.7-5 The City shall continue to evaluate and
update information available to the City
regarding potential fire hazards and hazard
areas. Provide public information regarding
defensible space surrounding residences and
businesses. Use Wildland Fuel Modification
guidelines for controlling vegetation in
undeveloped areas, and Wildland Urban
Interface Code and week abatement
standards (Implementation Program I-27)
Mitigation Measure is not applicable.

5.7-6 Use public education activities to
accomplish the following objectives:
 Raise public awareness of public safety
issues including fire safety, flood hazards,
homeland security, and other programs;
and
 Educate the public regarding the
benefits of recycling and waste
reduction.

Mitigation Measure is not applicable.

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General Plan PEIR Mitigation Measure Applicable/Not Applicable Coordinate education activities and make
materials available to residents. Utilize all
available media, including forums, flyers,
brochures, email, videos, interpretive displays,
workshops, and the City’s website to
accomplish these objectives. Fully utilize the
resources of the Orange Public Library to
disseminate this information. Explore
partnerships with local schools and educators to
develop an educational program in historic
preservation, personal and community safety,
and environmental awareness.
(Implementation Program IV-3)

5.7-7 Adopt, review, implement, and update as
necessary the following master plans, standards,
and guidelines:
 Multi-Hazard Functional Plan, including
 Emergency Operations Plan and
evacuation routes.
(Implementation Program I-4)
Mitigation Measure is not applicable.

Discussion
a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? Narrative Summary: Impacts Analyzed in the GP PEIR (a)
Less than Significant Impact. The PEIR examined potential impacts of the General Plan relative to Hazards and Hazardous Materials to the public and environment.

Commercial uses such as dry cleaners and vehicle maintenance facilities, industrial uses and hospitals throughout the planning area may use, dispose of, or transport hazardous materials. Future development associated with the implementation of the General Plan that is in proximity to these uses could be exposed to hazardous materials related to the use, disposal, and transport of hazardous materials. New residential and mixed use development in areas previously zoned for commercial and industrial uses could lead to increased potential for residential exposure to hazardous materials. Some of the OGP land use focus areas are located adjacent to and on previously zoned commercial and industrial land. To minimize impacts related to hazardous materials, the GP PEIR implements Mitigation Measures 5.7-1, 5.7-6, and 5.7-7 would reduce impacts to a less than significant level by continuing to assess risks associated with Initial Study/CEQA Analysis under CEQA § 15183 Exemption February 2026 Rancho Ridge Residential Development
TTM 0052-23, Zone Change, CUP 3203-23, Major Site Plan Review 1137-23, Design Review 5119-23

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hazardous materials, educating the public on potential hazards and proper practices, and updating the Emergency Operations Plan and evacuation routes.

Under the General Plan, the City would continue to maintain permitting requirements that parallel County requirements for businesses within Orange that handle, store, or generate hazardous waste. The General Plan is in accordance with federal, state, and local requirements and regulations and new developments would be in conformance with the OCFA, State Department of Toxic Substances Control, the Regional Water Quality Control Board (RWQCB) and/or other responsible agencies. Therefore, there would be a less than significant impact with implemented Mitigation Measures.

Impacts Associated with the Proposed Project (a)
No New Impacts. The Proposed Project involves subdividing the Project Site into 11 individual parcels and developing each with a single-family dwelling, ranging from approximately 2,425 sq. ft. to approximately 2,724 sq. ft. During the construction phases of the Proposed Project, the transport of construction waste for disposal could result in accidental release of hazardous materials. The Property Owner/Developer would be required to comply with all applicable federal, state, and local laws and regulations pertaining to the transport, use, disposal, handling, and storage of hazardous waste to reduce the likelihood and severity of accidents during transit. The disposal of all construction waste would be conducted in accordance with current regulations and in conformance with emission thresholds. Ganddini Group, Inc. conducted an Air Quality, Greenhouse Gas, and Energy Impact Study for the Proposed Project. The Impact Study discusses design features to implement during the construction phase as well as operation phase to limit hazards and the release of hazardous materials and emissions.

Operation of the Proposed Project would not involve the transport, use, or disposal of copious quantities of hazardous materials. The use of hazardous materials on the Project Site post-construction would consist of those commonly used in a residential setting for routine maintenance and cleaning. Proper handling of the use and disposal of hazardous materials would reduce the potential for exposure.

Therefore, with incorporation of the recommendations, consistency with General Plan policies and programs, and with application of local, state, and federal regulations related to hazardous materials, no new impacts associated with significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials would occur.
b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?

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Orange City CouncilJuly 14, 2026

Orange City Council
July 14, 2026