Attachment 11 Addendum.pdf — San Clemente City Council, November 1, 2022

Addendum to the City of San Clemente
Housing and Safety Elements Update Program
Environmental Impact Report for the
San Clemente Senior Housing & Medical
Office Project
San Clemente, California
Prepared for
City of San Clemente
910 Calle Negocio
San Clemente, CA 92673
Prepared by
RECON Environmental, Inc.
3111 Camino del Rio North, Suite 600
San Diego, CA 92108
P 619.308.9333
RECON Number 9335-6
September 29, 2022
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Addendum to 2021 FEIR for the Housing and Safety Element Updates San Clemente Senior Housing & Medical Office Project
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TABLE OF CONTENTS

1. Project Title ....................................................................................................................................... 1

2. Lead Agency Name and Address ............................................................................................... 1

3. Contact Person and Phone Number .......................................................................................... 1

4. Project Location ............................................................................................................................... 1

5. Project Applicant/Sponsor’s Name and Address .................................................................. 2

6. General Plan Designation ............................................................................................................ 2

7. Zoning ............................................................................................................................................... 2

8. Statement of Environmental Findings ...................................................................................... 2

9. Previous Environmental Document ........................................................................................... 2

10. Summary of Original Project ....................................................................................................... 3

11. Project Site Existing Conditions and Surrounding Land Use(s) ......................................... 3

12. Project Description ........................................................................................................................ 4

13. Other Required Agency Approvals or Permits Required .................................................... 5

14. New Significant Environmental Effects or Substantially More Severe Environmental Effects Compared to Those Identified in the Previous CEQA Document .............................. 5

15. Determination ................................................................................................................................. 5

15.1 Aesthetics ............................................................................................................................. 10

15.2 Agriculture Resources ....................................................................................................... 13

15.3 Air Quality ............................................................................................................................ 13

15.4 Biological Resources ......................................................................................................... 19

15.5 Cultural Resources ............................................................................................................ 23

15.6 Energy ................................................................................................................................... 26

15.7 Geology and Soils .............................................................................................................. 31

15.8 Greenhouse Gas Emissions ............................................................................................ 35

15.9 Hazards and Hazardous Materials .............................................................................. 38

15.10 Hydrology and Water Quality ........................................................................................ 41

15.11 Land Use and Planning ................................................................................................... 45

15.12 Mineral Resources ............................................................................................................ 46 ATTACHMENT 31
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TABLE OF CONTENTS (cont.)

15.13 Noise ..................................................................................................................................... 46

15.14 Population and Housing ................................................................................................. 56

15.15 Public Services and Recreation ..................................................................................... 57

15.16 Transportation ................................................................................................................... 60

15.17 Utilities and Service Systems ......................................................................................... 64

15.18 Wildfire ................................................................................................................................. 66

16.0 Mitigation Monitoring and Reporting Program Incorporated into the project .......... 68

17.0 Checklist References ..................................................................................................................... 71

FIGURES
1: Regional Location ............................................................................................................................................. 7 2: Project Location on Aerial Photograph ..................................................................................................... 8 3: Site Plan ................................................................................................................................................................ 9 4: Noise Measurement Locations .................................................................................................................. 48 TABLES
1: Project Construction Emissions in Pounds Per Day ............................................................................. 15 2: Project Operational Emissions in Pounds Per Day ............................................................................... 16 3: Project Localized Construction Emissions in Pounds Per Day.......................................................... 17 4: Project Localized Operational Emissions in Pounds Per Day ........................................................... 17 5: Off-site Construction Vehicle Fuel Consumption ................................................................................. 27 6: On-site Construction Equipment Fuel Consumption .......................................................................... 27 7: Vehicle Fuel/Electricity Consumption ...................................................................................................... 28 8: Operational Electricity and Natural Gas Use ......................................................................................... 30 9: Greenhouse Gas Emissions (metric tons per year) .............................................................................. 36 10: Storm Water Flow Rates in Cubic Yards Per Second .......................................................................... 44 11: Existing Noise Level Measurements—Long Term ............................................................................... 47 12: Potential Construction Noise Impacts by Phase .................................................................................. 49 13: Potential Construction Noise Impacts During Site Preparation and Grading ............................ 50 14: Summary of HVAC Noise Levels ............................................................................................................... 52 15: Potential Construction Vibration Annoyance Impacts at Nearest Receptor .............................. 55 16: Potential Construction Vibration Damage Impacts at Nearest Receptor .................................... 55 17: Project Trip Generation Comparison ....................................................................................................... 62 18: Mitigation, Monitoring, and Reporting Program Incorporated into the Project ...................... 69 ATTACHMENT 31
Addendum to 2021 FEIR for the Housing and Safety Element Updates San Clemente Senior Housing & Medical Office Project
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TABLE OF CONTENTS (cont.)

APPENDICES
A: Visual, Light, Glare, Shade, and Shadow Memorandum
B: Arborist Report
C: Air Quality and Greenhouse Gas Analysis
D: Biological Assessment
E: Cultural Resources Records Search Results
F: Energy Calculations
G: Geologic and Seismic Hazards Review
H: Phase I Environmental Site Assessment
I: Preliminary Water Quality Management Plan
J: Paleontological Analysis
K: Hydrology Analysis
L: Noise and Vibration Impact Analysis
M: Vehicle Miles Traveled Analysis
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CITY OF SAN CLEMENTE

ADDENDUM TO ADOPTED PROGRAM ENVIRONMENTAL IMPACT REPORT This document is an Addendum to the San Clemente Housing and Safety Elements Update PEIR (State Clearinghouse No. 2021020256) that was adopted by the City Council on October 5, 2021, hereafter referred to as “2021 FEIR”). The Addendum analyzes the environmental effects of the proposed project in light of the Final PEIR, which analyzed potential environmental impacts associated with the development of a number of housing sites, including housing development at 654 Camino del los Mares. The Addendum has been prepared in accordance with relevant provisions of the California Environmental Quality Act (CEQA) of 1970 (as amended) and the State CEQA Guidelines.

According to Section 15164 of the State CEQA Guidelines, an addendum to a previously certified EIR or Negative Declaration is the appropriate environmental document in instances when “only minor technical changes or additions are necessary” and when the new information does not involve new significant environmental effects beyond those identified in the previous EIR. The analysis herein demonstrates that the proposed addendum involves only minor technical changes to the 2021 FEIR and would not result in any new or increased severity significant environmental effects beyond those identified in the 2021 FEIR. As such, an addendum is the appropriate environmental document under CEQA.

1. Project Title
San Clemente Senior Housing & Medical Office Project

2. Lead Agency Name and Address
City of San Clemente
910 Calle Negocio
San Clemente, CA 92673

3. Contact Person and Phone Number
Jennifer Savage
Assistant to the City Manager
City of San Clemente
(949) 361-6186
[email protected]

4. Project Location
654 Camino del los Mares, San Clemente, CA 92673
Assessor’s Parcel Number 675-072-19-00
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5. Project Applicant/Sponsor’s Name and Address
Memorial Care Health System
17360 Brookhurst Street
Fountain Valley, CA 92708

6. General Plan Designation
Existing: Regional Medical Facilities (RMF)
Proposed: Community Commercial (CC4)

7. Zoning
Existing: Regional Medical Facilities (RMF1)
Proposed: Community Commercial (CC4)
All reports and documents referenced in this Addendum are on file with the City of San Clemente, Community Development Department, 910 Calle Negocio, San Clemente, California 92673.

Telephone Number: (949) 361-6100. A digital copy is available from the City website:
https://www.san-clemente.org/departments-services/environmental-documents-for-currentprojects.

8. Statement of Environmental Findings
An Addendum to the Program Environmental Impact Report (PEIR) for the Housing and Safety Elements Update was prepared by the City of San Clemente (City), Community Development Department to evaluate whether development of senior housing and medical office at 645 Camino de los Mares would result in any new significant impacts or increased severity of impacts beyond those identified in the 2021 FEIR for the Housing and Safety Elements Update. As Lead Agency under CEQA, and based on the findings contained in the attached Addendum, the City has determined that the project would not have any new or more severe impacts that were not previously identified in the PEIR for the Housing and Safety Elements Update. The City also finds that the Addendum reflects the City’s independent judgment.

The location and custodian of the documents and any other materials which constitute the record of proceedings upon which the City bases its determination to adopt this Addendum are as follows:

City of San Clemente, Community Development Department, 910 Calle Negocio, San Clemente, California, Custodian: Jennifer Savage, Assistant to the City Manager.

9. Previous Environmental Document
The 2021 FEIR determined that implementation of the Housing and Safety Elements Update would result in significant and unavoidable direct and/or cumulative impacts related to Air Quality (Direct and Cumulative), Greenhouse Gas (Direct and Cumulative), Land Use (Direct), Noise (Direct and Cumulative), and Transportation (Direct and Cumulative). The 2021 FEIR determined that implementation of the Housing and Safety Elements Update would result in impacts that would be mitigated to a level less than significant related to Biological Resources (Direct and Cumulative), ATTACHMENT 31
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Cultural and Tribal Resources (Direct and Cumulative), Geology and Soils (Direct and Cumulative), and Hazards and Hazardous Materials (Direct). All other impacts were determined to be less than significant or would have no impact.

10. Summary of Original Project
The original project consisted of updates to the City’s Housing and Safety Elements as described below.

Housing Element Update: The City prepared the 6th Cycle Housing Element Update (2021-2029) to identify the City’s housing needs and outline goals, policies, and programs to address them. The Housing Element evaluated ways to accommodate the Regional Housing Needs Assessment (RHNA) of 982 new housing units allocated to the City by the Southern California Association of Governments (SCAG). To this end, the City identified an inventory of available sites that could accommodate the City’s RHNA allocation through a combination of sources including accessory dwelling units (ADUs) and vacant and underutilized sites (Housing Sites). The project evaluated rezoning of specific sites to allow development ranging from residential medium (24 dwelling units per acre [du/ac]), residential medium high (30 du/ac), or residential high (40 du/ac). Although the 2021 FEIR evaluated rezoning of these sites, including the site at 654 Camino del los Mares, rezones were not adopted with certification of the FEIR. The City’s intent was to implement rezoning at a future date, such as when development is proposed. Relevant to this addendum, the FEIR evaluated development at 645 Camino de los Mares of up to 238 housing units and 7,500 square feet of commercial space. The site is referred to as Site V in the FEIR.

The Housing Element also included a program to allow by-right approval of housing projects that include 20 percent of the units as housing affordable to lower income households. The ministerial process is implemented through a Housing Overlay that provides objective development standards.

The City’s existing architectural and design review process is used for projects in the Affordable Housing Overlay Zone. Future development consistent with the Housing Element was anticipated to be processed either ministerially, using the City’s existing Affordable Housing Overlay Zone or a subsequently approved Housing Overlay Zone, or with a discretionary process.

Safety Element Update: The project also included an update to the Safety Element, including figure updates for the issues of geologic, seismic and soil hazards, flood hazards, potential tsunami inundation areas, fire hazard severity zones, critical facilities, and hazardous materials sites. Updates to the Safety Element did not affect the potential for development to occur or result in any physical change as it is a policy document.

11. Project Site Existing Conditions and Surrounding Land Use(s) The 6.63-acre project site is located at 654 Camino del los Mares in San Clemente, California and is a Housing Site identified in the City’s Housing Element Update sites inventory. The project site is located on the south side of Camino de los Mares, approximately 545 feet west of the intersection with Marbella. The project site is currently developed with a vacant hospital facility and supporting access drives and parking areas. The project site is located within an urban environment surrounded by a mixture of commercial and residential uses. Existing commercial uses are located along the project’s western boundary, and to the north across Camino de los Mares. The San Clemente Villas ATTACHMENT 31
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by the Sea assisted living facility is located adjacent to the project’s southeastern boundary, while Interstate 5 (I-5) is located south of the project site. Figure 1 presents the regional location and Figure 2 presents an aerial photograph of the project site and vicinity.

12. Project Description
The project would implement housing and medical office at 654 Camino del los Mares, a site evaluated for approval of rezoning and a general plan amendment under the 2021 Final EIR. The project would demolish the existing buildings on-site and construct a 250-dwelling unit senior housing complex consisting of two residential apartment buildings (Building 1, 99 units and Building 2, 151 units), and a 7,500-square-foot (sf), two-story medical office (Building 3). The senior housing complex would consist of 61 studio units (540 sf), 119 one-bedroom units (650–897 sf), and 70 two-bedroom units (985–1,120 sf), for a total of 192,568 net leasable square feet. The project proposes both indoor and outdoor amenities for the residents, including a common clubroom, fitness center, roof-top deck, resort style pool deck, landscaped courtyards, and central paseo walkway. Both the senior housing and medical office would have all-access drives with surface parking areas around the perimeters of the buildings.

Access to the project site would be provided via Camino del los Mares with two entries at the west and east ends of the project’s frontage. The west entry would serve as the main entry and drop-off site, while the east entry would be the main access point for the medical office building as well as a secondary access point for the senior apartments. In order to reinforce the right-in and right-out turning movements at the western driveway, the project would make median improvements within Camino de Los Mares, and introduce signage and a center island at the driveway entrance to direct traffic. These changes would improve safety for turns into or out of the western driveway. The site would have a total of 312 parking spaces, of which 249 would be for the senior apartments, two would be for the manager’s unit, 38 for the medical office, and the remaining 23 would be part of a shared parking agreement. Figure 3 presents the proposed site plan. Construction of the project is anticipated to begin in the fall of 2023 and would continue for 18 to 24 months.

The project would require the following discretionary actions:
• General Plan Amendment to change the land use designation from Regional Medical Facilities (RMF) to Community Commercial (CC4).
• Zoning Code Amendment to change the zoning designation from Regional Medical Facilities (RMF1) to Community Commercial (CC4).
• Vesting Tentative Parcel Map to subdivide the property into two parcels. • Conditional Use Permit for a proposed senior housing use under the Community Commercial (CC4) zone.
• Site Plan Permit for development of a new non-residential building and a tentative map. • Architectural Permit for development of a new non-residential building and a new residential development of five or more units.

Compared to the development assumptions for the site analyzed in the 2021 Final EIR, the project is consistent except 12 additional senior housing units are proposed. The 2021 Final EIR evaluated development of 238 units, while the project proposes 250 units. This addendum addresses the increase in units to ensure no new or more severe impacts would result. Additionally, it should be ATTACHMENT 31
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noted that the 2021 FEIR authorized up to a maximum of 1,564 residential units, but not all sites are likely to be developed, resulting in a conservative estimate of impacts. Additionally, the PEIR assumed the General Plan designation and zone at 654 Camino del los Mares would change from Regional Medical Facility to Community Commercial, or CC4 allowing up to 45 units per acre. The project is consistent with this zone and designation.

13. Other Required Agency Approvals or Permits Required General Construction Permit (San Diego Regional Water Quality Control Board)

14. New Significant Environmental Effects or Substantially More Severe Environmental Effects Compared to Those Identified in the Previous CEQA Document The subject areas checked below were determined to be new significant environmental effects or to be previously identified effects that have a substantial increase in severity either due to a change in project, change in circumstances or new information of substantial importance, as indicated by the checklist and discussion on the following pages.

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

15. Determination
Based on all available information in light of the entire record, the analysis in this Addendum, and pursuant to Section 15164 of the State CEQA Guidelines, the City has determined the following:
• There are no substantial changes proposed in the project which will require major revisions of the previous environmental document due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects;
• Substantial changes have not occurred with respect to the circumstances under which the project is undertaken which will require major revisions of the previous environmental document due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; or ATTACHMENT 31
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FIGURE 1
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15.1 Aesthetics
Scenic Vistas
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development that could have a substantial adverse effect on a scenic vista. The 2021 FEIR determined that adherence to regulatory requirements, including the San Clemente Municipal Code (SCMC), the design principles contained within the City’s Design Guidelines, and applicable General Plan policies focused on preservation of scenic vistas and views, would ensure that future development of Housing Sites would not have a substantial adverse effect on a scenic vista, and impacts would be less than significant.

Project
The Visual, Light, Glare, Shade, and Shadow Memorandum (Visual Memo) completed for the project evaluated potential impacts related to aesthetics (Appendix A). A scenic vista is made up of three components: public viewing location; viewing corridor; and viewing scene. Review of Figures 4.1-1 and 4.1-2a of the 2021 FEIR determined that the project site is not visible from a City-Designated View Corridor. Although views of the Pacific Ocean and canyons do exist over the project site, implementation of the project would not block these view corridors, primarily because of the extensive landform and elevation changes north of the project site. With the exception of two or three private homes that would have a portion of their views of the Pacific Ocean obscured by the four-story height of the project, land areas to the north would continue to have public and private views over the project site. It should be noted that private views are not protected views under CEQA.

Additionally, the project would not contrast with the viewing scene (the horizon, water body/ocean or other coastal visual resources). Therefore, the project would not have a new or more substantial adverse effect on a scenic vista than previously analyzed, and impacts would be less than significant.

No new impact would occur.

Scenic Resources
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development that could substantially damage any scenic resources. The 2021 FEIR determined that adherence to regulatory requirements, including the SCMC, the City’s provisions of the Master Landscape Plan for Scenic Corridors, and applicable General Plan policies, would ensure that future development of Housing Sites would not degrade scenic resources, and impacts would be less than significant.

Project
Views of a regionally significant viewing scene (the ocean, waterfront, and horizon line) exist from I-5, and would be considered as scenic vistas. I-5 has the potential for scenic designation from Caltrans if adopted by the City. Regardless of the status of designation, the project is located on the ATTACHMENT 31
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north side of I-5, making it impossible to block motorist views of the ocean, canyons or other unique landforms.

The project site, although part of the broader viewing scene, is not itself the focus of views. The project would not remove scenic resources such as natural landforms, rock outcrops, natural areas, or other elements that make up the visual character and community character of the surrounding area. As described in Section 15.5 below, there are no designated historic buildings or designated historic resources located within or near the project site. Furthermore, the vacant hospital facility and supporting structures on-site that would be demolished do not qualify as historic resources. An Arborist Report was prepared for the project consistent with the requirements of the City’s Trees Ordinances (Ord. 17.64.060 and 17.84.020(B)) (Appendix B). The Arborist Report documented that the project site currently possesses 175 ornamental landscape trees, 77 of which are in good condition, 69 are in fair condition, and 29 are in poor condition. All the tree species found on-site are common non-native ornamental landscape trees that are readily available at commercial nurseries. Most of the trees are growing in less-than-optimal conditions, and none would be required to be preserved on site. Furthermore, the project would be consistent with all City regulations, including installation of new landscaping with drought-tolerant plant material that would enhance the scenic quality of the project site. Therefore, the project would not result in new or more substantial damage to any scenic resources than previously analyzed, and impacts would be less than significant. No new impact would occur.

Visual Character and Quality
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development that could substantially degrade existing visual character or quality. The 2021 FEIR determined that adherence to applicable sections of the SCMC and the City’s Design Guidelines, as well as land use plans that provide supplemental development regulations for those areas within the City’s Focus Areas and/or Specific Plan Areas, would ensure that development of the Housing Sites would not substantially degrade the existing visual character or quality of public views of the site and its surroundings, and impacts would be less than significant.

Project
Visual quality is associated with the delicate balance of uniqueness and uniformity, as well as the organization of the visual environment into either a chaotic, bland, unique or highly intact compositional arrangement of natural and man-made features. If a project introduces chaotic elements or removes elements that contribute to the intactness of an area, then a potential visual quality impact can occur. The project’s architecture would be a positive form and have aesthetically balanced detailing and materials. The project is designed to relate to the forms, materials, and colors of structures in the immediately surrounding area in terms of color, material, style, and scale. Project architecture and its forms would be aesthetically organized and simple, and are intended to enhance the City’s character of “Spanish Village by The Sea.”
The City is characterized by tall hills to the east with some ridgeline development, large slopes made up of mostly housing, bluffs and mesa tops on each side of the freeway, and ocean views to the ATTACHMENT 31
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west. Land uses change from housing developments, to commercial complexes and strip commercial development with some business parks and employment centers are common to the eastern hills of the City. The materials, scale, architectural detailing, and color of the project’s buildings would be consistent with the existing elements of the adjacent buildings, and would be consistent with much of the style and architectural treatments found throughout the viewshed. The project would have an overall low contrast with the existing setting. The overall architectural character of the immediate commercial and institutional community is that of Spanish revival, Spanish colonial, or mission style architecture. The common building materials of the adjacent community include mostly stucco with a high percentage of buildings using red clay tile roofing and heavy beam rafters.

The visual character of the existing and undeveloped portions of the project site are not considered to have a high or moderately high visual quality, are not part of a larger viewing scene or area that has high or moderate visual quality or community character associated with it. The project would not contrast with or dominate the visual character or visual quality of the adjacent areas, nor would the project change the visual character of the surrounding areas. Therefore, the project would not result in new or more substantial impacts relating to the existing visual character or quality of the site and its surroundings, and impacts would be less than significant. No new impact would occur.

Light and Glare
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development that could generate a substantial source of light or glare that would adversely affect day or nighttime views. The 2021 FEIR determined that development of the Housing Sites would be required to comply with SCMC standards related to light and glare (Chapter 17.24.130) and General Plan Policies NR-7.1, NR-7.2, and NR-7.3, which serve to minimize light pollution and trespass in order to preserve dark skies, and impacts would be less than significant.

Project
Glare can occur during both daytime and nighttime hours. Daytime glare is caused by the reflection of sunlight or artificial light from highly polished surfaces, such as window glass or reflective materials, and to a lesser degree, from broad expanses of light-colored surfaces. Daytime glare generation is common in urban areas and is typically associated with mid- to high-rise buildings with exterior façades largely or entirely comprised of highly reflective glass or mirror-like materials from which the sun can reflect, particularly following sunrise and prior to sunset. Daytime glare generation is typically related to sun angles, although glare resulting from reflected sunlight can occur regularly at certain times of the year. Glare can also be produced during evening and nighttime hours by artificial light directed or reflected toward a light-sensitive land use.

The City’s standard of permitting indicates that all proposed glazing (e.g., glass exterior surfaces or windows) would be required to meet current building code requirements to minimize reflectivity in order to avoid creating glare in off-site locations. Additionally, building facade features would be required, such as window shades, stepped building setbacks, angled building sides, and other architectural features that would reduce direct sunlight onto the building surface and minimize glare.

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most solar panels are designed with anti-reflective glass front surface and only reflects about two percent of incoming light. Reflective Coating (AR Coating) is a technical means to reduce reflection that also increases light absorption of solar cells and thus increase its performance. The project would be required to utilize panels that follow these standards, and therefore would not create an impact to adjacent parcels or motorists. The project would not include any other reflective materials that could generate glare, such as polished surfaces, mirror like window films, or highly reflective gloss painting.

Outdoor lighting would be subject to the requirements of City’s Lighting Ordinance (Section 17.24.130, which states the following:

Exterior lighting shall be energy-efficient and shielded or recessed so that direct glare and reflections are contained within the boundaries of the parcel, and shall be directed downward and away from adjoining properties and public rights-of-way. No lighting shall blink, flash, or be of unusually high intensity or brightness. All lighting fixtures shall be appropriate in scale, intensity and height to the use. Security lighting shall be provided at all entrances/exits.

The project has developed a lighting plan that would ensure consistency with the City’s Lighting Ordinance described above, which would prevent light from spilling over onto adjacent properties.

Additionally, the Visual Memo determined that project lighting would not affect nighttime views from surrounding properties. Therefore, the project would not create a new or more substantial source of light or glare that would adversely affect day or nighttime views in the area than previously analyzed, and impacts would be less than significant. No new impact would occur.

15.2 Agriculture Resources
2021 FEIR
Section 8.1 of the 2021 FEIR determined that the City does not possess any active farmland cultivation, zoning for agricultural use, or Williamson Act Contract. Additionally, no forest lands are present.

Therefore, the 2021 FEIR found that the Housing and Safety Elements Update would not result in any impacts to agricultural or forestry resources.

Project
There is no change to the analysis provided in the 2021 FEIR. No agricultural resources are present and therefore, no new or more severe impacts would occur.

15.3 Air Quality
Consistency with Air Quality Plans
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development that could increase regional emissions. The 2021 FEIR determined that development of the Housing Sites would be inconsistent with the South Coast Air Quality ATTACHMENT 31
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Management District (SCAQMD) 2016 Air Quality Management Plan (2016 AQMP), because buildout under the plan would exceed the population estimates assumed for the 2016 AQMP and would cumulatively contribute to the nonattainment designations of the South Coast Air Basin (Basin). No mitigation measures were available that would reduce impacts associated with the inconsistency with the 2016 AQMP, and impacts were determined to remain significant and unavoidable. Overriding considerations were prepared to support approval of the Housing Element Update notwithstanding the remaining significant impacts.

Project
The project is located within the Basin, which is under the jurisdiction of the SCAQMD. The Air Quality and Greenhouse Gas Analysis prepared for the project evaluated the project’s consistency with the 2016 AQMP (Appendix C). Consistent with the 2021 FEIR, the project would require a General Plan amendment to change the land use designation from Regional Medical Facilities (RMF) to Community Commercial (CC4) to allow for development of the senior housing complex and medical office. Therefore, growth forecasting in the 2016 AQMP for the project site was based on the existing Regional Medical Facilities (RMF) land use designation, which has a higher trip generation rate than senior housing and medical office. Based on the former hospital use, the project site was estimated to generate approximately 1,405 average daily trips (ADT). The current project would generate 1,080 ADT, which would be 325 ADT fewer than the former hospital use. Consequently, the proposed senior housing complex and medical office would generate fewer vehicle trips compared to the hospital use used for growth forecasting in the 2016 AQMP, and thereby generate fewer emissions compared to what was assumed in the 2016 AQMP. Therefore, the project would result in fewer trips than what was considered in the 2016 AQMP and would not obstruct or conflict with implementation of the Regional Air Quality Strategy (RAQS). Although the FEIR determined conflicts with the RAQS to be significant, development at this particular site would be consistent with the RAQS for the reasons discussed above. Therefore, the project would not result in any new or more severe impacts compared to the 2021 FEIR analysis.

Cumulative Net Increases of Criteria Pollutants
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development that could violate air quality standards. The 2021 FEIR determined that development of the Housing Sites could generate short-term emissions that would exceed the SCAQMD’s significance thresholds that could cumulatively contribute to the nonattainment designations of the Basin. Although implementation of 2021 FEIR mitigation measure AQ-1 would reduce criteria air pollutant emissions from construction-related activities to the extent feasible, the 2021 FEIR determined that impacts would remain significant and unavoidable.

Project
SCAQMD has established daily emissions thresholds for construction and operation of a project in the Basin. The emissions thresholds were established based on the attainment status of the Basin with regard to air quality standards for specific criteria pollutants. Because the concentration standards were set at a level that protects public health with an adequate margin of safety, these ATTACHMENT 31
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emissions thresholds are regarded as conservative and would overstate an individual project’s contribution to health risks.

Construction and operation air emissions were calculated using California Emissions Estimator Model (CalEEMod). Table 1 presents the total projected construction maximum daily emission levels for each criteria pollutant and compares emissions to the SCAQMD regional significance thresholds.

As shown in Table 1, maximum daily construction emissions for each separate phase of construction of the project would not exceed the daily SCAQMD regional thresholds for all criteria pollutants. In addition to the construction period thresholds of significance, the project is required to comply with regional rules that assist in reducing short-term air pollutant emissions. SCAQMD Rule 403 requires that fugitive dust be controlled with best-available control measures so that the presence of such dust does not remain visible in the atmosphere beyond the property line of the emission source. In addition, SCAQMD Rule 403 requires implementation of dust suppression techniques to prevent fugitive dust from creating a nuisance off-site.

Table 1
Project Construction Emissions in Pounds Per Day
Project Construction
Maximum Pollutant Emissions (lbs/day)
VOC NOx CO SOx PM10 PM2.5
Demolition 0.7 15.2 17.7 <0.1 2.4 0.9
Site Preparation and Grading 0.9 22.7 23.2 0.1 7.8 4.1
Building Construction 1.1 10.2 18.2 0.1 3.4 1.3
Architectural Coating 9.5 1.4 3.2 <0.1 0.6 0.2
Paving 1.3 11.3 17.7 <0.1 0.8 0.7
Maximum (lbs/day) 11.9 22.7 39.1 0.1 7.8 4.4
SCAQMD Thresholds 75.0 100.0 550.0 150 150.0 55.0
Exceeds Thresholds? No No No No No No
SOURCE: Appendix C.

NOTE: Maximum emissions of volatile organic compounds and carbon monoxide occurred during the overlapping building construction, architectural coating, and paving phases.

CO = carbon monoxide
lbs/day = pounds per day
NOX = nitrogen oxides
PM2.5 = particulate matter less than 2.5 microns in size PM10 = particulate matter less than 10 microns in size
SCAQMD = South Coast Air Quality Management District
SOX = sulfur oxides
VOC = Volatile organic compounds
Table 2 presents the total projected operational emissions generated by the project. As shown in Table 2, operational emissions would not exceed any of the SCAQMD’s regional thresholds for criteria pollutants.

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Table 2
Project Operational Emissions in Pounds Per Day
Source
Pollutant Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
Area Sources 6.7 4.0 22.2 <0.1 0.4 0.4
Energy Sources 0.1 0.7 0.3 <0.1 0.1 0.1
Mobile Sources 2.8 2.9 27.2 0.1 7.4 2.0
Total Project Emissions 9.5 7.6 49.7 0.1 7.9 2.6
SCAQMD Thresholds 55.0 55.0 550.0 150.0 150.0 55.0
Exceeds Thresholds? No No No No No No
SOURCE: Appendix C.

NOTE: Values may not add correctly due to rounding.

CO = carbon monoxide
lbs/day = pounds per day
NOx = nitrogen oxides
PM2.5 = particulate matter less than 2.5 microns in size PM10 = particulate matter less than 10 microns in size
SCAQMD = South Coast Air Quality Management District
SOX = sulfur oxides
VOC = Volatile organic compounds
The SCAQMD published its Final Localized Significance Threshold Methodology in July 2008, recommending that all air quality analyses include an assessment of air quality impacts to nearby sensitive receptors.1 This guidance was used to analyze potential localized air quality impacts associated with construction of the project. Localized significance thresholds (LST) are developed based on the size or total area of the emission source, the ambient air quality in the source receptor area, and the distance to the project. Sensitive receptors include residences, schools, hospitals, and similar uses that are sensitive to adverse air quality.

LSTs are based on the ambient concentrations of that pollutant within the project Source Receptor Area (SRA) and the distance to the nearest sensitive receptor. For the project, the appropriate SRA for the LST is the nearby Capistrano Valley area (SRA 21). SCAQMD provides LST screening tables for 25, 50, 100, 200, and 500-meter source-receptor distances. As identified above, the closest sensitive receptors to the project site are the San Clemente Villas by the Sea, which are adjacent to the project site. In cases where receptors may be closer than 82 feet (25 meters), any distances within the 82- foot (25-meter) buffer zone can be used. As such, the minimum distance of 82 feet was used. Based on the anticipated construction equipment, it is assumed that the maximum daily disturbed acreage for the project would be 2.5 acres.2
Project construction and operation emissions were compared to the LST screening tables in SRA 21, based on a 25-meter source-receptor distance and a disturbed acreage of 2.5-acres. Table 3 compares construction emissions to the recommended LST thresholds. As shown in Table 3, construction emissions would not exceed any of the SCAQMD LST thresholds. Table 4 compares 1South Coast Air Quality Management District. 2008b. Final Localized Significance Threshold Methodology. July. 2South Coast Air Quality Management District. n.d. Fact Sheet for Applying CalEEMod to Localized Significance Thresholds. Website: http://www.aqmd.gov/docs/default-source/ceqa/handbook/localized-significancethresholds/caleemod-guidance.pdf (accessed July 2022).

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operational emissions to the LST thresholds. As shown in Table 4, operational emissions would not exceed any of the SCAQMD LST thresholds.

Table 3
Project Localized Construction Emissions in Pounds Per Day Source NOx CO PM10 PM2.5
On-Site Project Emissions 17.1 21.2 6.9 3.8
Localized Significance Threshold 142.0 1,128.0 7.0 4.7
Exceeds Threshold? No No No No
SOURCE: Appendix C.

NOTE: Source Receptor Area 21, based on a 2.5-acre construction disturbance daily area, at a distance of 25 meters from the project boundary.

CO= carbon monoxide PM2.5= particulate matter less than 2.5 microns in size NOx= nitrogen oxides PM10= particulate matter less than 10 microns in size Table 4
Project Localized Operational Emissions in Pounds Per Day Source NOx CO PM10 PM2.5
On-Site Project Emissions 4.1 23.6 <1.0 <1.0
Localized Significance Threshold 142.0 1,128.0 2.2 1.2
Exceeds Threshold? No No No No
SOURCE: Appendix C.

NOTE: Source Receptor Area 21, based on a 2.5-acre construction disturbance daily area, at a distance of 25 meters from the project boundary.

CO= carbon monoxide PM2.5= particulate matter less than 2.5 microns in size NOx= nitrogen oxides PM10= particulate matter less than 10 microns in size Construction and operation of the project would not exceed SCAQMD thresholds related to construction or operational emissions. As shown in Tables 3 and 4, project specific construction and operational emissions would not exceed the LSTs. Therefore, the project would not result in a new or substantially greater cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment, and impacts would be less than significant. No new impact would occur.

Sensitive Receptors
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development that could generate substantial pollutant concentrations. The 2021 FEIR determined that development of the Housing Sites would not result in a carbon monoxide (CO) hot spot or expose sensitive receptors to TACs from construction activities, stationary sources, or mobile sources, and impacts would be less than significant.

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Project
The Air Quality and Greenhouse Gas Analysis prepared for the project evaluated the project’s potential to generate CO hotspots or generate health risks on nearby sensitive receptors (see Appendix C).

CO Hot Spot Analysis
Vehicular trips associated with the project would contribute to congestion at intersections and along roadway segments in the project vicinity. The primary mobile-source pollutant of local concern is CO, a direct function of vehicle idling time, and therefore of traffic flow conditions. CO transport is extremely limited; under normal meteorological conditions, CO disperses rapidly with distance from the source. However, under certain extreme meteorological conditions, CO concentrations near a congested roadway or intersection may reach unhealthful levels, affecting local sensitive receptors (e.g., residents, schoolchildren, the elderly, and hospital patients). Typically, high CO concentrations are associated with roadways or intersections operating at unacceptable levels of service or with extremely high traffic volumes. In areas with high ambient background CO concentrations, modeling is recommended to determine a project’s effect on local CO levels.

An assessment of project-related impacts on localized ambient air quality requires that future ambient air quality levels be projected. Existing CO concentrations in the immediate project vicinity are not available. Ambient CO levels monitored at the Mission Viejo station (the closest stations to the project site) showed a highest recorded 1-hour concentration of 1.7 peak particulate matter (ppm; the State standard is 20 ppm) and a highest 8-hour concentration of 0.9 ppm (the State standard is 9 ppm) during the past 3 years. The highest CO concentrations would normally occur during peak traffic hours; hence, CO impacts calculated under peak traffic conditions represent a worst-case analysis.

The Air Quality and Greenhouse Gas Analysis documented that the project would generate 73 AM peak-hour trips and 92 PM peak-hour trips. The level of service evaluation completed in the Transportation Impact Analysis determined that the addition of the project traffic would not create any significant adverse impacts to nearby intersections (LSA 2022). Given the extremely low level of CO concentrations in the project area, and that the project would not result in any impacts related to LOS, project-related vehicles are not expected to contribute significantly to result in the CO concentrations exceeding the State or federal CO standards. The project would not result in a new or substantially greater CO concentration levels than previously analyzed, and impacts would be less than significant. No new or more severe impacts would occur compared to the 2021 FEIR.

Health Risk on Nearby Sensitive Receptors
Sensitive receptors are defined as people that have an increased sensitivity to air pollution or environmental contaminants. Sensitive receptor locations include schools, parks and playgrounds, day care centers, nursing homes, hospitals, and residential dwelling units. Land uses adjacent to the project site include residential and commercial uses. The nearby sensitive receptors to the project area include the residential area of San Clemente Villas by the Sea, which are located adjacent to the southeastern project boundary.

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Construction of the project may expose surrounding sensitive receptors to airborne particulates and a small quantity of construction equipment pollutants (i.e., usually diesel-fueled vehicles and equipment). However, construction contractors would be required to implement measures to reduce or eliminate emissions by following SCAQMD rules for standard construction practices. As shown in Tables 1 through 4 above, the project would not exceed any of the local or regional emissions thresholds during construction or operation. Therefore, the project would not expose sensitive receptors to new or substantially greater pollutant concentrations than previously analyzed, and impacts would be less than significant. No new impact would occur.

Odors
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development that could generate odors. The 2021 FEIR determined that construction of the Housing Sites would generate emissions, such as diesel exhaust, and volatile organic compounds from architectural coatings and paving activities may generate odors; however, these odors would be temporary, intermittent, and not expected to affect a substantial number of people.

Additionally, noxious odors would be confined to the immediate vicinity of construction equipment.

By the time such emissions reach a receptor (e.g., people in residential units, day care centers, schools, nursing homes, etc.), they would be diluted to well below any level of air quality concern, and impacts would be less than significant. Once operational, the Housing Sites would not be a source of objectionable odors, and impacts would be less than significant.

Project
Odors associated with the project would be the same as that analyzed in the 2021 FEIR. During project construction, some odors may be present due to diesel exhaust. However, these odors would be temporary and limited to the construction period. Operation of the project would not include any activities or operations that would generate objectionable odors. Therefore, the project would not result in new or substantially greater impacts related to odors compared to the 2021 FEIR.

15.4 Biological Resources
Sensitive Species
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development that could impact any sensitive species. The 2021 FEIR determined that some of the Housing Sites would have the potential to impact sensitive species, which would be considered a significant impact. The 2021 FEIR found that implementation of the City’s General Plan Mitigation Monitoring Program for future discretionary development, and implementation of 2021 FEIR Mitigation Framework BIO-1 for ministerial development, would reduce impacts to a level less than significant.

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Project
Consistent with the City’s General Plan Mitigation Monitoring Program (Measure 3-1) which was incorporated by reference into the 2021 FEIR, a Biology Assessment was completed for the project that included a literature review to assist in determining the existence or potential occurrence of sensitive plant and animal species on the project site (Appendix D). Database records for the San Clemente, and Dana Point, California United States Geological Survey 7.5-minute quadrangles were reviewed on August 1, 2022, using the California Department of Fish and Wildlife’s California Natural Diversity Database and the California Native Plant Society Electronic Inventory. On May 9, 2022, LSA Biologists Leo Simone and Heather Monteleone conducted a general evaluation of the biological resources within and immediately adjacent to the project site to evaluate the existing conditions in the designated project area and to identify any existing or potential biological resource issues that would require additional study.

Vegetation within the immediate vicinity of project consists of non-native ornamental, all derived from commercial nursery stock. No native vegetation was observed on, or within, the immediate vicinity of the project site. The lack of native habitat is typical of urban land uses, and there is no high value habitat within or directly adjacent to the project site. The habitat of existing urban development is indicated by the low diversity of faunal species. The nearest native vegetation that would be considered high value habitat is more than three miles from the project site. Therefore, the project would not result in the loss of sensitive habitat or any special-status species. However, ornamental vegetation may provide nesting habitat for migratory birds protected under the federal Migratory Bird Treaty Act (MBTA). Consequently, vegetation removal during the avian nesting period, which typically extends between February and September would have the potential to impact nesting migratory birds protected under the MBTA, which would be considered a significant impact.

Implementation of mitigation measure MM-BIO-1 would reduce impacts related to nesting migratory birds to a level less than significant. Mitigation measure MM-BIO-1 is consistent with the requirements of Measure 3-1 listed in the City’s General Plan Mitigation Monitoring Program, which was incorporated by reference into the 2021 FEIR. Therefore, the project would not have a new or substantially greater adverse effect on any sensitive species than previously analyzed, and impacts would be less than significant. The 2021 FEIR Mitigation Framework BIO-1 would not apply to this project, as it is not being processed ministerially. No new impact would occur.

Mitigation Measures
MM-BIO-1: Nesting Migratory Birds
No direct impacts shall occur to any nesting birds, their eggs, chicks, or nests during the breeding season. If vegetation removal activities must occur during the bird breeding season of February 1 to September 15, then a pre-construction survey would be necessary to confirm the presence or absence of breeding birds within the temporary parking lot. If nests or breeding activities are located on-site, then an appropriate buffer area around the nesting site shall be maintained until the young have fledged. The width of the buffer would be determined by a qualified biologist and biological monitoring would be required during construction. If no nesting birds are detected during the preconstruction survey, no avoidance measures would be required.

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Sensitive Vegetation Communities
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development that could impact riparian habitat or other sensitive natural communities. The 2021 FEIR determined that some sites proposed for development under the Housing Element Update would have the potential to impact riparian habitat or other sensitive natural communities, which would be considered a significant impact. The 2021 FEIR found that implementation of the City’s General Plan Mitigation Monitoring Program for future discretionary development, and implementation of PEIR Mitigation Framework BIO-1 for ministerial development, would reduce impacts to a level less than significant.

Project
The project site is fully developed and does not possess any natural habitat, including riparian habitat.

Therefore, the project would not have a substantial adverse effect on any riparian habitat or other sensitive natural community than previously analyzed. Mitigation measure BIO-1 would not apply to this project as it is not being processed ministerially. No new impact would occur.

Wetlands
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development that could impact wetlands. The 2021 FEIR determined that some sites proposed for development under the Housing Element Update would have the potential to impact wetlands, which would be considered a significant impact. The 2021 FEIR found that implementation of the City’s General Plan Mitigation Monitoring Program for future discretionary development, and implementation of 2021 FEIR Mitigation Framework BIO-2 for ministerial development, would reduce impacts to a level less than significant.

Project
The project site is fully developed and does not possess any federally protected wetlands, and no wetlands are located within proximity to the project site. Therefore, the project would not have a new or substantially greater adverse effect on state or federally protected wetlands than previously analyzed. Mitigation measure BIO-2 would not apply to this project as it is not being processed ministerially. No new impact would occur.

Wildlife Corridors
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development that could impact wildlife corridors or wildlife nursery sites. The 2021 FEIR determined that some sites proposed for development under the Housing Element Update would have the potential to impact wildlife corridors or wildlife nursery sites, which would be ATTACHMENT 31
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considered a significant impact. The 2021 FEIR found that implementation of the City’s General Plan Mitigation Monitoring Program for future discretionary development, and implementation of 2021 FEIR Mitigation Framework BIO-1 for ministerial development, would reduce impacts to a level less than significant.

Project
As described above, no native vegetation was observed on, or within, the immediate vicinity of the project site. The lack of native habitat is typical of urban land uses, and there is no high value habitat within or directly adjacent to the project site. The Biological Assessment determined there is no evidence that wildlife movement occurs within the project site, and the faunal carrying capacity is expected to be very low due to the project location and proximity to surrounding commercial development. As described above, vegetation removal during the avian nesting period, which typically extends between February and September would have the potential to impact nesting migratory birds protected under the MBTA, which would be considered a significant impact.

Implementation of mitigation measure MM-BIO-1 described above would reduce impacts related to nesting migratory birds to a level less than significant. Mitigation measure MM-BIO-1 would be consistent with the requirements of Measure 3-1 listed in the City’s General Plan Mitigation Monitoring Program, which is consistent with the requirements of the 2021 FEIR. Therefore, the project would not have a new or substantially greater adverse effect on wildlife corridors than previously analyzed. The 2021 FEIR Mitigation Framework BIO-1 would not apply to this project as it is not being processed ministerially. No new impact would occur.

Habitat Conservation Planning
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development that could conflict with the provisions of an adopted Habitat Conservation Plan (HCP), Natural Community Conservation Plan. The City is one of the signatories of the Southern Orange County Subregional HCP, but is not a participant receiving regulatory coverage for impacts to covered species. The 2021 FEIR determined that none of the Housing Sites are located within the HCP Reserve area which represents the areas needed for conservation to achieve the goals of the HCP. Therefore, the 2021 FEIR found that development at the Housing Sites would not conflict with the Southern Orange County Subregional HCP, and impacts would be less than significant.

Project
The project site is not located within HCP Reserve area which represents the areas needed for conservation to achieve the goals of the HCP. Therefore, the project would not result in a new or substantially greater conflict with the Southern Orange County Subregional HCP than previously analyzed. No new impact would occur.

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Policies and Ordinances Protecting Biological Resources 2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development that could conflict with any local policies or ordinances protecting biological resources. The 2021 FEIR determined that future discretionary development on Housing Sites would undergo an environmental review and would be subject to site specific mitigation measures to ensure impacts to biological resources are reduced to less than significant. Additionally, for future development that may proceed with a ministerial approval, implementation of 2021 FEIR Mitigation Framework BIO-1 and BIO-2 would ensure that the City applies applicable objective development standards to ensure consistency with City policies for the protection of biological resources. Therefore, the 2021 FEIR found that impacts related to policy and ordinance compliance To be
Project
The project would be required to be consistent with all relevant SCMC regulations and General Plan policies. An Arborist Report documented that the project site currently possesses 175 ornamental landscape trees, 77 of which are in good condition, 69 are in fair condition, and 29 are in poor condition. All the tree species found on-site are common non-native ornamental landscape trees that are readily available at commercial nurseries. Most of the trees are growing in less-than-optimal conditions, and none would be required to be preserved on-site. As described in above, impacts to all other biological resources would be less than significant or mitigated to a level less than significant. Therefore, the project would not conflict with any local policies or ordinances protecting biological resources, such as tree preservation policy or ordinance, to any greater degree than previously analyzed and impacts would be less than significant. The 2021 FEIR Mitigation Framework BIO-1 and BIO-2 would not apply to this project as it is not being processed ministerially. No new impact would occur.

15.5 Cultural Resources
Historic Resources
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development that could impact historic resources. The 2021 FEIR determined that adherence to applicable requirements of the City’s Design Guidelines, Henry Lenny Architectural Design Guidelines, Architectural Overlay District and the SCMC would ensure impacts related to historic resources for both ministerial and discretionary projects developed under the Housing Element Update would be less than significant.

Project
Consistent with the City’s General Plan Mitigation Monitoring Program (Measure 4-1) which was incorporated by reference into the 2021 FEIR, a Cultural Resources Records Search Results was completed for the project (Appendix E). This report included completion of a records search for the ATTACHMENT 31
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project at the South Central Coastal Information Center (SCCIC) that identified two thematic historic districts, the Spanish Colonial Revival Thematic Historic District and the Ole Hanson/Spanish Village by the Sea Thematic Historic District (see Appendix E). However, thematic historic districts consist of a group of resources linked together by a specific set of characteristics rather than cluster of resources located within a specific geographic region. Consequently, these thematic historic districts are noncontiguous and consist of various resources scattered throughout the City. There are no designated historic buildings associated with these thematic historic districts, or any other designated historic resources, located within or near the project site. Furthermore, the vacant hospital facility and supporting structures onsite that would be demolished do not qualify as historic resources.

Therefore, the project would not cause a new or substantially greater adverse change in the significance of an historical resource pursuant to §15064.5 than previously analyzed. No new impact would occur.

Archaeological Resources
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development that could impact archaeological resources. The 2021 FEIR determined that some sites proposed for development under the Housing Element Update would have the potential to encounter subsurface archaeological deposits, which could be considered a significant impact. The 2021 FEIR found that implementation of the City’s General Plan Mitigation Monitoring Program for future discretionary development, and implementation of 2021 FEIR Mitigation Framework CUL-1 for ministerial development, would reduce impacts to a level less than significant.

Project
The Cultural Resources Records Search Results completed for the project at the SCCIC determined that 11 previous studies had been completed within one mile of the project site, two of which included portions of the project site. No previously identified archaeological resources were identified within the project site. However, the record search identified an expansive (15,600-square-meter) prehistoric artifact scatter was identified approximately 0.18-mile south of the project site. Furthermore, the prehistoric artifact scatter is located approximately 0.65 mile from the shoreline within the coastal corridor of a dense prehistoric habitation. Therefore, the presence of the prehistoric artifact scatter may be an indication that the project site may have moderate sensitivity for the presence of archaeological resources, which would be considered a significant impact. Implementation of the MM-CUL-1 would reduce impacts related to archaeological resources to a level less than significant.

Mitigation measure MM-CUL-1 is consistent with the requirements of Measure 4-1 listed in the City’s General Plan Mitigation Monitoring Program, which was incorporated by reference into the 2021 FEIR. Therefore, the project would not cause a new or substantially greater substantial adverse change in the significance of an archeological resource pursuant to §15064.5 than previously analyzed.

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Mitigation Measures
MM-CUL-1: Archaeological Monitoring
A qualified archaeologist shall be retained for the project to conduct the following monitoring activities during construction:
a. An archaeologist shall be on call during grading and other significant ground-disturbing activities.
b. Should any cultural/scientific resources be discovered, no further grading shall occur in the area of the discovery until the Community Development Director concurs in writing that adequate provisions are in place to protect these resources. c. Unanticipated discoveries shall be evaluated for significance by an Orange County Certified Professional Archaeologist. If significance criteria are met, then the project shall be required to perform data recovery, professional identification, radiocarbon dates as applicable, and other special studies; submit materials to the California State University Fullerton or local archival facility, where available; and provide a comprehensive final report including appropriate records for the California Department of Parks and Recreation (Building, Structure, and Object Record; Archaeological Site Record; or District Record, as applicable).

Human Remains
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development that could impact human remains. The 2021 FEIR determined that in the unlikely event that human remains are discovered during future development at Housing Sites, adherence to California Health and Safety Code Section 7050.5 and Public Resources Code Section 5097.98, the California Native American Graves Protection and Repatriation Act (2001), the federal Native American Graves Protection and Repatriation Act (1990), as well as AB 52 early consultation requirements, would ensure that impacts would be less than significant.

Project
In the event human remains are encountered, State Health and Safety Code Section 7050.5 requires that no further disturbance shall occur until the County Coroner has made a determination of origin and disposition pursuant to Public Resources Code Section 5097.98. The County Coroner must be notified of the find immediately. If the remains are determined to be Native American, the County Coroner will notify the Native American Heritage Commission (NAHC), which will determine and notify a Most Likely Descendant (MLD). With the permission of the landowner or his/her authorized representative, the MLD may inspect the site of the discovery. The MLD shall complete the inspection within 48 hours of notification by the NAHC. The MLD will have the opportunity to offer recommendations for the disposition of the remains. Adherence to these requirements is consistent with the 2021 FEIR analysis and would ensure no new or more substantial impacts on human remains would occur than previously analyzed in the 2021 FEIR.

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Tribal Cultural Resources
2021 FEIR
As part of the 2021 FEIR, the City consulted with Native American Tribes. Although the City did not receive any requests for consultation or comments, the potential to uncover buried tribal cultural resources exists where development would disturb native soils. Therefore, the FEIR found that the potential for direct and/or indirect impacts to existing tribal cultural resources would be potentially significant.

Project
The City received one request for consultation on the subject Senior Housing and Medical Office project. The tribe has requested Native American monitoring during all ground disturbing activities.

However, implementation of MM-CUL-1 described above would ensure that a Native American monitor would be present during all ground disturbing activities. No changes to the project evaluated in the 2021 FEIR are proposed that would affect conclusions related to tribal cultural resources.

15.6 Energy
Wasteful, Inefficient, or Unnecessary Consumption of Energy 2021 FEIR
The 2021 FEIR determined that the Safety Element is a policy document that would not result in any physical development that would consume energy. The 2021 FEIR determined that there are no conditions in the project areas of the Housing Sites that would require non-standard equipment or construction practices that would increase fuel-energy consumption above typical rates. Consistent with state requirements, all construction equipment would meet California Air Resources Board (CARB) Tier 3 In-Use Off-Road Diesel Engine Standards. Development of the Housing Sites would not result in any unusual characteristics that would result in excessive long-term operational building energy demand. Therefore, the 2021 FEIR found that the Housing and Safety Elements Update would not result in potentially significant environmental impacts due to wasteful, inefficient, or unnecessary consumption of energy resources, and impacts would be less than significant.

Project
Construction-Related Energy Use
During construction, energy use would occur in two general categories: fuel use from vehicles used by workers commuting to and from the construction site, and fuel use by vehicles and other equipment to conduct construction activities. The construction equipment and worker trips required for the project were determined as a part of the Air Quality and Greenhouse Gas (GHG) Analysis prepared for the project (see Appendix C). Heavy-duty construction equipment is usually diesel powered.

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Project construction activities would temporarily contribute additional vehicle trips on the local circulation system, and would generate up to 233 daily worker trips during an approximately 20- month period. Demolition hauling would generate up to 285 vehicle trips, soil hauling would generate up to 1,347 vehicle trips, and deliveries of construction materials would periodically generate up to 48 additional vehicle trips. Fuel consumption associated with on-road worker trips and delivery trips were calculated using the total trips, trip lengths calculated in the Air Quality and GHG Analysis, and EMFAC2021 fuel consumption rates (Appendix F). Fuel consumption associated with on-site construction equipment was calculated using the equipment quantities and phase lengths calculated in the Air Quality and GHG Analysis and CARB OFF-ROAD model (see Appendix F). Off-site and on-site fuel consumption that would occur over the entire construction period is summarized in Tables 5 and 6, respectively.

Table 5
Off-site Construction Vehicle Fuel Consumption
Trip Type
Total Vehicle Miles
Traveled
Total Fuel Consumption (gallons)
Electricity
Consumption
Gasoline Diesel kWh
Workers 1,380,845 49,483 1,231 196,673
Hauling 32,640 -- 194,428 --
Deliveries 331 -- 1,973 --
Total 1,413,816 49,483 197,632 196,673
Table 6
On-site Construction Equipment Fuel Consumption
Phase
Phase
Length
(Days) Equipment Amount
Total Usage
Hours
Total Diesel Fuel
Consumption
(gallons)
Demolition 20
Concrete Industrial Saws 1 160 221
Excavator 1 160 501
Rubber Tired Dozers 2 320 1,641
Site Preparation
and Grading 35
Rubber Tired Dozers 2 560 2,871
Tractors/Loaders/Backhoes 2 560 1,048
Excavator 1 280 877
Grader 1 280 1,114
Building
Construction 360
Crane 1 2,520 8,680
Forklifts 3 8,640 8,076
Tractors/Loaders/Backhoes 3 7,560 14,147
Paving 10
Paver 2 160 446
Paving Equipment 2 160 389
Rollers 2 160 255
Architectural
Coatings 180 Air Compressor 1 1,080 1,103
Total 39,500
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Consistent with federal requirements, all equipment was assumed to meet CARB Tier 3 InUse OffRoad Diesel Engine Standards. There are no known conditions in the project area that would require nonstandard equipment or construction practices that would increase fuel-energy consumption above typical rates. Therefore, the project would not result in the use of excessive amounts of fuel or other forms of energy during construction greater than previously analyzed, and impacts would be less than significant during construction. No new impacts would occur.

Operation-Related Energy Use
During operation, energy use would be associated with transportation-related fuel use (gasoline, diesel fuel, and electric vehicles), and building-related energy use (electricity and natural gas).

Transportation-Related Energy Use
Buildout of the project and occupation by residents would result in transportation energy use. Trips by individuals traveling to and from the project site would result from use of passenger vehicles or public transit. Passenger vehicles would be mostly powered by gasoline, with some fueled by diesel or electricity. Public transit would be powered by diesel or natural gas, and could potentially be fueled by electricity. The project is anticipated to generate 1,080 daily trips. Vehicle emission factors and fleet mix were based on regional averages from the CARB Emission Factors 2021 model. Based on CalEEMod Air Quality and GHG Analysis, the project would generate 3,468,235 annual vehicle miles traveled (VMT) which equals approximately 9,502 daily VMT. Total gasoline and diesel fuel consumption was calculated using EMFAC2021 fuel consumption rates and fleet data for light duty autos, light duty trucks, light heavy duty trucks, and motorcycles. The results are summarized in Table 7.

Table 7
Vehicle Fuel/Electricity Consumption
Gasoline Diesel Electric Plug-In Hybrid Total
VMT 8,974 187 403 196 9,760
Fuel Consumed (gallons) 256,891 4,208 0 11,860 272,958
Electricity Consumer (kWh) 0 0 1,042 648 1,690
kWh = kilowatt hour.

The Orange County Transit Authority Bus Route 1 runs along Camino de los Mares immediately adjacent to the project site. This route operates between San Clemente and Long Beach and connects to the San Clemente Metrolink Station. The proximity of regional shopping and local bus routes would help reduce VMT generated by the project. In addition, project fuel consumption would decline over time beyond initial operational year of the project as a result of continued implementation of increased federal and state vehicle efficiency standards. There is no component of the project that would result in unusually high vehicle fuel use during operation. As such, operation of the project would not create a land use pattern that would result in new or substantially greater wasteful, inefficient, or unnecessary use of energy than previously analyzed, and impacts would be less than significant. No new impact would occur.

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Non-Transportation-Related Energy Use
Non-transportation energy use would be associated with electricity and natural gas. The Renewables Portfolio Standard (RPS) promotes diversification of the state’s electricity supply and decreased reliance on fossil fuel energy sources. Renewable energy includes (but is not limited to) wind, solar, geothermal, small hydroelectric, biomass, anaerobic digestion, and landfill gas. Originally adopted in 2002 with a goal to achieve a 20 percent renewable energy mix by 2020 (referred to as the “Initial RPS”), the goal has been accelerated and increased by Executive Orders (EOs) S-14-08 and S-21-09 to a goal of 33 percent by 2020. In April 2011, SB 2 (1X) codified California’s 33 percent RPS goal. SB 350 (2015) increased California’s renewable energy mix goal to 50 percent by year 2030. SB 100 (2018) further increased the standard set by SB 350 establishing the RPS goal of 44 percent by the end of 2024, 52 percent by the end of 2027, and 60 percent by 2030. Once operational, the project would be served by San Diego Gas & Electric (SDG&E). As of 2020, SDG&E had a 39 percent procurement of renewable energy (CPUC 2021).

The California Code of Regulations, Title 24, is referred to as the California Building Code. It consists of a compilation of several distinct standards and codes related to building construction, including plumbing, electrical, interior acoustics, energy efficiency, handicap accessibility, and so on. Of particular relevance to GHG reductions are the California Building Code’s energy efficiency and green building standards as outlined below.

Title 24, Part 11 of the California Code of Regulations is CALGreen. Beginning in 2011, CALGreen instituted mandatory minimum environmental performance standards for all ground-up new construction of commercial and low-rise residential buildings, state-owned buildings, schools, and hospitals. It also includes voluntary tiers (I and II) with stricter environmental performance standards for these same categories of residential and non-residential buildings. Local jurisdictions must enforce the minimum mandatory requirements and may adopt CALGreen with amendments for stricter requirements.

The project would, at a minimum, be required to comply with the mandatory measures included in the current 2019 Energy Code (California Code of Regulations, Title 24, Part 6) and the 2019 CALGreen standards. The mandatory standards require:
• Solar on single- and multi-family residential buildings • Outdoor water use requirements as outlined in local water efficient landscaping ordinances or current Model Water Efficient Landscape Ordinance standards, whichever is more stringent;
• Requirements for water conserving plumbing fixtures and fittings; • 65 percent construction/demolition waste diverted from landfills; • Inspections of energy systems to ensure optimal working efficiency; • Low-pollutant emitting exterior and interior finish materials such as paints, carpets, vinyl flooring, and particle boards;
• Dedicated circuitry to facilitate installation of electric vehicle charging stations in newly constructed attached garages for single-family and duplex dwellings; and ATTACHMENT 31
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• Installation of electric vehicle charging stations for at least three percent of the parking spaces for all new multi-family developments with 17 or more units.

Similar to the compliance reporting procedure for demonstrating Energy Code compliance in new buildings and major renovations, compliance with the CALGreen operational water reduction requirements must be demonstrated through completion of water use reporting forms for new lowrise residential and non-residential buildings. The water use compliance form must demonstrate a 20 percent reduction in indoor water use by either showing a 20 percent reduction in the overall baseline water use as identified in CALGreen or a reduced perplumbing-fixture water use rate.

Electricity and natural gas service to the project site is provided by SDG&E. Once operational, the proposed residential units would use electricity and natural gas to run various appliances and equipment, including space and water heaters, air conditioners, ventilation equipment, lights, and numerous other devices. Generally, electricity use is higher in the warmer months due to increased air conditioning needs, and natural gas use is highest when the weather is colder as a result of high heating demand. As a part of the Air Quality and GHG Analysis prepared for the project (see Appendix C), CalEEMod was used to estimate the total operational electricity and natural gas consumption associated with the project. Table 8 summarizes the anticipated operational energy and natural gas use.

Table 8
Operational Electricity and Natural Gas Use
Total Use
Electricity 1,103,313 kWh/Year
Natural Gas 2,855,275 kBTU/Year
kwH = kilowatt hour; kBTU = 1,000 British thermal units Buildout of the project would result in an increase of operational electricity and natural gas usage when compared to the existing condition. The project would be required to meet the mandatory energy requirements of 2019 CALGreen and the California Energy Code (Title 24, Part 6 of the California Code of Regulations) and would benefit from the efficiencies associated with these regulations as they relate to building heating, ventilating, and air conditioning mechanical systems, water-heating systems, and lighting. The project would include solar panels. Further, electricity would be provided to the project by SDG&E, which currently has an energy mix that includes 39 percent renewables and is on track to achieve 60 percent by 2030 as required by RPS. Therefore, there are no project features that would result in new or a substantially greater use of excessive amounts of energy compared to what was evaluated in the FEIR. The project would not create unnecessary energy waste, or conflict with any adopted plan for renewable energy efficiency. New or more severe energy impacts would not occur. No new impact would occur.

Conflict with State or Local Energy Plans
2021 FEIR
The 2021 FEIR determined that the Safety Element is a policy document that would not result in any physical development that would consume energy. Future development associated with implementation of residential development at the Housing Sites would be subject to compliance ATTACHMENT 31
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with the California Building Code (Title 24) which aims to reduce excessive and inefficient energy use.

By locating housing at existing retail sites and developing retail uses along with multi-family residential uses on the potential Housing Sites, non-commute vehicle trips would be reduced. Future discretionary development would be reviewed for conformance with Mobility and Complete Streets Element policies that are intended to reduce VMT throughout the City. Furthermore, future development would, at a minimum, be required to comply with the mandatory measures included in the current 2019 Energy Code (California Code of Regulations, Title 24, Part 6) and the 2019 CALGreen standards. Therefore, the 2021 FEIR found that the Housing and Safety Elements Update would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency, and impacts would be less than significant.

Project
The applicable State plans that address renewable energy and energy efficiency are CALGreen, the California Energy Code, and RPS. As discussed above, the project would be required to meet the mandatory energy requirements of 2019 CALGreen and the 2019 California Energy Code. Therefore, the project would not result in new or substantially greater impacts related to conflicts with energy plans compared to the FEIR. The project would comply with all aspects of CALGreen and the California Energy Code. No new or more severe impacts would result compared to the FEIR.

15.7 Geology and Soils
Seismic Hazards and Unstable Geology
2021 FEIR
The 2021 FEIR determined that the Safety Element is a policy document that would not result in any physical development that that could be affected by seismic ground shaking, ground rupture, unstable soils, liquefaction, landslide, or collapse. The 2021 FEIR determined that adherence to regulatory requirements including the California Building Code (CBC) and SCMC requirements for soils engineering/ engineering geology reports and erosion control plans would ensure that development of the Housing Sites would not cause substantial adverse effects associated with seismic hazards and unstable geology, and impacts would be less than significant.

Project
No project changes have been identified that would affect the conclusion of the FEIR related to seismic hazards and unstable geology. As described in the Geologic and Seismic Hazards Review completed for the project (Appendix G), the project would be designed in accordance with all applicable current codes and standards utilizing the appropriate seismic design parameters to reduce seismic risk as defined by California Geological Survey (CGS) Chapter 2 of Special Publication 117a (CGS 2008), and the 2019 edition of the CBC, or the most current edition of the code at the time of project construction. The project would be required to comply with the SCMC.

The Geologic and Seismic Hazards Review completed for the project determined that the project site is not located within a liquefaction hazard zone based on the Seismic Hazard Zone Map for the Orange Quadrangle, nor is the site underlain by shallow groundwater or near-surface deposits of ATTACHMENT 31
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non-cohesive soils prone to liquefaction. Therefore, the project would not cause new or substantially greater adverse effects involving liquefaction than previously analyzed.

The site is flat and mostly would not be susceptible to landslide except the southwestern portion of the project site may be susceptible to landslide. The project would implement the use of shear keys, flattening of the existing slope gradients, or assignments of structural setbacks behind top of slope areas in order to avoid landslides. Through these measures the project would ensure protection against landslides. The project would not cause new or substantially greater adverse effects involving strong seismic ground shaking, unstable geology, landslides, liquefaction or collapse than previously analyzed, and impacts would be less than significant. No new impact would occur.

Soil Erosion
2021 FEIR
The 2021 FEIR determined that the Safety Element is a policy document that would not result in any physical development that could cause soil erosion. The 2021 FEIR determined that adherence to regulatory requirements including preparation of a storm water pollution prevention plan (SWPPP) and SCMC Chapter 15.36 (Grading Ordinance) would ensure that both future ministerial and discretionary development within the Housing Sites would not result in substantial soil erosion or the loss of topsoil, and impacts would be less than significant.

Project
The Preliminary Water Quality Management Plan (Appendix H) completed for the project identifies potential best management practices (BMPs) to be included as design features to protect against soil erosion, such as temporary catchment basins and/or sandbagging which would control runoff and contain sediment transport within the project site during construction. Following completion of the project, the project site would be improved with structures, hardscape, landscaping and appropriate drainage infrastructure. Therefore, the project would not result in new or substantially greater soil erosion or loss of topsoil than previously analyzed, and impacts would be less than significant. No new impact would occur.

Expansive Soils
2021 FEIR
The 2021 FEIR determined that the Safety Element is a policy document that would not result in any physical development that would be susceptible to expansive soils. The 2021 FEIR determined that adherence to CBC requirements as adopted by the City (SCMC Section 15.36.180) would ensure that future ministerial and discretionary development would not create substantial direct or indirect risks associated with expansive soils, and impacts would be less than significant.

Project
The Geologic and Seismic Hazards Review completed for the project included expansion index testing of shallow soil samples that revealed a low to medium expansion potential. The report states that import material for replacement fill, if needed, should consist of soils with low expansion ATTACHMENT 31
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potential, and implementation of standard engineering and earthwork construction practices, such as proper foundation design and controlled moisture conditioning or mixing with non-expansive soils, would reduce the risks associated with expansive soils (see Appendix G). The project would not create new or substantially greater direct or indirect risks to life or property associated with expansive soil than previously analyzed, and impacts would be less than significant. No new impact would occur.

Septic Systems
2021 FEIR
The 2021 FEIR determined that the Safety Element is a policy document that would not result in any physical development that would require wastewater services. The 2021 FEIR determined that none of the Housing Sites would utilize septic tanks or alternative wastewater disposal systems, and no impact would occur.

Project
The project would connect to existing wastewater services lines that traverse the project site and would not require the use of septic tanks or alternative wastewater disposal systems. No new or substantially greater impact would occur.

Paleontological Resources and Unique Geology
2021 FEIR
The 2021 FEIR determined that the Safety Element is a policy document that would not result in any physical development that could impact paleontological resources or unique geology. The 2021 FEIR found that implementation of the City’s General Plan Mitigation Monitoring Program for future discretionary development, and implementation of 2021 FEIR Mitigation Framework PAL-1 for ministerial development, would, reduce impacts related to paleontological resources to a level less than significant.

Project
Consistent with the City’s General Plan Mitigation Monitoring Program (Measure 4-2) which was incorporated by reference into the 2021 FEIR, a Paleontological Analysis was completed for the project (Appendix I). The project specific Paleontological Analysis determined that soils beneath the site consist of artificial fill and Capistrano Formation (see Appendix I). Artificial fill consists of sediments that have been removed from one location and transported to another location by human activity, rather than by natural means, and does not possess any paleontological sensitivity. The marine Capistrano Formation was deposited during the early Pliocene to late Miocene. Two facies that are distinguished by their depositional environments and corresponding compositions are located within the vicinity of the project. The turbidite facies formed in marine channel and sub-sea fan environments, and is composed of coarse-grained, poorly bedded, weakly cemented sandstone and conglomeratic sandstone. In contrast, the siltstone facies accumulated in deep shelf and slope environments and consists of white to pale gray, massive to poorly bedded, friable siltstone, mudstone, and diatomaceous shale. Only the siltstone facies are mapped within the project site. The ATTACHMENT 31
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Capistrano Formation has produced abundant and diverse scientifically significant fossils, many of which come from the siltstone facies. Therefore, the Capistrano Foundation is considered to have high paleontological sensitivity. Although the fossil locality search did not identify any fossil localities within the boundaries of the project site, the search noted records of several fossil localities nearby from the Capistrano Formation. Therefore, project excavation within the Capistrano Foundation would have the potential to impact paleontological resources, which would be considered a significant impact, consistent with the FEIR. Implementation of mitigation measures MM-PAL-1 through MM-PAL-3 would reduce impacts related to paleontological resources to a level less than significant. Mitigation measures MM-PAL-1 through MM-PAL-3 are consistent with the requirements of Measure 4-2 listed in the City’s General Plan Mitigation Monitoring Program, which was incorporated by reference into the 2021 FEIR. Therefore, the project would not cause a new or substantially greater adverse change in the significance of a unique paleontological resource or site or unique geologic feature than previously analyzed. No new or substantially more severe impact would occur.

Mitigation Measures
MM-PAL-1: Paleontological Resources Impact Mitigation Program A paleontologist who meets the qualifications established by the Society of Vertebrate Paleontology (SVP) shall be retained to develop a Paleontological Resources Impact Mitigation Program (PRIMP) for this project. The PRIMP shall be consistent with the standards of the SVP and include the methods that will be used to protect paleontological resources that may exist within the project site, as well as procedures for monitoring, fossil preparation and identification, curation into a repository, and preparation of a report at the conclusion of grading.

MM-PAL-2: Paleontological Monitoring
Excavation and grading activities in deposits with high paleontological sensitivity (i.e., the Capistrano Formation) shall be monitored by a qualified paleontological monitor following a PRIMP. No monitoring is required for excavations in deposits with no paleontological sensitivity (i.e., Artificial Fill). If paleontological resources are encountered during the course of ground disturbance, the paleontological monitor shall have the authority to temporarily redirect construction away from the area of the find. In the event that paleontological resources are encountered when a paleontological monitor is not present, work in the immediate area of the find shall be redirected, and the paleontologist or paleontological monitor shall be contacted to assess the find for scientific significance. If determined to be scientifically significant, the fossil shall be collected from the field.

MM-PAL-3: Paleontological Resources Report
Collected resources shall be prepared to the point of identification, identified to the lowest taxonomic level possible, cataloged, and curated into the permanent collections of a museum repository. At the conclusion of the monitoring program, a report of findings shall be prepared to document the results of the monitoring program.

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15.8 Greenhouse Gas Emissions
GHG Emissions
2021 FEIR
The 2021 FEIR determined that the Safety Element is a policy document that does not have the potential to add growth or population to the City, and therefore would not generate GHG emissions.

The 2021 FEIR determined that adoption of the Housing Element sites inventory would result in an increase in GHG emissions that exceed the 2017 Scoping Plan efficiency metrics and would result in an increase in VMT, resulting in a significant impact. Although implementation of Mitigation Framework GHG-1 would support GHG reductions for future ministerial development, and despite the City’s continued implementation of the City’s Climate Action Plan (CAP) and Sustainability Action Plan (SAP), the 2021 FEIR found that impacts would remain significant and unavoidable.

Project
The Air Quality and Greenhouse Gas Analysis prepared for the project evaluated the potential for the project to emit GHG (see Appendix C). GHG emissions associated with the project would occur over the short-term from construction activities, consisting primarily of emissions from equipment exhaust. There would also be long-term GHG emissions associated with project-related vehicular trips. CalEEMod results were used to quantify GHG emissions generated by the project. To provide guidance to local lead agencies on determining significance for GHG emissions in their CEQA documents, SCAQMD has provided screening thresholds. Though the SCAQMD has not published a quantified threshold beyond 2020, the Air Quality and Greenhouse Gas Analysis utilized a threshold of 2,400 metric tons of carbon dioxide equivalent (CO2e) per year or 3.8 metric tons of CO2e per year per service population, which was calculated for the buildout year of 2025 based on the GHG reduction goals of Senate Bill (SB) 32 and Executive Order B-30-15.

Demolition and construction activities associated with the project would produce combustion emissions from various sources. During construction, GHGs would be emitted through the operation of construction equipment and from worker and builder supply vendor vehicles, each of which typically use fossil-based fuels to operate. The combustion of fossil-based fuels creates GHGs such as CO2, CH4, and N2O. Furthermore, CH4 is emitted during the fueling of heavy equipment. Exhaust emissions from on-site construction activities would vary daily as construction activity levels change.

Lead agencies are required to quantify and disclose GHG emissions that would occur during construction, and the SCAQMD requires the construction GHG emissions to be amortized over the life of the project, defined as 30 years, added to the operational emissions, and compared to the applicable interim GHG significance threshold tier. Using CalEEMod, it was estimated that the project would generate 950.8 metric tons of CO2e during construction of the project. When annualized over the 30-year life of the project, annual emissions would be 31.7 metric tons CO2e.

Long-term operational GHG emissions are typically associated with mobile, area, and stationary sources as well as indirect emissions from sources associated with energy consumption, waste sources, and water sources. Following guidance from the SCAQMD, GHG emissions were estimated using CalEEMod. Table 9 presents the calculated GHG emissions for the project. As shown in Table 9, ATTACHMENT 31
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the project would generate 1,876.1 metric tons of CO2e per year, which would be below the scaled numeric threshold of 2,400 metric tons of CO2e per year. Therefore, the project’s contribution of GHG emissions would be below the SCAQMD threshold. Therefore, the project would not generate new or substantially greater GHG emissions than previously analyzed in the 2021 FEIR.

Table 9
Greenhouse Gas Emissions (metric tons per year)
Emissions Source
Operational Emissions
CO2 CH4 N2O CO2e
Percentage
of Total
Area Sources 58.2 <0.1 <0.1 58.7 3
Energy Sources 422.6 <0.1 <0.1 424.5 23
Mobile Sources 1,083.6 <0.1 <0.1 1,098.6 60
Waste Sources 62.8 3.7 0.0 155.5 8
Water Sources 88.8 0.6 <0.1 107.1 6
Total Operational Emissions 1,844.4 100
Amortized Construction Emissions 31.7 -
Total Annual Emissions 1,876.1 -
SCAQMD Threshold 2,400 -
Exceeds Threshold? No -
SOURCE: Appendix C.

CH4 = methane N2O = nitrous oxide
CO2 = carbon dioxide SCAQMD = South Coast Air Quality Management District CO2e = carbon dioxide equivalent
Policies, Plans and Regulations to Reduce GHG Emissions 2021 FEIR
The 2021 FEIR determined that the Safety Element is a policy document that does not have the potential to add growth or population to the City, and therefore would not generate GHG emissions.

The 2021 FEIR determined that development of the Housing Sites would increase GHG emissions and VMT in the City. Although implementation of mitigation measure GHG-1 would support GHG reductions for future ministerial development, and despite the City’s continued implementation of the CAP and SAP, the 2021 FEIR found that impacts would remain significant and unavoidable.

Project
The City adopted a CAP in January 2014. The project would be consistent with the alternative transportation goal of the CAP by expanding pedestrian networks. The project would implement internal walkways linking the residential units with the amenity areas and surface parking areas, as well as providing connection to the Camino de los Mares parkway for access to the nearby transportation (bus stops), commercial centers, and the medical office building. This expansion of network would encourage people, including residents of the project site, to walk instead of drive.

Further, the senior housing in proximity to the Medical Offices would support reductions in VMT and associated GHG emissions. Additionally, the project would be consistent with the CAP land use goal, ATTACHMENT 31
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increasing the planting of new trees by incorporating landscaped courtyards in the residential community.

The project would also be consistent with the CAP goal of increasing energy efficiency in new buildings by complying with the latest California Building Code (Title 24), including the latest CALGreen standards for energy efficiency. The project would replace older buildings that were built with less efficient standard codes, improving the overall efficiency of the project site. Construction of the project would include a diversion of construction waste from landfills to recycling consistent with current local and State standards and CAP goals to increase diversion and reduction of waste.

Therefore, the project would be consistent with applicable CAP goals.

The project was analyzed for consistency with the goals of Assembly Bill (AB) 32 and the AB 32 Scoping Plan, as well as Executive Order B-30-15, SB 32, and AB 197. The AB 32 Scoping Plan contains GHG reduction measures that work towards reducing GHG emissions, consistent with the targets set by AB 32, Executive Order B-30-15 and codified by SB 32 and AB 197. AB 32 aimed at reducing GHG emissions to 1990 levels by 2020 and required the CARB to prepare a Scoping Plan that outlines the main State strategies for meeting the 2020 deadline and to reduce GHGs that contribute to global climate change. Executive Order B-30-15 added the immediate target of reducing GHG emissions to 40 percent below 1990 levels by 2030. CARB released a second update to the Scoping Plan, the 2017 Scoping Plan,
3 to reflect the 2030 target set by Executive Order B-30-15 and codified by SB 32. The companion bill to SB 32, AB 197, provides additional direction to the CARB related to the adoption of strategies to reduce GHG emissions. Additional direction in AB 197 intended to provide easier public access to air emissions data that are collected by CARB was posted in December 2016.

Overall, the AB 32 Scoping Plan contains GHG reduction measures that work towards reducing GHG emissions, consistent with the targets set by AB 32, Executive Order B-30-15 and codified by SB 32 and AB 197. The measures applicable to the project include energy efficiency measures, water conservation and efficiency measures, and transportation and motor vehicle measures. The project would comply with applicable energy measures through compliance with CALGreen energy conservation and green building standards. Compliance with CALGreen would also include measures related to the reduction of wastewater and water use. The project would also be required to comply with the California Model Water Efficient Landscape Ordinance. Therefore, the project would not conflict with any of the water conservation and efficiency measures. While specific regional emission targets for transportation emissions would not directly apply to the project, vehicles traveling to the project site would comply with the Pavley II (LEV III) Advanced Clean Cars Program. Therefore, the project would be consistent with the City’s CAP goals and would not result in new or substantially greater conflicts with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs than previously analyzed in the 2021 FEIR. 3California Air Resources Board. 2017. California’s 2017 Climate Change Scoping Plan. November.

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15.9 Hazards and Hazardous Materials
Transport, Use, or Disposal of Hazardous Materials/Accidental Release/Emissions Near a School 2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development that may require the transport, use, disposal of hazardous materials, or accidental release of hazardous materials. The 2021 FEIR determined that both ministerial and discretionary development on Housing Sites would be subject to extensive regulatory requirements including SCMC Chapter 8.36 (Hazardous Materials), the California Accidental Release and Prevention program, and other federal and state regulations relating to hazardous materials management and the SCMC requirements for the preparation and filing of Material Safety Data Sheet consistent with state laws would reduce impacts to a level less than significant.

Project
Construction and operation of the project would be subject to the regulatory requirements described in the 2021 FEIR. The project residential and commercial uses are consistent with allowable uses envisioned in the zone as part of the 2021 FEIR. The nearest school is Palisades Elementary School located approximately 0.9-mile northwest of the project site, greater than one quarter of a mile.

Therefore, project would not create a significant hazard to the public or the environment through routine transport, use, or disposal of hazardous materials, including within one-quarter mile of a school. No new or more severe impacts related to hazardous materials emissions or accidental release would occur.

Hazardous Materials Sites
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development that may be located on a hazardous materials site. The 2021 FEIR determined that future discretionary development at Housing Sites would be subject to an environmental review under CEQA that would ensure site-specific evaluation of individual sites to ensure no hazardous conditions are present or if present, measures are taken to minimize risk. The 2021 FEIR determined that implementation of Mitigation Framework HAZ-1 would reduce impacts for ministerial projects to a level less than significant.

Project
A Phase I Environmental Site Assessment (ESA) was prepared for the project that evaluated whether the site is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 (Appendix J). The Phase I ESA conducted a record search for the project site which identified the following listings on hazardous materials databases:
• The project site is listed as active in the California Facility Index (CA FID) underground storage tank (UST) database. The project site is listed in the Emissions Inventory Data (EMI) system as producing one carbon monoxide ton per year and two oxides of nitrogen tons per year.

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• The project site is listed in the Hazardous Waste Tracking System (HWTS) database with the inactive dates of 1999, 2000, 2001, 2005, and 2020.
• The project site is listed in the California Hazardous Waste Manifest (HAZNET) database maintained by the Department of Toxic Substances Control (DTSC) as having disposed of hazardous materials.
• The project site is listed in the Resource Conservation and Recovery Act Small Quantity Generator (RCRA-SQG) database. No violations were found. • The project site is listed in the Facility Index System/Facility Registry System (FINDS) and Enforcement & Compliance History Information (ECHO) database as various healthcare facilities. The environmental interest type is listed as “other hazardous waste activities”. No releases of hazardous substances are associated with the above listings.

Based on the review of database listings described above, the Phase I ESA determined that the project site does not qualify as a Recognized Environmental Conditions (REC). However, the Phase I ESA determined that the project site is listed in the UST database as having two USTs, one 550-gallon diesel UST and one 1,000-gallon product (not specified) UST. Both USTs are listed as active. The project site is listed in the California Environmental Reporting System (CERS) as a leaking underground storage tank (LUST) cleanup site. According to the Environmental Data Resources (EDR) Report, the leak was found on August 12, 1991, during inventory control. The cause of the leak is listed as corrosion. Approximately 190 gallons of diesel was leaked into the soils in the vicinity of the UST. The EDR Report lists that the leak was stopped by removing the contents of the UST.

Furthermore, the Orange County Health Care Agency (OCHCA) provided documents summarizing the activities associated with the clean-up of a diesel release onsite. The site received case closure and a No Further Action (NFA) letter on March 11, 1992. Based on the issuance of a NFA letter by the OCHCA, the Phase I ESA determined that this onsite listing is considered a Historical Recognized Environmental Conditions (HREC), which is defined as “a previous release of hazardous substances or petroleum products affecting the subject property that has been addressed to the satisfaction of the applicable regulatory authority or authorities and meeting unrestricted use criteria established by the applicable regulatory authority or authorities without subjecting the subject property to any controls (for example, activity and use limitations or other property use limitation).” The Phase I ESA did not identify any surrounding properties listed as hazardous materials sites in any regulatory databases. Therefore, as the project site has been remediated and cleared by the OCHCA, the project is not located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5. No new or substantially greater impacts associated with hazardous materials sites than previously analyzed in the 2021 FEIR would occur.

Airport Hazards
2021 FEIR
The 2021 FEIR determined that the City is not located within an Airport Land Use Compatibility Plan or within two miles of a public airport or public use airport. Therefore, the 2021 FEIR found that the Housing and Safety Elements Update would not result in an airport safety hazard or excessive noise for people residing or working in the project area.

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Project
The project site is not located within an Airport Land Use Compatibility Plan or within two miles of a public airport or public use airport. Therefore, the project would not result in a new or substantially greater safety hazard or excessive noise for people residing or working in the project area than previously analyzed. No new ore more severe impact would occur compared to what was evaluated in the 2021 FEIR.

Emergency Response
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development, and the Housing Sites are located within existing developed areas and along major transportation corridors in the City that would allow for evacuation and response.

Development at the Housing Sites would not physically interfere with any emergency response or evacuation plans because they would not include any features that would prevent continued implementation of these plans, and impacts would be less than significant.

Project
The project site is located within an urban environment along a developed transportation corridor that would allow for emergency evacuation. The project would utilize the existing driveway connections to Camino de los Mares. In order to reinforce the right-in and right-out turning movements at the western driveway, the project would make median improvements within Camino de Los Mares, and introduce signage and a center island at the driveway entrance to direct traffic.

These changes would improve safety for turns into or out of the western driveway and support emergency evacuation and response. The project would not make any other changes to the existing circulation network. Therefore, the project would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan beyond that previously analyzed, and no new or more severe impacts would occur compared to what was evaluated in the 2021 FEIR.

Wildland Fires
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development, and implementation of Safety Element policies by the City focused on increasing wildfire safety through increased coordination with fire protection agencies, using the latest mapping to determine wildfire risks, and supporting efforts to evaluate wildfire evacuation and safety planning. The 2021 FEIR determined that development of the Housing Sites, especially within or adjacent to Very High Fire Hazard Severity Zone (VHFHSZ), could result in impacts related to wildfire. However, future ministerial and discretionary development at the Housing Sites would be required to adhere to all regulatory requirements in place to minimize wildfire hazards including applicable sections of the SCMC, fire and building codes, and requirements from the fire chief that would be identified during future building permit reviews. Additionally, implementation of General Plan Policies S-3.02 through S-3.06 in the City’s General Plan Safety Element would further protect ATTACHMENT 31
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land uses within the VHFHSZ and enhance wildfire safety. Therefore, the 2021 FEIR determined that the Housing and Safety Elements Update would not expose people or structures either directly or indirectly to a significant risk of loss, injury, or death involving wildland fires, and impacts would be less than significant.

Project
The project site is located in an urbanized area and is not within, or adjacent to, an area identified as a VHFHSZ. The project would not result in new or more severe impact related to exposure of people or structures to wildland fires.

15.10 Hydrology and Water Quality
Water Quality
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development that could impact water quality. The 2021 FEIR determined that development of the Housing Sites would be subject to federal, state, and local regulations aimed at controlling water quality impacts. Both discretionary and ministerial development would be required to adhere to regulatory requirements including MS4 requirements, SCMC Chapters 13.40 (Stormwater Runoff Control), and Chapter 15.36 (Grading Ordinance), which include requirements to ensure storm water runoff is captured and treated and erosion control measures are implemented.

Adherence to these requirements would ensure that impacts associated with water quality would be less than significant.

Project
The Preliminary Water Quality Management Plan (PWQMP) prepared for the project determined that site is currently serviced by three existing storm drain lines (Appendix K). Runoff from the western portion of the project site is conveyed along the existing western drive aisle southerly to an existing inlet located in the southwestern portion of the site. Runoff is ultimately discharged to the existing storm drain line servicing Ocean View Plaza and conveyed southerly under I-5 to an existing wetland and natural drainage area, and then southeasterly through an existing golf course, prior to discharging to Prima Deshecha Canada and the Pacific Ocean to the south.

Runoff from the central and eastern portions of the project site are serviced by two existing storm drain lines located in the southeastern and the eastern portions of the site. These two storm drains convey flows to an existing storm drain line located within the existing apartment complex located east of the project site. Runoff is then conveyed easterly and then southerly under I-5, prior to discharging to an existing natural drainage and wetland and then southeasterly through an existing golf course, prior to discharging to Prima Deshecha Cañada and the Pacific Ocean to the south. The project does not receive run-on from off-site areas.

In the post-project condition, runoff from the site would be conveyed similar to pre-project conditions, with hydromodification controls employed to retain the site’s pre-development runoff flow rates and volumes. To satisfy the project’s requirement for Low Impact Development (LID) BMPs, ATTACHMENT 31
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hydromodification, and treat storm water pollutants of concerns, the project has been divided into five Drainage Management Areas (DMAs) as follows:
• DMA 1 (1.674 acres): Consists of the western and northern segment of the project site. Runoff would be conveyed southwesterly to an infiltration well located at the western portion of the project site.
• DMA 2 (4.463 acres): Consists of the central and southern portion of the project site. Runoff would be conveyed southwesterly to an infiltration well for retention. • DMA 3 (0.019 acre): Consists of existing landscaping, sidewalk and portion of the project’s southern entrance that drain away from the project site to the existing gutter in Camino de los Mares. Runoff from this area is not hydrologically connected to the project’s onsite DMAs.

No improvements are proposed for this area. No treatment is proposed for this area. • DMA 4 (0.448 acres): Consists of existing slopes and temporary disturbed areas (designated as 4-1 and 4-2) at the project’s southwestern limits required for remedial grading that would be returned to natural state. No treatment is proposed. • DMA 5 (0.064 acre): Consists of parkway and median improvements to Camion de los Mares.

Runoff from this area would be discharged to Camino de los Mares and is not hydrologically connected to the project’s onsite DMAs. Improvements within DMA would consist of the following:
o DMA 5-1 (0.002 acres): Replace existing pavement with extended paved median. No BMPs are proposed.
o DMA 5-2 (0.035 acres): Replace existing paved median and turn lane with landscaped median. Area is considered self-retaining as would consist almost entirely of depressed landscaping areas.
o DMA 5-3 (0.027 acres): The project would add two feet of sidewalk width and extend sidewalk to reconfigure project’s southern entrance. Runoff would be addressed via hydrologic source control BMP (HSC-3 Street Trees) designed to maximum extent practicable standards per U.S. Environmental Protection Agency’s Green Streets Manual.

Implementation of the infiltration facilities listed above would include water quality treatment that would ensure that runoff in the post-project condition would not violate any water quality standards or waste discharge requirements. Therefore, the project would not result in new or substantially greater impact on water quality than previously analyzed, and impacts would be less than significant.

No new impact would occur.

Groundwater
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development that could have an adverse effect related to groundwater. The 2021 FEIR stated that a majority of the City’s water is sourced from imported and recycled water, with approximately 5 percent of the City’s water supply portfolio for Fiscal Year 2019-2020 pumped for municipal use through two groundwater wells (wells #6 and #8). The 2021 FEIR determined that both ATTACHMENT 31
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redevelopment and new development on vacant sites would be required to comply with applicable storm water management requirements that focus on retention and infiltration of waters on-site.

Additionally, development at all Housing Sites would be required to comply with current stormwater regulations that prioritize infiltration and treatment of stormwater and generally require increased on-site infiltration and higher standards of water quality protection compared to water quality standards that would have been implemented on existing developed sites. Therefore, the 2021 FEIR determined that the Housing and Safety Elements Update would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that they may impede sustainable groundwater management of the basin, and impacts would be less than significant.

Project
The project site was evaluated as a potential rezone site (Site V) in the Housing Element Update that would be redeveloped with 238 multi-family residential units and 7,500 square feet of commercial space. The project has been slightly revised compared to the Housing Element Update to develop 250 senior housing units and 7,500 square feet of medical offices. The redesigned residential component would not substantively increase demand for water supply compared to what was evaluated in the 2021 FEIR. In fact, residents in a senior housing development may have lower demand for water supply compared to residents in multi-family units. The project would not utilize a groundwater well and would be served through a standard connection to the City of San Clemente Water Utility, drawing water from the City’s overall supply portfolio. As described above, the project would introduce two infiltrations wells on-site. These infiltration wells would increase infiltration compared to pre-project conditions, and therefore improve groundwater recharge onsite. Therefore, the project would not result in new or substantially greater impact on groundwater supplies or interference with groundwater recharge than previously analyzed, and impacts would be less than significant. No new impact would occur.

Drainage Patterns/Storm Water Runoff
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development that could result in impacts related to drainage patterns and storm water runoff. The 2021 FEIR determined that development of the Housing Sites would be subject to federal, state, and local regulations aimed at reducing polluted storm water and avoiding overloading the City’s drainage system. Both ministerial and discretionary development would be required to adhere to regulatory requirements including SCMC Chapter 13.40 (Stormwater Runoff Control) which includes requirements for the elimination or reduction of storm water run-off. Impacts associated with drainage patterns and storm water runoff would be less than significant. Adherence to these requirements would ensure that impacts associated with drainage patterns and storm water runoff would be less than significant.

Project
The Hydrology Analysis completed for the project evaluated peak stormwater flows during the 2-, 20-, and 100-year storm events in the pre-project and post-project conditions. As shown in Table 10, ATTACHMENT 31
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the project would reduce peak flows during 2-, 20-, and 100-year storm events in the post-project condition. Therefore, the project would not result in new or substantially greater impact related to drainage patterns or storm water runoff than previously analyzed, and impacts would be less than significant. No new impact would occur.

Table 10
Storm Water Flow Rates in Cubic Yards Per Second
Existing Proposed Change
West
2-Year Storm Event 2.60 2.60 0.00
10-Year Storm Event 4.80 4.70 0.00
100-Year Storm Event 7.50 6.75 -0.75
Northeast
2-Year Storm Event 2.90 2.90 0.00
10-Year Storm Event 5.30 5.20 -0.10
100-Year Storm Event 8.20 8.00 -0.20
Southeast
2-Year Storm Event 4.20 4.20 0.00
10-Year Storm Event 7.70 7.70 0.00
100-Year Storm Event 11.80 8.24 -3.56
Flood Hazard/Tsunami Inundation
2021 FEIR
The 2021 FEIR determined that Policy S-2.03 of the Safety Element reinforces application of Federal Emergency Management Agency regulations prohibiting development within a flood zone unless adequate assurances are provided against flood hazards. The 2021 FEIR also determined that the Safety Element update includes policies supporting implantation of adaptation strategies of the Coastal Resiliency Plan and incorporates this future document and the City’s Sea Level Rise Vulnerability Assessment by reference. The 2021 FEIR determined that future development of the Housing Sites would be required to conform to applicable federal, state, and City regulatory standards to effectively avoid and/or address potential impacts associated with development in flood zones, and none of the Housing Sites are within areas anticipated to be affected by tsunami or future sea level rise scenarios. Therefore, the 2021 FEIR determined that the Housing and Safety Elements Update determined that impacts associated with flood hazards and tsunami inundation would be less than significant.

Project
The project would be constructed entirely with the footprint of Site V that was evaluated in the 2021 FEIR. Review of Figure 4.8-2 of the 2021 FEIR determined that Site V is not located within a flood hazard zone, and review of Figure 4.8-3 of the 2021 FEIR determined that Site V is not located within the 2021 Tsunami Hazard Area. Therefore, the project would not result in new or substantially greater impact related to flood hazards and tsunami than previously analyzed. No new impact would occur.

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15.11 Land Use and Planning
Physically Divide an Established Community
2021 FEIR
The 2021 FEIR determined that the Safety Element is a policy document that would not result in any physical development, and none of the Housing Sites would require any new major infrastructure or improvements that could physically divide an established community. Therefore, the 2021 FEIR determined that the Housing and Safety Elements Update would not physically divide an established community, and impacts would be less than significant.

Project
There are no changes to the project that would affect the conclusions of the FEIR. The project site is located within an urban environment along a developed transportation corridor and was one of the sites evaluated for development in the PEIR. The project would redevelop a vacant hospital facility and supporting structures to a senior housing facility and medical office and would be constructed entirely within the project site without affecting adjacent properties. The project would utilize the existing driveway connections to Camino de los Mares and would not alter the existing circulation network. The project would connect to existing utilities that are already serving the surrounding development. Therefore, the project would not result in new or more severe impacts related to physical division of an established community compared to what was disclosed in the 2021 FEIR.

Conflicts with Plans and Policies
2021 FEIR
The 2021 FEIR determined that adoption of the Safety Element would ensure consistency with state law and provide additional policy in the City’s General Plan for the purpose of avoiding environmental impacts related to wildfire and climate change including sea level rise. The 2021 FEIR determined that future discretionary projects under the Housing Element Update would be subject to implementation of the City’s General Plan Mitigation Monitoring Requirements to ensure environmental impacts are minimized. However, future ministerial development would not be subject to an extensive policy review for consistency with General Plan policies and/or other applicable plans, and impacts related to policy inconsistency would remain significant and unavoidable.

Project
As described in Section 15.5 above, the project would mitigate all potential impacts to cultural resources to a level less than significant. As described in Section 15.7 above, the project would mitigate all potential impacts on paleontological resources to a level less than significant. As described in Section 15.8 above, the project would be consistent with the City’s CAP. As demonstrated throughout this Addendum, all other environmental impacts not requiring mitigation would be less than significant or would have no impact. The project would not cause a new or substantially greater or more severe impacts related to conflicts with any land use plan, policy, or ATTACHMENT 31
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regulation adopted for the purpose of avoiding or mitigating an environmental effect compared to what was previously analyzed.

15.12 Mineral Resources
2021 FEIR
The 2021 FEIR determined in Chapter 8.3 that the majority of land within the City is designated as MRZ-1, which is land where adequate geologic information indicates that no significant mineral deposits are present (8,464.95 acres). The remainder, located within the southwestern portion of the City (3,279.23 acres), is designated as MRZ-3, land for which the significance of mineral resources cannot be determined. Neither of these MRZ categories are considered significant mineral resources.

The City’s land use map does not delineate any mineral resource recovery sites or designate any land for mineral resource production. Therefore, the 2021 FEIR determined that the Housing and Safety Elements Update would not impact any known mineral resources that would be of value to the region, the state, or locally.

The 2021 FEIR determined that the City’s land use map does not delineate any mineral resource recovery sites or designate any land for mineral resource production. Therefore, the 2021 FEIR determined that the Housing and Safety Elements Update would not impact any mineral resource recovery sites.

Project
The project site is located in an area designated as MRZ-3, which is not considered a significant mineral resource. The project site is not delineated as a mineral resource recovery site on any land use plans. Therefore, the project would not result in a new or substantially greater impact related to the loss of availability of a known mineral resource that would be of value to the region or residents of the state or the City, compared to what was previously analyzed.

15.13 Noise
Noise Standards
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development that could have an adverse effect related to noise standards. The 2021 FEIR determined that development of the Housing Sites would not result in any impacts related to vehicular ambient noise, railroad noise, or stationary noise. The 2021 FEIR determined that implementation of the City’s General Plan Mitigation Monitoring Program for future discretionary development, and implementation of 2021 FEIR Mitigation Framework NOS-1 for ministerial development, would reduce impacts associated with land use noise compatibility to a level less than significant. However, the 2021 FEIR determined even after implementation of Final PEIR Mitigation Framework NOS-2 for ministerial development, impacts related to construction noise would remain significant and unavoidable.

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Project
A site-specific Noise and Vibration Impact Analysis was prepared for the project (Appendix L). Two long-term noise measurements were recorded in the vicinity of the project site in order to calculate the average hourly equivalent level (Leq) and community noise equivalent level (CNEL) at each location, which incorporate the evening and nighttime hours. Sources that dominate the existing noise environment include traffic on I-5, light traffic on Camino de los Mares, and occasional aircraft noise. Noise measurement data collected during the long-term noise monitoring are summarized in Table 11. Figure 4 presents the noise measurement locations.

Table 11
Existing Noise Level Measurements—Long Term
Location Description Date
Daytime
Noise Levels1
(dBA Leq)
Evening
Noise Levels2
(dBA Leq)
Nighttime
Noise Levels3
(dBA Leq)
Daily Noise
Level
(CNEL)
LT-1 654 Camino de los Mares, on
top of roof, near southwest
corner of building,
approximately 3 ft from edge of
roof, 300 ft from I-5 centerline.
4/13/2022 66.9–68.0 65.2–67.0 59.4–66.8 71.0
LT-2 654 Camino de los Mares, north
side of building facing Camino
de los Mares, approximately
80 ft from Camino de los Mares
centerline.
4/13/2022 61.8–62.9 59.3–61.4 46.6–60.7 64.1
SOURCE: Appendix L.
1 Daytime Noise Levels = noise levels during the hours from 7:00 a.m. to 7:00 p.m. 2Evening Noise Levels = noise levels during the hours from 7:00 p.m. to 10:00 a.m. 3Nighttime Noise Levels = noise levels during the hours from 10:00 p.m. to 7:00 a.m.

CNEL = Community Noise Equivalent Level
dBA = A-weighted decibels
ft = foot/feet
I-5 = Interstate 5
Leq = equivalent continuous sound level
Short-term Construction Impacts
Two types of short-term noise impacts would occur during project construction: (1) equipment delivery and construction worker commutes; and (2) project construction operations.

The first type of short-term construction noise would result from transport of construction equipment and materials to the project site and construction worker commutes. Based on the Air Quality and Greenhouse Gas Impact Analysis for the San Clemente Senior Housing Project, the project would generate an estimated total of 285 hauling truck trips over a 20-day demolition phase (14 trips per day) and an estimated total of 1,357 hauling truck trips over a 35-day grading phase (39 trips per day) (see Appendix C). These transportation activities would incrementally raise noise levels on access roads leading to the site. It is expected that larger trucks used in equipment delivery would generate higher noise impacts than trucks associated with worker commutes. The single-event noise from equipment trucks passing at a distance of 50 feet from a sensitive noise receptor would reach a ATTACHMENT 31
FIGURE 4
Noise Measurement Locations
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CAMPANILLA

CAMINO DE LOS MARES
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1 2
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CAMINO DE LOS MARES
§¨¦5
1 2
Image Source: NearMap (flown June 2022)
0 Feet 200 [
Project Boundary
!( Noise Measurement Location
M:\JOBS5\9335.6\common_gis\MXD\fig4_EIR.mxd 09/28/2022 bma ATTACHMENT 31
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maximum level of 84 A-weighted decibels maximum sound level (dBA Lmax). However, the pieces of heavy equipment for grading and construction activities would be moved on-site just one time and would remain on-site for the duration of each construction phase. This one-time trip, when heavy construction equipment is moved on- and off-site, would not add to the daily traffic noise in the project vicinity. The total number of daily vehicle trips would be minimal when compared to existing traffic volumes on the affected streets, and the long-term noise level change associated with these trips would not be perceptible. Therefore, equipment transport noise and construction-related worker commute impacts would be short-term and would not result in a significant off-site noise impact.

The second type of short-term noise impact is related to noise generated during demolition, site preparation, grading, building construction, architectural coatings, and paving on the project site.

Construction is undertaken in discrete steps, each of which has its own mix of equipment, and, consequently, its own noise characteristics. These various sequential phases would change the character of the noise generated on the project site. Therefore, the noise levels vary as construction progresses. Composite noise level of each construction phase was calculated as presented in Table 12.

Table 12
Potential Construction Noise Impacts by Phase
Phase Equipment (Quantity)
Composite Noise Level at
50 feet (dBA Leq)
Demolition Concrete Saw (1), Excavator (1), Dozer (2) 86 Site Preparation and
Grading
Excavator (1), Grader (1), Dozer (2), Tractor
(2) 87
Building Construction Crane (1), Forklift (3), Tractor (2) 84 Paving Paver (2), Paving Equipment (2), Roller (2) 86
Architectural Coating Air Compressor (1) 74
SOURCE: Appendix L.
dBA Leq = average A-weighted hourly noise level
Composite construction noise levels at a distance of 50 feet would range from 74 dBA Leq to 87 dBA Leq, with the highest noise levels occurring during the site preparation phase. The Noise and Vibration Analysis then adjusted noise levels based on distances to the nearest sensitive receptor. Table 13 shows the nearest sensitive uses that surround the project site, the distances of their respective property lines from the center of construction activities, which represents the acoustic center of construction noise, and the noise levels expected during site preparation and grading activities, which would generate the greatest noise levels. These noise level projections do not take into account intervening topography or barriers, and therefore can be considered conservative estimates.

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Table 13
Potential Construction Noise Impacts During Site Preparation and Grading Receptor Distance (feet) Noise Level (dBA Leq)
San Clemente Villas Senior Living (Southeast) 260 73
Commercial (West and North) 350 70
SOURCE: Appendix L.
dBA Leq = average A-weighted hourly noise level
While construction noise will vary, it is expected that composite noise levels during construction at the nearest off-site residential land uses to the southeast would reach 73 dBA Leq during the site preparation phase. It is expected that composite noise levels during construction at the nearest commercial land uses to the west and north would reach 70 dBA Leq. These predicted noise levels would only occur when all construction equipment is operating simultaneously at the closest point of construction, and therefore are assumed to be conservative in nature. While construction-related short-term noise levels have the potential to be higher than existing ambient noise levels in the project area under existing conditions, the noise impacts would no longer occur once project construction is completed.

Noise impacts associated with construction activities are regulated by the City’s noise ordinance. The project would be required to comply with the construction hours specified in the City’s Noise Ordinance, which states that construction activities are allowed between 7:00 a.m. and 6:00 p.m., Monday through Friday, and between 8:00 a.m. and 6:00 p.m. on Saturday. Construction is not permitted outside of these hours, on a Sunday, or on a City-recognized holiday, unless a temporary waiver is granted by the development services director or his/her authorized representative, or in emergencies, including maintenance work on City rights-of-way.

As it relates to off-site uses, construction-related noise impacts would remain below the 80 dBA Leq and 85 dBA Leq construction noise level criteria, as established by the Federal Transit Authority (FTA) for residential and commercial land uses, respectively. Therefore, impacts associated with construction noise would be considered less than significant. To minimize noise impacts even further to the extent feasible, the project construction would utilize the following practices:
• All construction vehicles or equipment, fixed or mobile, operated within 1,000 ft of a dwelling shall be equipped with operating and maintained mufflers. • Stockpiling and/or vehicle storage areas shall be located as far as practicable from and out of view of dwellings.

Therefore, the project would not result in a new or substantially greater impact related to construction noise compared to what was previously analyzed, and impacts would be less than significant. No new impact would occur.

Operational Traffic Noise Impacts on Off-Site Receivers The project would generate 1,080 daily trips. The Noise and Vibration Analysis evaluated potential traffic noise impacts on off-site receivers based on a peak-hour traffic volume of 1,899 vehicle trips on Camino de los Mares. Assuming the ADT is ten times the peak-hour traffic, the ADT in the vicinity ATTACHMENT 31
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of the project would be 18,990 vehicle trips. The addition of project-related vehicle trips would result in an increase of approximately 0.24 CNEL along Camino de los Mares. A noise level increase of less than 3 dBA would not be perceptible to the human ear. Therefore, the project would not result in a new or substantially greater impact related to traffic noise impacts on off-site receivers compared to what was previously analyzed, and impacts would be less than significant. No new impact would occur.

Operational On-Site Generated Noise
The project would include rooftop heating, ventilation, and air conditioning (HVAC) units. While Building 3 (Health Center Building) would contain rooftop HVAC equipment, noise impacts would only occur during daytime operational hours. For the proposed living units in Buildings 1 and 2, the HVAC equipment could operate 24 hours per day. The Noise and Vibration Analysis estimated that rooftop HVAC equipment for a single unit would generate a noise level of 66.6 dBA Leq at 5 feet.

Table 14 presents the noise levels from HVAC equipment at the nearest noise-sensitive location. The closest off-site sensitive uses to the proposed location of an on-site HVAC unit would be located approximately 140 feet away. According to the site plan, 20 banks of HVAC units are proposed to be installed. Per the building plans, each building would have parapet walls to hide the mechanical equipment, which would reduce noise levels by a minimum of 5 dBA, resulting in a reference level of 72.4 dBA Leq at 5 feet from each bank of HVAC units. After distance attenuation, noise generated from the four closest banks of HVAC equipment would be up to 48.0 dBA Leq at the nearest sensitive use. This noise level would not exceed the City’s exterior daytime (7:00 a.m. to 11:00 p.m.) and nighttime (11:00 p.m. to 7:00 a.m.) noise standards of 55 dBA Leq and 50 dBA Leq, respectively.

Additionally, the projected noise level would be below the quietest existing ambient noise levels at the nearest off-site sensitive building façade. The other 16 banks of HVAC equipment would be further away and would receive greater noise reduction due to additional rooftop parapet shielding, and thus are not expected to contribute to the combined noise level. Therefore, the project would not result in a new or substantially greater impact related to operational on-site noise compared to what was previously analyzed, and impacts would be less than significant. No new impact would occur.

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Table 14
Summary of HVAC Noise Levels
Off-Site
Land Use
(Direction)
Distance
from HVAC
Units
(ft)
Reference Noise
Level for 1 Unit
at 5 ft
(dBA Leq)
Reference Noise for
a Bank of 12 Units
at 5 ft
(dBA Leq)
1 Distance
Attenuation
(dBA)
Noise
Level
(dBA Leq)
Combined
Noise
Level
(dBA Leq)
San
Clemente
Villas Senior
Living
(Southeast)
140

66.6 72.4
29 43.0

48.0 150 30 43.0
190 32 41.0
195 32 41.0
SOURCE: Appendix L.
1 Includes a minimum reduction of 5 dBA provided by rooftop parapet walls. dBA = A-weighted decibel(s)
ft = foot/feet
HVAC = heating, ventilation, and air conditioning
Leq = equivalent continuous sound level
On-Site Land Use Compatibility
While impacts to the project site from the surrounding environment are not considered an impact related to CEQA, the following analysis assesses compliance with the local land use compatibility standards. The project is in an area where parcels to the east, west, and north are currently occupied and operational. For this reason, this analysis relies on the existing measured noise levels as well as future predicted noise levels to provide the most accurate description of the noise environment related to traffic noise impacts. The City’s General Plan does not provide land use compatibility standards for future development. Therefore, for the purposes of this analysis, the County’s exterior noise level standard of 65 CNEL was used to determine project compatibility. The interior noise level standard for residential uses is 45 CNEL.

Exterior Noise Assessment
As shown in Table 11 above, the existing measured noise levels at the project site range from approximately 64.1 CNEL on the northern portion of the site, close to Camino de los Mares, to

71.0 CNEL on the southern portion of the site, close to I-5.

To assess the exterior noise levels at the proposed pool area south of Building 1, the future noise levels were based on existing measured noise levels and an estimated noise increase based on future growth. The Noise and Vibration Impact Analysis determined that the annual average daily traffic (AADT) on I-5 in the vicinity of the project is 179,700. The estimated future AADT, assuming a time period of 20 years and a 1 percent growth rate, would be 215,640, resulting in a 0.8 dB increase.

Therefore, the exterior noise levels at the recreational pool area closest to I-5 would approach 72 CNEL.

The project would include a six-foot-high combo masonry and glass pool barrier that would be located around the pool area at Building 1. Additionally, the project would include a six-foot-high combo stucco wall and glass safety and sound barrier that would be located at the perimeter of the ATTACHMENT 31
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rooftop deck. Noise levels would be reduced by approximately 8 dBA at each location, resulting in a noise level of 64 CNEL. Noise levels at these locations would be below the County’s 65 CNEL exterior noise level standard. Therefore, with the proposed barriers, no additional noise reduction features would be necessary to comply with land use compatibility standards.

The project would also include an additional outdoor recreation area in the form of the central courtyard in the northern portion of Building 2, which would be considered an exterior sensitive use.

With future exterior noise levels approaching 64.4 CNEL (existing noise level of 64.1 CNEL + 0.3 CNEL growth from the project) and significant noise reduction provided by the building on all sides, the noise level would be well below the County’s 65 CNEL exterior noise level standard. Therefore, no additional noise reduction features would be required. All other courtyard areas including those between Building 1 and Building 2, as well as the courtyard on the southern portion of Building 2 are not considered noise sensitive as they are points of access from the exterior sidewalks and interior units. Therefore, the project would not result in a new or substantially greater impact related to exterior noise compatibility compared to what was previously analyzed, and impacts would be less than significant. No new impact would occur.

Interior Noise Assessment
Per Title 24 of the California Code of Regulations, an interior noise level standard of 45 CNEL or less is required for all habitable rooms (i.e., rooms used for living, sleeping, eating, and cooking).

Consistent with the 2021 FEIR, which incorporated by reference the City’s General Plan Mitigation Monitoring Requirements, the Noise and Vibration Impact Analysis included a detailed analysis of the noise reduction requirements and needed noise insulation features in order to meet the interior noise standards (City’s General Plan Mitigation Monitoring Program Measure 10-1). Based on the expected future exterior noise levels at the southern façades of Buildings 1 and 2 closest to I-5, noise levels would approach 72 CNEL and a minimum noise reduction of 27 dBA would be required.

Because the project would include a form of mechanical ventilation, windows and doors could remain closed.

The Noise and Vibration Impact Analysis utilized previously completed sample interior noise calculations assume standard building construction and upgraded window assemblies. Based on reference information from transmission loss test reports for various Milgard windows, the southern, western, and eastern façades would require windows with sound transmission class (STC) ratings of approximately 30–35, depending on the glass-to-wall ratio at the façades with a view of I-5. For units facing Camino de los Mares, as well as units facing the center of the project buildings, interior noise levels of 45 CNEL or less would be achieved by using standard building construction along with standard windows (typically in the STC 25–28 range). Therefore, the project would not result in a new or substantially greater impact related to interior noise compared to what was previously analyzed, and impacts would be less than significant. No new impact would occur.

Groundborne Noise and Vibration
2021 FEIR
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noise. The 2021 FEIR determined that implementation of the City’s General Plan Mitigation Monitoring Program for future discretionary development, and implementation of 2021 FEIR Mitigation Framework NOS-3 for ministerial development, would reduce impacts associated with excessive groundborne vibration and groundborne noise to a level less than significant.

Project
An analysis of construction vibration using vibration levels in VdB for human annoyance and assessing the potential for building damages using vibration levels in PPV (in/sec). This is because vibration levels calculated in root-mean-square (RMS), representing an average condition, are best for characterizing human response to building vibration, while calculating vibration levels in PPV is best for characterizing the potential for damage representing maximum vibration conditions.

In order to determine the potential for annoyance, the distance between the nearest off-site buildings and the center of project construction is utilized to represent the average condition. To assess potential vibration damage, the distance of assessment is measured between the nearest offsite buildings and the project construction boundary (assuming the construction equipment would be used at or near the project setback line). Bulldozers and other heavy-tracked construction equipment (expected to be used for this project) would generate approximately 0.089 PPV in/sec or 87 VdB of groundborne vibration when measured at 25 feet, based on the FTA Manual.

As shown in Table 15, vibration levels are expected to approach 56 VdB at the closest residence located immediately southeast of the project site and 53 VdB at the closest commercial uses located west and north of the project site, which are below the 78 VdB and 84 VdB thresholds for annoyance, respectively.

The closest structure to the project site is the residence to the southeast of the site, approximately 25 ft from the limits of construction activity. As shown in Table 16, it is expected that vibration levels generated by dump trucks and other large equipment that would be as close as 25 ft from the property line would generate groundborne vibration levels of up to 0.089 PPV (in/sec) at the closest structure to the project site and would not exceed the 0.2 PPV (in/sec) threshold. All other structures are further away and would experience lower vibration levels. Because construction activities are regulated by the City’s Municipal Code, which states that construction activities are only allowed between 7:00 a.m. and 6:00 p.m., Monday through Friday, and between 8:00 a.m. and 6:00 p.m. on Saturday, vibration impacts would not occur during the more sensitive nighttime hours.

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Table 15
Potential Construction Vibration Annoyance Impacts at Nearest Receptor Receptor (Location)
Reference
Vibration Level
(VdB) at 25 ft1 Distance (ft)2
Vibration Level
(VdB)
Residence (Southeast) 87 260 56
Commercial (West and North) 350 53
SOURCE: Appendix L. 1
The reference vibration level is associated with a large bulldozer, which is expected to be representative of the heavy equipment used during construction.
2 The reference distance is associated with the average condition, identified by the distance from the center of construction activities to surrounding uses.
ft = foot/feet
VdB = vibration velocity decibel(s)
Table 16
Potential Construction Vibration Damage Impacts at Nearest Receptor Receptor (Location)
Reference Vibration
Level (PPV) at 25 ft1 Distance (ft)2
Vibration
Level
(PPV)
Residence (Southeast)

0.089
25 0.089
Commercial (West) 40 0.044
Commercial (North) 120 0.008
SOURCE: Appendix L. 1
The reference vibration level is associated with a large bulldozer, which is expected to be representative of the heavy equipment used during construction.
2 The reference distance is associated with the peak condition, identified by the distance from the perimeter of construction activities to surrounding structures. ft = foot/feet
PPV = peak particle velocity
The streets surrounding the project site are paved, smooth, and unlikely to cause significant groundborne vibration. Additionally, the rubber tires and suspension systems of buses and other on road vehicles make it unusual for on-road vehicles to cause groundborne noise or vibration problems. Additionally, once constructed, the project would not contain uses that would generate groundborne vibration. Therefore, the project would not result in a new or substantially greater impact related to vibration compared to what was previously analyzed, and impacts would be less than significant. No new impact would occur.

Aircraft Noise
2021 FEIR
The 2021 FEIR determined that no portions of the City are within the 65 CNEL noise contours of any airport and the Housing and Safety Elements Update would not expose people residing or working in the area to excessive noise levels.

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Project
The project site is not located within 65 CNEL noise contours of any airport. Therefore, the project would not result in a new or substantially greater impact related to exposure of people to excessive airport noise levels compared to what was previously analyzed in the 2021 FEIR.

15.14 Population and Housing
Induce Unplanned Population Growth
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that does not have the potential to add growth or population to the City. The 2021 FEIR determined that the Housing Element Update would allow for development of residential units to meet the City’s future housing needs identified in the 2020 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) and assist in the City’s ability to meet its RHNA goals. Therefore, the 2021 FEIR determined that the Housing and Safety Elements Update would not induce substantial unplanned population growth in an area, either directly or indirectly, and impacts would be less than significant.

Displace People or Housing
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that does not have the potential to redevelop existing housing. The 2021 FEIR determined that implementation of the Housing Element Update would result in an increase in housing units in the City. Although the Housing Element Update would displace residential uses at two rezone sites, replacement housing would expand opportunities for housing in the City by providing increased density at redeveloped sites. Therefore, the 2021 FEIR determined that the Housing and Safety Elements Update would not displace substantial numbers of existing housing or people, and impacts would be less than significant.

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Project
The project site consists of a vacant hospital facility, does not possess any housing, and its redevelopment would not displace any residents. Therefore, the project would not result in new or substantially greater impacts relating to the displacement of existing people or housing compared to what was evaluated in the 2021 FEIR.

15.15 Public Services and Recreation
Fire Protection
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that does not have the potential to add growth or population to the City and would not, in itself have an impact on the need for new fire protection facilities. The 2021 FEIR determined that development at the Housing Sites would not directly result in sufficient demand to require construction of new fire facilities, since each incremental housing development would pay its fair share toward anticipated fire facility needs.

Furthermore, construction of any future fire facilities would be under a separate environmental review and approval. Therefore, the 2021 FEIR determined that the Housing and Safety Elements Update would not result in substantial adverse physical impacts associated with the provision of new or physically altered fire protection facilities, and impacts would be less than significant.

Project
The project site was evaluated as a potential rezone site (Site V) in the Housing Element Update that would be redeveloped with 238 multi-family residential units and 7,500 square feet of commercial space. The project has been slightly revised compared to the Housing Element Update to develop 250 senior housing units and 7,500 square feet of medical offices. The redesigned residential component would still be consistent with the Housing Element Update goal of meeting the City’s future housing needs identified in the 2020 RTP/SCS and comply with state law. Furthermore, the addition of 12 units compared to what was evaluated in the PEIR would not substantially increase demand for fire protection services. Therefore, the project would not result in a new or substantially greater need for new or altered public service facilities than previously analyzed, and impacts would be less than significant. No new impact would occur.

Police Protection
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that does not have the potential to add growth or population to the City and would not, in itself have an impact on the need for new police protection services. The 2021 FEIR determined that development at the Housing Sites would not directly result in sufficient demand to require construction of new police facilities, since each incremental housing development would pay its fair share toward anticipated police facility needs. Furthermore, construction of any future police facilities would be under a separate environmental review and approval. Therefore, the 2021 FEIR determined that the Housing and Safety Elements Update would not result in substantial adverse physical impacts associated with the ATTACHMENT 31
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provision of new or physically altered police protection facilities, and impacts would be less than significant.

Project
The project site was evaluated as a potential rezone site (Site V) in the Housing Element Update that would be redeveloped with 238 multi-family residential units and 7,500 square feet of commercial space. The project has been slightly revised compared to the Housing Element Update to develop 250 senior housing units and 7,500 square feet of medical offices. The redesigned residential component would still be consistent with the Housing Element Update goal of meeting the City’s future housing needs identified in the 2020 RTP/SCS and comply with state law. Furthermore, the addition of 12 units compared to what was evaluated in the 2021 FEIR would not substantially increase demand for police protection services. Therefore, the project would not result in a new or substantially greater need for new or altered police protection facilities than previously analyzed, and impacts would be less than significant. No new impact would occur.

Schools
2021 FEIR
The PEIR determined that the Safety Element Update is a policy document that does not have the potential to add growth or population to the City needing school services. The PEIR determined that development at the Housing Sites would not directly result in sufficient demand to require construction of new school facilities, since each incremental housing development would pay its fair share toward anticipated school facility needs. Furthermore, construction of any future school facilities would be under a separate environmental review and approval. Therefore, the PEIR determined that the Housing and Safety Elements Update would not result in substantial adverse physical impacts associated with the provision of new or physically altered school facilities, and impacts would be less than significant.

Library Services
2021 FEIR
The PEIR determined that the Safety Element Update is a policy document that does not have the potential to add growth or population to the City needing additional public services such as libraries.

The PEIR determined that development at the Housing Sites would not directly result in sufficient demand to require construction of new public facilities such as libraries, since each incremental housing development would pay its fair share toward anticipated facility needs. Furthermore, construction of any future public facilities would be under a separate environmental review and ATTACHMENT 31
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approval. Therefore, the PEIR determined that the Housing and Safety Elements Update would not result in substantial adverse physical impacts associated with the provision of new or physically altered public facilities such as libraries, and impacts would be less than significant.

Parks and Recreation Facilities
2021 FEIR
The PEIR determined that the Safety Element Update is a policy document that does not have the potential to add growth or population to the City needing park services. The PEIR determined that development at the Housing Sites would not directly result in sufficient demand to require construction of new park facilities, since each incremental housing development would pay its fair share toward anticipated park facility needs. Furthermore, construction of any future park facilities would be under a separate environmental review and approval. Therefore, the PEIR determined that the Housing and Safety Elements Update would not result in substantial adverse physical impacts associated with the provision of new or physically altered park facilities, and impacts would be less than significant.

The 2021 FEIR determined that development of the Housing Sites would increase use of existing park facilities and increase demand for additional park and recreation facilities. However, future residential units developed under the project would be required to pay in-lieu fees consistent with the Quimby Act to pay for additional park facilities within the City. Payment of such fees would allow the City to continue to implement numerous General Plan policies in place to maintain park and recreation facilities within the City. Furthermore, construction of any future park facilities would be under a separate environmental review and approval. Therefore, the 2021 FEIR determined that the Housing and Safety Elements Update would not increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated, and impacts would be less than significant.

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demand. The project also proposes both indoor and outdoor amenities for the residents, including a common clubroom, fitness center, roof-top deck, resort style pool deck, landscaped courtyards, and central paseo walkway. These amenities would be located entirely within the project footprint.

The project park demands would be consistent with what was analyzed in the 2021 FEIR. No new or more severe impacts related to park and recreation facilities would result compared to what was analyzed in the 2021 FEIR. The project would not result in any new impacts or a substantial increase in severity of impacts related to parkland deterioration or provision of recreational facilities compared to what was evaluated in the 2021 FEIR.

15.16 Transportation
Circulation System
2021 FEIR
The 2021 FEIR determined that adoption of the Housing and Safety Elements Update would not physically impact any existing roadway, pedestrian, bicycle, or transit facilities. Future site-specific projects at Housing Sites would be subject to an engineering and design review that would ensure consistency with applicable policies related to transit, roadway, bicycle, and pedestrian facilities.

Therefore, the 2021 FEIR determined that the Housing and Safety Elements Update would not conflict with a plan, ordinance, or policy addressing the circulation system, and impacts would be less than significant.

Project
The project would be consistent with the City’s General Plan Mobility and Complete Streets Element because it would continue to provide safe access to the site for all users. Sidewalks are provided to access adjacent uses (e.g., Ocean View Plaza), consistent with the policies outlined in the City’s Bicycle and Pedestrian Master Plan. The project would also be consistent with Policy M-2.07 because it would provide a mix of senior housing and medical office uses, and is located along an existing transit route (Orange County Transit Authority Route 1, Long Beach to San Clemente) on Camino de los Mares.

The project would not alter any existing transportation facilities adjacent to and surrounding the project site (e.g., vehicular, transit, bicycle, or pedestrian). The project would utilize the existing driveway connections to Camino de los Mares. In order to reinforce the right-in and right-out turning movements at the western driveway, the project would make median improvements within Camino de Los Mares, and introduce signage and a center island at the driveway entrance to direct traffic.

These changes would improve safety for turns into or out of the western driveway. The project would not make any other changes to the existing circulation network. Similarly, the project would not preclude implementation of a Class 3 Bike Route along Camino de los Mares as recommended in the City’s Bicycle and Pedestrian Master Plan. Therefore, the project would not result in a new or substantially greater conflict with a plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities than previously analyzed, and impacts would be less than significant. No new impact would occur.

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Vehicle Miles Traveled
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that does not have the potential to add growth or population to the City that would increase VMT. The 2021 FEIR determined that development of the Housing Sites in conjunction with buildout of the City’s General Plan land use map and transportation network would result in a VMT efficiency representing 158 percent of the regional average for Orange County. This would be a significant impact.

Implementation of 2021 FEIR Mitigation Framework TRA-1 would ensure that future ministerial development implements applicable General Plan policies that promote reduction in VMT, including the implementation of Transportation Demand Management programs. However, the effectiveness of VMT reducing measures is context-sensitive and would vary depending on the site-specific project site. Therefore, impacts associated with VMT would remain significant and unavoidable.

Project
A Vehicle Miles Traveled Analysis was prepared for the project to identify whether the project’s VMT generation would be consistent with the assumptions used in the 2021 FEIR for the project site (Appendix M). The project site was evaluated as a potential rezone site (Site V) in the 2021 FEIR. The 2021 FEIR analysis assumed the site would be redeveloped with 238 multi-family residential units and 7,500 square feet of commercial space. Compared to the 2021 FEIR analysis for the site, the project has been slightly revised to propose 250 senior housing units and 7,500 square feet of medical offices.

Table 17 presents a comparison of trip generation based on the land uses assumed in the 2021 FEIR compared to the current project. The current project consists of senior housing units rather than typical multi-family dwelling units that were evaluated in the 2021 FEIR. Similarly, the current project consists of medical office use rather than commercial (general office) use which was used as the basis for trip generation in the 2021 FEIR. As shown in Table 17, Site V was estimated to generate 1,162 ADT, and the current project is estimated to generate 1,080 ADT based on trip rates referenced from the Institute of Transportation Engineers Trip Generation Manual, 11th Edition. Overall, trip generation would decrease compared to the 2021 FEIR.

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Table 17
Project Trip Generation Comparison
Development
Assumptions
Trip Rate
(ADT/Unit or
TSF)
Average Daily
Trips
2021 FEIR Trip Generation
Multi-family Housing (Mid-Rise) 238 DU 4.54 1,081
General Office Building 7.500 TSF 10.84 81
Total 2021 FEIR Trip Generation 1,162
Project Trip Generation
Senior Adult Housing – Multi-family 250 DU 3.24 810
Medical-Dental Office Building –Stand-Alone 7.500 SF 36.00 270 Total Current Project Trip Generation 1,080
Net Trip Generation (Project – 2021 FEIR) (82)
SOURCE: Appendix M.

ADT = average daily trips
TSF = thousand square feet
DU = dwelling unit
In addition to the reduced average daily trips, the land uses proposed by the current project land would generate trips with shorter trip lengths than the uses previously analyzed in the 2021 FEIR, because the senior housing units would not be associated with a home-work commute for most units. Additionally, the medical office building would likely be used by the adjacent senior housing residents, reducing the distance of potential trips for medical needs. The proposed medical office building would offer other residential uses in the City a more convenient location than existing medical offices farther away.

Internal trip capture reductions were calculated between the proposed uses due to the interaction between the senior housing and medical office uses on site. Internal trip capture reductions were estimated using the National Cooperative Highway Research Program (NCHRP) 684 Trip Capture Estimation Tool, which is referenced in the ITE Trip Generation Handbook, 3rd Edition (2017). Based on the NCHRP 684 Trip Capture Estimation Tool, 3 percent of the senior housing outbound trips and 6 percent of the medical office inbound trips would occur internally during the AM peak-hour. Four percent of the senior housing outbound trips and 11 percent of the medical office inbound trips would occur internally during the PM peak-hour. The internal trip capture concept could also be applied to the senior housing use east of the project site (San Clemente Villas by the Sea), as those residents would be able to walk to the proposed medical office building rather than driving to other medical office buildings in San Clemente or beyond.

Furthermore, the project site is immediately east of Ocean View Plaza with a variety of uses including restaurant, retail, bank, supermarket, and drugstore. The future senior housing residents would be able to walk to these nearby uses rather than driving to similar uses in the City and beyond, which would result in a reduction in VMT. Due to the combination of lower trip generation and reduced trip length, the current project would generate less VMT compared to the previous project that was evaluated in the 2021 FEIR. Therefore, the project would not result in a new or substantially greater impact related to VMT than previously analyzed.

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The 2021 FEIR concluded impacts related to VMT would be significant and unavoidable because VMT/capita would exceed the regional average for Orange County. The 2021 FEIR referenced consistency with Mobility Element Policy 1.21 as a means to reduce single-occupant vehicles and encourage alternative modes of transportation. The project, as discussed above is VMT reducing as it would locate senior housing in proximity to a medical office building and in proximity to other services within walking distance. The project incorporates pedestrian access to facilitate and encourage walking. The project has demonstrated consistency with City policy related to VMT reduction to the extent feasible. Implementation of the project would result in reduced VMT compared to what was analyzed in the 2021 FEIR. No new impacts or more severe impacts related to VMT would occur.

Hazards Due to a Design Feature
2021 FEIR
The 2021 FEIR determined that the Housing and Safety Elements Update did not propose any changes to the existing roadway network, and future site-specific development would be designed consistent with established roadway design standards. Therefore, the 2021 FEIR determined that the Housing and Safety Elements Update would not substantially increase hazards, and impacts would be less than significant.

Project
The project would utilize the existing driveway connections to Camino de los Mares. In order to reinforce the right-in and right-out turning movements at the western driveway, the project would make median improvements within Camino de Los Mares, and introduce signage and a center island at the driveway entrance to direct traffic. These changes would improve safety for turns into or out of the western driveway. The project would not make any other changes to the existing circulation network. Any modifications to the existing connections to Camino de los Mares would be completed consistent with applicable safety standards. Therefore, the project would not result in a new or substantially greater increase hazards due to a geometric design feature or incompatible use than previously analyzed, and impacts would be less than significant. No new impact would occur.

Emergency Access
2021 FEIR
The 2021 FEIR determined that the Housing and Safety Elements Update did not propose any changes to the existing roadway network, and access for future site-specific development to the existing roadway network would be configured consistent with established roadway design standards that would allow for emergency access. The City would continue to implement the MultiHazard Emergency Plan to ensure adequate emergency access within the City. Therefore, the 2021 FEIR determined that the Housing and Safety Elements Update would not result in inadequate emergency access, and impacts would be less than significant.

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Project
The project site is located within an urban environment along a developed transportation corridor that would allow for emergency access. The project would utilize the existing driveway connections to Camino de los Mares. In order to reinforce the right-in and right-out turning movements at the western driveway, the project would make median improvements within Camino de Los Mares, and introduce signage and a center island at the driveway entrance to direct traffic. These changes would improve safety for turns into or out of the western driveway and support emergency access. The project would not make any other changes to the existing circulation network. Any modifications to the existing connections to Camino de los Mares would be completed consistent with applicable safety standards related to emergency access. Therefore, the project would not result in new or substantially greater inadequate emergency access than previously analyzed, and impacts would be less than significant. No new impact would occur.

15.17 Utilities and Service Systems
Utility Infrastructure
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that is a policy document that would not result in any physical development that would require utility services. The 2021 FEIR determined that future development at the Housing Sites would be located within existing developed areas with access to utility infrastructure. Utility infrastructure improvements and relocations associated with the future Housing Sites would be evaluated in their respective subsequent environmental documents for discretionary projects, or as part of the ministerial review that will be implemented through an overlay zone that includes objective standards and requirements to reduce physical impacts to the extent feasible, and impacts would be less than significant.

Project
Existing utility services are available adjacent to the site, and improvements would be limited to extension of pipelines onto the project site. Consequently, potential impacts associated with proposed on-site utility facilities have been considered within this environmental document. The project site was evaluated as a potential rezone site (Site V) in the Housing Element Update that would be redeveloped with 238 multi-family residential units and 7,500 square feet of commercial space. The project has been slightly revised compared to the Housing Element Update to develop 250 senior housing units and 7,500 square feet of medical offices. The redesigned residential component would not substantively increase demand for utility services compared to what was evaluated in the 2021 FEIR. In fact, residents in a senior housing development may have lower utility demand compared to residents in multi-family units. Therefore, the project would not result in a new or substantially greater increase in demand for utility services than previously analyzed, and impacts would be less than significant. No new impact would occur.

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Water Supply
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development that would increase demand for water supply. The City’s UWMP anticipated that it would be able to acquire necessary water supplies to meet demand through 2045.

Future residential uses anticipated in the Housing Element sites inventory and potential rezone sites would accommodate future population growth within the City anticipated by SCAG and would not introduce additional housing beyond what is projected. The 2021 FEIR determined that the Housing Sites have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years, and impacts would be less than significant.

Wastewater Treatment
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development that would increase demand for wastewater treatment. Development at the Housing Sites would accommodate future population growth within the City anticipated by SCAG. Therefore, the project would not introduce additional housing that is not anticipated within the City, and would not increase demand for wastewater treatment beyond what has been planned and is anticipated by the City’s service providers, and impacts would be less than significant.

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Solid Waste
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development that would generate solid waste. The 2021 FEIR determined that adequate landfill capacity exists to serve development of the Housing Sites, and impacts would be less than significant. The 2021 FEIR additionally determined that the project would comply federal, state, and local management and reduction statutes related to solid waste, and impacts would be less than significant.

Regarding consistency with regulations and policies, the City would continue to implement General Plan policies to reduce amount of material disposed at landfills, and the project would be subject to the same requirements. Therefore, the project would not result in a new or substantially greater impact related to conflicts with statutes and regulations related to solid waste compared to what was analyzed in the 2021 FEIR.

15.18 Wildfire
Emergency Response Plans
2021 FEIR
The 2021 FEIR determined that the Safety Element is a policy document that would not result in any physical development, and the Housing Sites are located within existing developed areas and along major transportation corridors in the City that would allow for evacuation and response.

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emergency response and evacuation. The project would not make any other changes to the existing circulation network. Therefore, the project would not result in any new impacts or substantially increase the severity of impacts related to emergency response plans or emergency evacuation plans beyond what was previously analyzed in the 2021 FEIR.

Wildfire
2021 FEIR
The 2021 FEIR determined that the Safety Element is a policy document that would not result in any physical development, and implementation of Safety Element policies by the City focused on increasing wildfire safety through increased coordination with fire protection agencies, using the latest mapping to determine wildfire risks, and supporting efforts to evaluate wildfire evacuation and safety planning. The 2021 FEIR determined that development of the Housing Sites, especially within or adjacent to VHFHSZ, could result in impacts related to wildfire. However, future ministerial and discretionary development at the Housing Sites would be required to adhere to all regulatory requirements in place to minimize wildfire hazards including applicable sections of the SCMC, fire and building codes, and requirements from the fire chief that would be identified during future building permit reviews. Additionally, implementation of General Plan Policies S-3.02 through S-3.06 in the City’s General Plan Safety Element would further protect land uses within the VHFHSZ and enhance wildfire safety. Therefore, the 2021 FEIR determined that the Housing and Safety Elements Update would not expose people or structures either directly or indirectly to a significant risk of loss, injury, or death involving wildland fires, and impacts would be less than significant.

Project
The project site is located in an urbanized area and is not within, or adjacent to, an area identified as a VHFHSZ. Therefore, the project would not result in new impact or substantially increase the severity of an impact related to exposure of people or structures to a significant risk of loss, injury, or death involving wildland fires compared to what was previously analyzed in the 2021 FEIR.

Infrastructure
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development that could result in fire risk. The 2021 FEIR determined that future ministerial and discretionary development at Housing Sites and associated infrastructure would be required to adhere to all regulatory requirements in place to minimize wildfire hazards including applicable sections of the SCMC, fire and building codes, and requirements from the fire chief that would be identified during future building permit reviews. Therefore, the 2021 FEIR determined that the Housing and Safety Elements Update would not require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment, and impacts would be less than significant.

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Project
As described in Section 15.19.a above, existing utility services are available adjacent to the site, and improvements would be limited to extension of pipelines onto the project site. Furthermore, the project would not increase demand for utility services beyond what was analyzed in the 2021 FEIR.

Consequently, the project would not project would not construct any infrastructure facilities.

Therefore, the project would not require the installation or maintenance of associated infrastructure that may a new or substantially greater fire risk than previously analyzed, and impacts would be less than significant. No new impact would occur.

Flooding and Landslides
2021 FEIR
The 2021 FEIR determined that the Safety Element Update is a policy document that would not result in any physical development that could result in fire risk. The 2021 FEIR determined that development of future Housing Sites would be required to comply with applicable regulations and policies related to flooding, drainage patterns, and landslides. Therefore, the 2021 FEIR determined that the Housing and Safety Elements Update would not expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes, and impacts would be less than significant.

Project
Review of Figure 4.8-2 of the 2021 FEIR determined that the project site is not located within a flood hazard zone. As described in Section 4.7. above, the Geologic and Seismic Hazards Review completed for the project determined that the majority of the project site is flat and would not be subject to landslides. Implementation of measures identified in the Geologic and Seismic Hazards Review would ensure protection against landslides. Therefore, the project would not expose people or structures to a new impact or a substantial increase in the severity of impacts related to downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage compared to what was previously analyzed in the 2021 FEIR.

16.0 Mitigation Monitoring and Reporting Program Incorporated into the project The project shall be required to comply with the applicable mitigation measures outlined within the MMRP of the previously certified PEIR, including measures incorporated by reference from the City’s General Plan Mitigation Monitoring Program, and those identified with the project-specific subsequent technical studies. The following MMRP presented in Table 18 below identifies measures that specifically apply to this project.

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Table 18
Mitigation, Monitoring, and Reporting Program Incorporated into the Project Mitigation Measure
Timing of
Verification
Responsible for
Verification
Status/
Date/
Initials
Biological Resources
MM -BIO-1: Nesting Migratory Birds
No direct impacts shall occur to any nesting birds, their eggs, chicks, or nests during the breeding season. If vegetation removal activities must occur during the bird breeding season of February 1 to September 15, then a pre-construction survey would be necessary to confirm the presence or absence of breeding birds within the temporary parking lot.

If nests or breeding activities are located on-site, then an appropriate buffer area around the nesting site shall be maintained until the young have fledged. The width of the buffer would be determined by a qualified biologist and biological monitoring would be required during construction. If no nesting birds are detected during the preconstruction survey, no avoidance measures would be required.

During
Construction
City of San
Clemente/
Qualified
Biologist
Cultural Resources
MM-CUL-1: Archaeological Monitoring
A qualified archaeologist shall be retained for the project to conduct the following monitoring activities during construction:
a. An archaeologist shall be on call during grading and other significant ground-disturbing activities.
b. Should any cultural/scientific resources be discovered, no further grading shall occur in the area of the discovery until the Community Development Director concurs in writing that
adequate provisions are in place to protect these resources. c. Unanticipated discoveries shall be evaluated for significance by an Orange County Certified Professional Archaeologist. If significance criteria are met, then the project shall be required to perform data recovery, professional identification,
radiocarbon dates as applicable, and other special studies; submit materials to the California State University Fullerton or local archival facility, where available; and provide a comprehensive final report including appropriate records for the California Department of Parks and Recreation (Building, Structure, and Object Record; Archaeological Site Record; or District Record, as applicable).

During
Construction
City of San
Clemente/
Qualified
Archaeologist
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Table 18
Mitigation, Monitoring, and Reporting Program Incorporated into the Project Mitigation Measure
Timing of
Verification
Responsible for
Verification
Status/
Date/
Initials
Geology and Soils
MM-PAL-1: Paleontological Resources Impact Mitigation Program A paleontologist who meets the qualifications established by the Society of Vertebrate Paleontology (SVP) shall be retained to develop a Paleontological Resources Impact Mitigation Program (PRIMP) for this project. The PRIMP shall be consistent with the standards of the SVP and include the methods that will be used to protect paleontological resources that may exist within the project site, as well as procedures for monitoring, fossil preparation and identification, curation into a repository, and preparation of a report at the conclusion of grading.

Prior to and
during
Construction
City of San
Clemente/
Qualified
Paleontologist
MM-PAL-2: Paleontological Monitoring
Excavation and grading activities in deposits with high paleontological sensitivity (i.e., the Capistrano Formation) shall be monitored by a qualified paleontological monitor following a PRIMP. No monitoring is required for excavations in deposits with no paleontological sensitivity (i.e., Artificial Fill). If paleontological resources are encountered during the course of ground disturbance, the paleontological monitor shall have the authority to temporarily redirect construction away from the area of the find. In the event that paleontological resources are encountered when a paleontological monitor is not present, work in the immediate area of the find shall be redirected, and the paleontologist or paleontological monitor shall be contacted to assess the find for scientific significance. If determined to be scientifically significant, the fossil shall be collected from the field.

During
Construction
City of San
Clemente/
Qualified
Paleontologist
MM-PAL-3: Paleontological Resources Report
Collected resources shall be prepared to the point of identification, identified to the lowest taxonomic level possible, cataloged, and curated into the permanent collections of a museum repository. At the conclusion of the monitoring program, a report of findings shall be prepared to document the results of the monitoring program.

During
Construction
City of San
Clemente/
Qualified
Paleontologist

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17.0 Checklist References
California Geological Survey (CGS)
2008 Special Publication 117A, Guidelines for Evaluating and Mitigating Seismic Hazards in California; originally adopted March 13, 1997 by the State Mining and Geology Board in Accordance with the Seismic Hazards Mapping Act of 1990, Revised and Re-Adopted September 11, 2008.

State of California Department of Conservation
2016 California Important Farmland Finder. https://maps.conservation.ca.gov/dlrp/ciff/ California Public Utilities Commission (CPUC)
2021 Renewables Portfolio Standard Annual Report, November 2021.

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San Clemente City CouncilNovember 1, 2022

San Clemente City Council
November 1, 2022